You are viewing a free summary from Descrybe.ai. For citation checking, legal issue analysis, and other advanced tools, explore our Legal Research Toolkit — not free, but close.

Arceneaux ex rel. "Rebekka A." v. Assumption Parish School Board

Citations: 242 F. Supp. 3d 486; 2017 U.S. Dist. LEXIS 34310Docket: CIVIL ACTION NO.16-6554

Court: District Court, E.D. Louisiana; March 9, 2017; Federal District Court

Narrative Opinion Summary

In this case, the plaintiffs, parents of a female student, alleged that their daughter faced gender discrimination under Title IX and the Equal Protection Clause after being dismissed from a high school cheerleading squad for misconduct. The defendants, including the school board and school principal, successfully moved for summary judgment, arguing that the plaintiffs failed to substantiate their claims. The court found that the cheerleading disciplinary policy had been updated to require two suspensions for removal, aligning with other sports policies, thereby negating claims of gender discrimination. Additionally, the plaintiffs’ retaliation claim was dismissed as there was no material adverse action, given that the daughter was not subjected to drug testing. The court also denied the defendants' request for attorneys' fees, ruling the plaintiffs' case was not frivolous. Ultimately, the court dismissed the plaintiffs' claims with prejudice, finding no basis for discrimination or retaliation under Title IX or the Equal Protection Clause, and upheld the summary judgment for the defendants.

Legal Issues Addressed

Attorneys’ Fees under 42 U.S.C. § 1988(b)

Application: The court denied the request for attorneys' fees as the plaintiffs’ belief in the discriminatory nature of the discipline was deemed reasonable, and the case was not frivolous.

Reasoning: The court noted that the plaintiffs’ belief in the discriminatory nature of Rebekka's discipline was reasonable, leading to the conclusion that the case was not frivolous.

Equal Protection Clause of the Fourteenth Amendment

Application: The plaintiffs' claim under the Equal Protection Clause was dismissed as there was no evidence of different treatment from similarly situated individuals or discriminatory intent.

Reasoning: The Equal Protection Clause of the Fourteenth Amendment mandates equal legal protection, with gender discrimination claims necessitating evidence of different treatment from similarly situated individuals and discriminatory intent.

Retaliation Claim under Title IX

Application: The court dismissed the retaliation claim as the plaintiff was not subjected to drug testing and hence did not suffer a material adverse action.

Reasoning: The court found that Rebekka did not experience a material adverse action, as she was not subjected to drug testing upon her dismissal, and simply walking to the office was insufficient to qualify as such.

Summary Judgment Standard under Rule 56 of the Federal Rules of Civil Procedure

Application: The court granted summary judgment as there was no genuine dispute over material facts and the movant was entitled to judgment as a matter of law.

Reasoning: The summary judgment standard requires the court to grant judgment if there is no genuine dispute over material facts and the movant is entitled to judgment as a matter of law, as outlined in Rule 56 of the Federal Rules of Civil Procedure.

Title IX Gender Discrimination

Application: The plaintiffs failed to demonstrate intentional gender discrimination under Title IX as the disciplinary policy was updated to align with the athlete policy, requiring two suspensions for removal.

Reasoning: Despite claims of differing suspension policies, evidence indicates that at the time of Rebekka’s removal, the cheerleading policy had been updated to align with the athlete policy, requiring two suspensions for removal.