Christiansen v. West Branch Community School, et al., No. 11-1904 (8th Cir. 2012)
Annotate this CasePlaintiff, a licensed Iowa educator, filed suit in Iowa state court against his employer, school officials, and private citizens following his termination. Plaintiff alleged various state-law claims as well as violations of his procedural and substantive due process rights under 42 U.S.C. 1983. On appeal, plaintiff challenged the denial of his motion to remand and the dismissal of his section 1983 claims. The court held that the district court did not err in denying the motion to remand where, based upon the facts of the case, the unanimity requirement was satisfied. The court also held that the district court did not err in dismissing plaintiff's procedural due process claims as unexhausted where he failed to appeal his termination to an adjudicator under Iowa Code 279.17 and in dismissing plaintiff's substantive due process claim where he failed to plausibly plead a substantive due process claim. Accordingly, the court affirmed the judgment.
Court Description: Civil case - Civil Rights. Under the facts presented, the district court did not err in denying the motion to remand; the district court did not err in dismissing plaintiff's procedural due process claims as unexhausted because he failed to appeal his termination to an adjudicator under Iowa Code Sec. 279/17; district court did not err in dismissing substantive due process claims as insufficiently pled.
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