DANIELLE MARTINEZ V. GAVIN NEWSOM, No. 20-56404 (9th Cir. 2022)
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In a putative class action, Plaintiffs alleged that Defendants violated the Individuals with Disabilities Education Act and the Fourteenth Amendment, and they sought declaratory and injunctive relief. The Ninth Circuit affirmed in part and vacated in part the district court’s dismissal of claims brought by a group of students and parents who alleged that every school district in California failed to adequately accommodate special needs students after California public schools transitioned to remote instruction in March 2020 in response to the COVID-19 pandemic.
The panel held that Plaintiffs lacked standing to sue school districts in which they were not enrolled and the State Special Schools, which they did not attend because they did not allege that those Defendants injured them personally. The panel held that even if the “juridical link” doctrine, provides an exception to the rule that a named plaintiff who has not been harmed by a defendant is generally an inadequate and atypical class representative for purposes of Fed. R. Civ. P. 23, ever applies outside of the Rule 23 context, it would not apply here.
The panel held that the California public schools’ return to in-person instruction mooted Plaintiffs’ claims against the California Department of Education and the State Superintendent of Public Education, as well as their claims against other defendants seeking injunctions requiring a return to in-person instruction or reassessment and services until students return to in-person instruction. The panel vacated the district court’s judgment dismissing on the merits the claims that Plaintiffs lacked standing to bring and remanded with instruction to dismiss those claims for lack of subject-matter jurisdiction.
Court Description: Individuals with Disabilities Education Act. The panel affirmed in part and vacated in part the district court’s dismissal of claims brought by a group of students and parents who alleged that every school district in California failed to adequately accommodate special needs students after California public school transitioned to remote instruction in March 2020 in response to the COVID-19 pandemic. In this putative class action, plaintiffs alleged that defendants violated the Individuals with Disabilities Education Act and the Fourteenth Amendment, and they sought declaratory and injunctive relief. The district court dismissed plaintiffs’ claims for failure to exhaust administrative remedies under the IDEA. The panel held that plaintiffs lacked standing to sue school districts in which they were not enrolled and the State Special Schools, which they did not attend, because they did not allege that those defendants injured them personally. The panel held that, even if the “juridical link” doctrine, providing an exception to the rule that a named plaintiff who has not been harmed by a defendant is generally an inadequate and atypical class representative for purposes of Fed. R. Civ. P. 23, ever applies outside of the Rule 23 context, it would not apply here. MARTINEZ V. NEWSOM 5 The panel held that the California public schools’ return to in-person instruction mooted plaintiffs’ claims against the California Department of Education and the State Superintendent of Public Education, as well as their claims against other defendants seeking injunctions requiring a return to in-person instruction or reassessment and services until students return to in-person instruction. Surviving were plaintiffs’ claims against the school districts in which they were enrolled seeking compensatory education, a declaratory judgment, and attorneys’ fees and costs. The panel held that under the IDEA, plaintiffs were required to exhaust administrative remedies before filing their claims against their school districts, seeking relief for the denial of a free and appropriate public education (FAPE) during the time they were receiving remote instruction. The panel held inapplicable exceptions to the exhaustion requirement for when plaintiffs seek systemic or structural relief, when it is improbable that adequate relief can be obtained by pursuing administrative remedies, or when exhaustion would be futile. For the systemic exception, plaintiffs did not satisfy the requirement that they identify an agency decision, regulation, or other binding policy that caused their injury. The inadequacy exception did not apply because even though some of their claims were based on the Fourteenth Amendment, plaintiffs sought relief for the denial of a FAPE, and unnamed class members were not required to exhaust. The panel declined to consider for the first time on appeal plaintiffs’ argument regarding the futility exception. The panel also declined to consider an argument regarding exhaustion of a claim for breach of a settlement agreement because such a claim was not included in the complaint. 6 MARTINEZ V. NEWSOM The panel vacated the district court’s judgment dismissing on the merits the claims that plaintiffs lacked standing to bring and remanded with instruction to dismiss those claims for lack of subject-matter jurisdiction. The panel vacated the district court’s judgment as to the claims against the California Department of Education and the State Superintendent of Public Education, which were moot, and remanded with instructions to dismiss those claims. The panel affirmed the district court’s dismissal of the claims against plaintiffs’ school districts for failure to exhaust administrative remedies. Concurring, Judge Lee wrote separately to urge laying to rest a potential “juridical link” exception to Article III standing. Judge Lee wrote that the majority opinion declined to address whether the juridical link doctrine could ever be viable, reasoning that plaintiffs lacked standing here even if the panel assumed the doctrine applied. Judge Lee wrote that he would prefer extinguishing the remaining embers of any such misguided exception to constitutional standing.
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