On June 27, 2014, the plaintiffs, a mentally disabled student 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. The plaintiffs brought suit under the Americans with Disabilities Act (ADA) against the City of Springfield, the Mayor of the City of Springfield, the Springfield Public Schools and the Superintendent of Springfield Public Schools. 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 of America 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 Disability Law Center as a plaintiff in the case.
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 for class certification 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. 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. This motion challenged that the organization plaintiffs—the Disability Law Center, the Massachusetts advocacy system, 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 Neiman. On June 1, 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 8, the plaintiffs appealed this judgment to the First Circuit, which held oral arguments in June 2019. The case is ongoing.
Eric Wendorf - 10/06/2017
Keagan Potts - 03/19/2019
compress summary
