DANIELLE MARTINEZ V. GAVIN NEWSOM, No. 20-56404 (9th Cir. 2022)Annotate this Case
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.