Don Huizenga v. ISD No. 11, No. 21-2418 (8th Cir. 2022)
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Three Anoka County residents sued a school district and teachers’ union about their union leave and reimbursement plan, alleging constitutional and statutory violations. The district court dismissed the case for lack of standing. The residents appealed.
The Eighth Circuit reversed the district court’s judgment. The court explained that pleading jurisdiction requires only “a short and plain statement of the grounds for the court’s jurisdiction,” while pleading the merits requires not just “a short and plain statement of the claim,” but one that “show[s] that the pleader is entitled to relief.” Here, the residents adequately alleged they are school district taxpayers and identified a “municipal action” contributing to their injury. Specifically, the school district spends tax revenues on the allegedly illegal action because the collective-bargaining agreement requires it to provide up to 100 days of paid leave, and the union does not fully reimburse that expense. Since the district court did not address the preliminary injunction factors, the common approach is to remand for the district court to conduct the full analysis in the first instance.
Court Description: [Per Curiam - Before Gruender, Benton, and Erickson, Circuit Judges] Civil case - Civil rights. In this action three Anoka County residents sued a school district and a teachers' union over the union leave and reimbursement plan, alleging the the defendants' policy of allowing teachers to take paid union leave to work for the collective-bargaining representative of the teachers was a violation of the Free Speech Clause; the district court dismissed the case for lack of standing; while plaintiffs did not have standing as state taxpayers, they had adequately alleged that they are school district taxpayers and had identified a municipal action contributing to their injury, and the district court erred in concluding they did have municipal taxpayer standing; reversed for further proceedings to address the preliminary injunction application.
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