On June 27, 2014, a student with mental disabilities and his mother, joined by the Parent/Professional Advocacy League, filed this class action lawsuit in the United States District Court for the District of Massachusetts. Represented by the Center for Public Representation, the Bazelon Center, and private counsel, the plaintiffs brought suit under the Americans with Disabilities Act (ADA) (42 U.S.C. §§ 12111 et seq.) against the City of Springfield, its mayor, the Springfield Public Schools, and its Superintendent. The complaint alleged that the defendants operated a discriminatory public school system that consigned hundreds of children with mental health disabilities to the Public Day School. The plaintiffs sought injunctive and declaratory relief for ongoing violations of the ADA, including an order that the defendants provide the student plaintiff and the plaintiff class with school-based behavior services in neighborhood schools to afford them an equal educational opportunity and enable them to be educated in neighborhood schools with their peers without a disability.
On July 28, 2014, the defendants filed a motion to dismiss for failure to state a claim. The defendants asserted that the complaint did not meet Federal pleading standards and elements of the plaintiff’s ADA claim could not be proved. On August 14, 2014, the United States filed an amicus brief on the proceedings in support of the plaintiff. And on February 11, 2015, the plaintiffs filed an amended complaint, modifying their pleading to add the Disability Law Center as a plaintiff.
Judge Mark G. Mastroianni held a hearing on the defendants’ motion to dismiss on May 13, 2015. He denied the motion on November 19, 2015, ruling that, because plaintiffs pled sufficient facts to make a showing as to each element of their ADA claim, dismissal for failure to state a claim was inappropriate. 146 F.Supp.3d 414.
On October 16, 2015, the plaintiffs filed a motion to certify a class consisting of all students with a mental health disability who were or had been enrolled in Springfield Public Day School who were not being educated in a Springfield neighborhood school. Two months later, Judge Mastroianni denied the plaintiffs’ motion for class certification. 318 F.R.D. 210. The denial turned on the fact that although the named plaintiff had exhausted his administrative remedies under ADA and IDEA prior to litigation (the ADA ruling was appealed), the proposed members of the class had not. The Court held: "Exhaustion is not only required before a party can litigate issues arising under the IDEA; a litigating party must also exhaust before bringing suit “pursuant to a different statute so long as the party is seeking relief that is available under subchapter II of IDEA.”
On December 30, 2016, the plaintiffs filed an appeal on the District Court’s denial of class certification to the Court of Appeals for the First Circuit.
On April 8, 2017, the City of Springfield moved for judgment on the pleadings. It argued that the organization plaintiffs—the Disability Law Center, the Massachusetts advocacy system, and the Parent/Professional Advocacy League—did not have standing to sue. After a few months, the court stayed discovery until the resolution of the defendant's motion for judgment on the pleadings and the First Circuit's resolution of the plaintiff's class certification appeal. But on November 30, 2017, the parties agreed to dismiss the claims solely relating to S.S. as an individual, one of the named plaintiffs.
On March 8, 2018 the parties requested that the case be transferred to a court sponsored mediator for resolution. The court granted this motion and assigned the case to Magistrate Judge Kenneth P. Neiman. On July 19, 2018, the magistrate judge found in favor of the defendants. Although the plaintiffs had associational standing, they had failed to exhaust the administrative remedies requires by the Individuals with Disabilities in Education Act. 332 F.Supp.3d 367.
On August 9, 2018 the plaintiffs appealed this judgment to the First Circuit, which held oral arguments in June 2019. This appeal was consolidated with the appeals challenging the granting of judgment on the pleadings and the denial of class certification. On August 8, 2019, the First Circuit (Toruella, Lynch, and Kayatta) affirmed the district court's judgment but on partially different grounds. Specifically, the First Circuit upheld the district court's decision to deny class certification, and it found (contrary to the district court) that the organizational plaintiffs lacked standing. 934 F.3d 13.
The case is now closed.
Eric Wendorf - 10/06/2017
Keagan Potts - 03/19/2019
Hope Brinn - 05/16/2020
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