Eva Loletta Wright, Individually and as Sole Surviving Parent of Daniel James Wright, a Deceased Minor v. Joe Lovin, Individually and in His Official Capacity as Clayton County School Superintendent Walter Stanford, Individually and in His Official Capacity as Administrative Assistant to the Clayton County School Superintendent Jim Lancaster, Individually and in His Official Capacity as a Principal for the Clayton Co. Bd. Of Ed. Richard Ashe, Individually and in His Official Capacity as an Assistant Principal for the Clayton Co. Bd. Of Ed. Winnie Anderson, Individually and in Her Official Capacity as a Teacher Employed by the Clayton Co. Bd. Of Ed. Patricia Hunt, Individually and in Her Official Capacity as a Teacher Employed by the Clayton Co. Bd. Of Ed. Clayton County Board of Education Clayton County School District
Docket: 93-9304
Court: Court of Appeals for the Eleventh Circuit; September 21, 1994; Federal Appellate Court
Eva Loletta Wright, as the surviving parent of deceased minor Daniel James Wright, appeals the district court's summary judgment against her claims under 42 U.S.C. § 1983 concerning alleged violations of her son's substantive due process rights under the Fourteenth Amendment by the Clayton County School District and various officials. Daniel, aged fifteen, died in an automobile accident after leaving a voluntary summer school session against school rules.
Wright contends that the defendants failed to enforce policies intended to safeguard students, constituting a violation of his rights. The appellate court reviews the summary judgment de novo to determine if any genuine issues of fact exist. The district court ruled that the school had no constitutional obligation to protect Daniel as he was not in its custody at the time of the accident, which was caused by a private party without a special relationship to the school. Wright argues that a special relationship exists, imposing a duty on the school to prevent students from leaving unsafely.
The court notes that substantive due process protections are limited to fundamental rights established by the Constitution, rather than by state law, indicating that tort claims typically do not fall under substantive due process protections.
The Due Process Clause does not mandate the State to protect individuals from harm by private actors, functioning instead as a limitation on state action rather than a guarantee of safety. In DeShaney v. Winnebago County, the Supreme Court rejected the notion that a constitutional duty of protection exists due to a state's 'special relationship' with an individual if the state did not contribute to the danger faced by that individual. A duty of protection may arise when the state restricts an individual's liberty, such as through incarceration or involuntary commitment, thus triggering the protections of the Due Process Clause.
In this context, the claim that schools have a constitutional duty to protect students from harm by third parties due to a special relationship has been consistently denied by federal circuit courts. Courts have determined that compulsory school attendance does not create the custody level necessary to impose such a duty. These rulings emphasize that mandatory school attendance does not restrict liberty in the same way as incarceration or institutionalization. Given that the specific case involved voluntary school attendance, the court concluded that this did not establish a custodial relationship sufficient to create a constitutional duty for the school to protect Daniel from injury.
Daniel's death did not violate his substantive due process rights, as it resulted from his own decision to leave school against school policies, rather than from any restraint on his liberty by the school. The school had implemented measures to keep students safe during school hours, and its failure to prevent Daniel from leaving does not constitute a constitutional violation. Additionally, a special relationship between the school and Daniel, which could establish a duty of protection, was not present. The school did not create the dangerous situation that led to Daniel's accident, nor did his voluntary attendance create a special relationship sufficient to impose a duty of care. Consequently, the district court's summary judgment favoring the defendants on Daniel's substantive due process claim is affirmed.
Wright's procedural due process claim is also without merit, and the district court's summary judgment on this issue is upheld. Furthermore, since Wright's claim regarding the violation of her substantive due process rights as a parent is based on the same facts as Daniel's claim, and it has been determined that Daniel's rights were not violated, Wright's claim is similarly dismissed. The district court's summary judgment is affirmed in all respects. There is a note of uncertainty regarding the continued validity of the precedent established in Cornelius, but this case is distinguished from it, and the court does not address the broader implications of that decision.
