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Mary Doe John Doe, by and Through His Next Friend, Mary Doe v. Woodford County Board of Education William S. Foley, Dr., Chairperson and His Successor, in His Official Capacity as Member of the Woodford County Board of Education Ambrose Wilson, Iv, and His Successor, in His Official Capacity as Member of the Woodford County Board of Education Margie Cleveland, and Her Successor, in Her Official Capacity as Member of the Woodford County Board of Education David Moore, and His Successor, in His Official Capacity as Member of the Woodford County Board of Education P. T. Vance, and His Successor, in His Official Capacity as Member of the Woodford County Board of Education Charles L. Dowler, Dr., in His Individual Capacity, and His Successor, in His Official Capacity as Superintendent of the Woodford County Public Schools Corlia Logsdon, and Her Successor, in Her Official Capacity as Section 504 and Ada Coordinator for the Woodford County Public Schools Roy Chapman, in His Individual Capacity, as Principal, Woodfo

Citations: 213 F.3d 921; 10 Am. Disabilities Cas. (BNA) 1094; 2000 U.S. App. LEXIS 11752Docket: 99-5369

Court: Court of Appeals for the Sixth Circuit; May 26, 2000; Federal Appellate Court

Narrative Opinion Summary

In this case, Mary Doe filed a lawsuit on behalf of her son, John Doe, against the Woodford County Board of Education and individual school officials. The lawsuit alleged violations of Section 504 of the Rehabilitation Act, Title II of the Americans with Disabilities Act, FERPA, and due process rights. The conflict began when John, a hemophiliac and hepatitis B carrier, was placed on 'hold' status by his school's junior varsity basketball team pending medical clearance. The district court granted summary judgment in favor of the defendants, leading to an appeal. The appellate court affirmed the lower court's decision, finding no violations of the Rehabilitation Act, ADA, or FERPA. The court held that the defendants had acted within the bounds of the 'direct threat' exception, seeking to protect public health and safety by requiring medical evidence of John's ability to participate safely. Additionally, the court found no FERPA violation as the information shared was within permissible exceptions. Ultimately, the court concluded that John's due process rights were not infringed, supporting the district court's summary judgment for the defendants, as John voluntarily withdrew from the team.

Legal Issues Addressed

Direct Threat Exception under Disability Law

Application: The court found the defendants' actions justified under the 'direct threat' exception, as they reasonably sought medical evidence to determine if John's participation posed a significant risk.

Reasoning: The definition of 'direct threat' involves a significant risk to health and safety that cannot be avoided through modifications or auxiliary aids.

Due Process under the Fourteenth Amendment

Application: The court concluded that John's due process rights were not violated, as there was no deprivation of rights under the Rehabilitation Act, ADA, or FERPA.

Reasoning: Furthermore, the court finds that John Doe did not experience a deprivation of rights under the Rehabilitation Act, the Americans with Disabilities Act (ADA), or FERPA, and thus, his due process rights under the Fourteenth Amendment were not violated.

Family Educational Rights and Privacy Act (FERPA)

Application: The court determined no FERPA violation occurred as the information shared fell within exceptions allowing disclosure to school officials with a legitimate educational interest.

Reasoning: Disclosure of personally identifiable information from educational records is generally prohibited without written consent, but exceptions exist. Specifically, school officials, including teachers with a legitimate educational interest, can access such information.

Section 504 of the Rehabilitation Act and Title II of the Americans with Disabilities Act

Application: The court analyzed whether the defendants discriminated against John Doe by placing him on 'hold' status due to his medical condition, considering the need to protect public health and safety.

Reasoning: The plaintiff alleges violations of Section 504 of the Rehabilitation Act and Title II of the Americans with Disabilities Act (ADA) by the defendants. Section 504 prohibits discrimination against qualified individuals with disabilities in federally assisted programs, while Title II similarly protects such individuals in public entities.