University of Michigan Law School
Civil Rights Litigation Clearinghouse
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Case Name Westfield High Sch. L.I.F.E. Club v. Westfield Pub. Sch. ED-MA-0001
Docket / Court 3:03-cv-30008-FHF ( D. Mass. )
State/Territory Massachusetts
Case Type(s) Education
Case Summary
On January 13, 2003, several student members of the Westfield High School L.I.F.E. Club filed a lawsuit in the U.S. District Court for the District of Massachusetts under 42 U.S.C. § 1983 and the Declaratory Judgment Act, 28 U.S.C. § 2201, against the City of Westfield, Massachusetts. The ... read more >
On January 13, 2003, several student members of the Westfield High School L.I.F.E. Club filed a lawsuit in the U.S. District Court for the District of Massachusetts under 42 U.S.C. § 1983 and the Declaratory Judgment Act, 28 U.S.C. § 2201, against the City of Westfield, Massachusetts. The complaint alleged that the defendant violated the plaintiffs' freedom of speech, assembly, and free exercise of religion under the First Amendment's Establishment Clause and Free Exercise Clause, and unlawfully discriminated against them based on the religious content of their speech in violation of the Equal Access Act, 20 U.S.C. § 4071, and the Fourteenth Amendment's Equal Protection Clause. The plaintiffs also alleged violation of their freedom of expression under Massachusetts state law. The plaintiffs, represented by private counsel and Alliance Defending Freedom (formerly "Alliance Defense Fund"), a Christian non-profit organization, requested a declaratory judgment, injunctive relief, and damages.

More specifically, the plaintiffs claimed that Westfield High School's policies and practices which prohibited and punished them for distributing religious literature, were discriminatory, content-based, vague, and acted as an unconstitutional prior restraint on speech. The alleged discrimination began during the 2001-2002 school year, when the plaintiffs were denied permission to distribute candy canes along with a religious story of the candy cane and Bible verses, to students at the school during non-instructional time. In 2002, the plaintiffs were again denied permission to distribute the literature, on the basis that the material was "offensive." The plaintiffs distributed the materials with the religious content anyway and were suspended as a consequence.

On January 13, 2003, along with their complaint, the plaintiffs moved for a preliminary injunction, requesting the Court enjoin the defendants from enforcing the allegedly unconstitutional policies and the suspensions on the plaintiffs. Both the ACLU of Massachusetts and the United States filed briefs as amici curiae in support of the plaintiffs' motion, on February 26 and February 20, respectively. Following a hearing, the District Court (Judge Frank H. Freedman) granted the plaintiffs' motion on March 17. Westfield High Sch. L.I.F.E. Club v. City of Westfield, 249 F. Supp. 2d 98, 108-109, 127-28 (D. Mass. 2003).

On April 7, 2003, the defendants filed a motion to stay, which the Court denied on April 16. On April 16, the plaintiffs amended their complaint to add the City of Westfield as a defendant and remove Westfield Public Schools as a party. The plaintiffs also moved for summary judgment.

On June 13, 2003, the Court entered a stipulation of dismissal of the claims against the individual defendants.

On June 16, 2003, the Court entered a consent decree, which proclaimed that the defendants had replaced the school speech policies with new agreed-upon rules. The defendants also agreed to rescind punishment of the plaintiffs for the distribution of the religious materials, remove prior restraints and content-based restrictions of distribution of materials during non-instructional time without complying with substantive and procedural safeguards, so long as distribution doesn't substantially and materially disrupt the operation of the school or the new policies. The plaintiffs were awarded $28,500 in attorneys' fees and costs and the case was closed.

Stella Cernak - 03/14/2014


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Issues and Causes of Action
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Issues
Constitutional Clause
Equal Protection
Establishment Clause
Free Exercise Clause
Freedom of speech/association
Content of Injunction
Discrimination Prohibition
Defendant-type
Elementary/Secondary School
Discrimination-basis
Religion discrimination
Plaintiff Type
Private Plaintiff
Type of Facility
Government-run
Causes of Action State law
Declaratory Judgment Act, 28 U.S.C. § 2201
42 U.S.C. § 1983
Defendant(s) The City of Westfield
Plaintiff Description Several high school students who were prohibited from distributing religious literature to fellow students during non-instructional time during the school day.
Indexed Lawyer Organizations None on record
Class action status sought No
Class action status granted No
Prevailing Party Plaintiff
Public Int. Lawyer Yes
Nature of Relief Attorneys fees
Injunction / Injunctive-like Settlement
Source of Relief Settlement
Form of Settlement Court Approved Settlement or Consent Decree
Order Duration 2003 - n/a
Case Closing Year 2003
Case Ongoing No
Additional Resources
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Case Studies Courts and Kids: Pursuing Educational Equity Through the State Courts
By: Michael Rebell (Columbia University, and Campaign for Educational Equity)
Citation: (University of Chicago Press, 2009)
[ Detail ] [ External Link ]

Docket(s)
3:03-CV-30008-FHF (D. Mass.) 03/04/2009
ED-MA-0001-9000.pdf | Detail
PACER [Public Access to Court Electronic Records]
General Documents
Verified Complaint for Preliminary and Permanent Injunctive Relief, Declaratory Relief and Damages 01/13/2003
ED-MA-0001-0001.pdf | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Order Granting Plaintiffs' Motion for Preliminary Injunction (249 F. Supp. 2d 98) 03/17/2003 (D. Mass.)
ED-MA-0001-0002.pdf | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Second Verified Amended Complaint 04/16/2003
ED-MA-0001-0003.pdf | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Order Entering Plaintiffs' Consent Decree 06/16/2003 (D. Mass.)
ED-MA-0001-0004.pdf | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Judges Freedman, Frank Harlan (FISC, D. Mass.)
ED-MA-0001-0002 | ED-MA-0001-0004 | ED-MA-0001-9000
Monitors/Masters None on record
Plaintiff's Lawyers Emmons, Bertin C. (Massachusetts)
ED-MA-0001-0001 | ED-MA-0001-0003 | ED-MA-0001-9000
Oster, Joel L. (Kansas)
ED-MA-0001-0001 | ED-MA-0001-0003 | ED-MA-0001-9000
Stanley, Erik William (Florida)
ED-MA-0001-0001 | ED-MA-0001-0003 | ED-MA-0001-0004 | ED-MA-0001-9000
Staver, Anita L (Florida)
ED-MA-0001-0001 | ED-MA-0001-0003 | ED-MA-0001-9000
Staver, Mathew D. (Florida)
ED-MA-0001-0001 | ED-MA-0001-0003 | ED-MA-0001-9000
Defendant's Lawyers Martin, Peter H. (Massachusetts)
ED-MA-0001-0004 | ED-MA-0001-9000
Mulvaney, Edward P. (Massachusetts)
ED-MA-0001-0004 | ED-MA-0001-9000
Thompson, Claire L (Massachusetts)
ED-MA-0001-0004 | ED-MA-0001-9000
Other Lawyers Berman, Amy I. (District of Columbia)
ED-MA-0001-9000
Caspar, Edward G. (District of Columbia)
ED-MA-0001-9000
Glassman, Jeremiah (District of Columbia)
ED-MA-0001-9000
Marshall, Franz (District of Columbia)
ED-MA-0001-9000
Newman, William C. (Massachusetts)
ED-MA-0001-9000
Pyle, Jeffrey Jackson (Massachusetts)
ED-MA-0001-9000
Treene, Eric W. (District of Columbia)
ED-MA-0001-9000

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