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 a mental health disability to the separate and inferior 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 failed to state a claim upon which relief could be granted because the plaintiff’s 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.
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.
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.
On December 16, 2016, 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. Litigation in the First Circuit continues.
Eric Wendorf - 10/06/2017
compress summary
