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
compress summary