Maple Run Unified School District v. Vermont Human Rights Commission
Annotate this CaseIn the case, Maple Run Unified School District (the District) appealed a trial court order which granted the Vermont Human Rights Commission (the Commission) a motion to dismiss the District’s complaint for lack of subject-matter jurisdiction. The dispute arose from a complaint of sexual harassment filed by a student in the District. The student's mother later filed a complaint with the Commission alleging that the District failed to comply with the Vermont Public Accommodations Act (VPAA), the anti-harassment provisions in Title 16, and the school’s own policy. The Commission decided to investigate the matter. The District filed a motion with the Commission to dismiss the investigation, arguing that federal regulations preempted Title 16 and the complaint failed to state a prima facie case of discrimination under the VPAA. The Commission denied the District’s motion and decided to continue the investigation. The District then filed a Rule 75 petition in the civil division against the Commission, which the Commission moved to dismiss arguing that there was no cognizable avenue for relief under Rule 75 and the superior court lacked subject-matter jurisdiction to review the petition. The court dismissed the District’s complaint. The District appealed claiming that subject-matter jurisdiction had been established under Rule 75 via either mandamus or prohibition. The Supreme Court of Vermont held that the Commission’s determination that the complaint states a prima facie case of discrimination under the VPAA is not reviewable under Rule 75 via either mandamus or prohibition, and therefore, the superior court did not err in dismissing the District’s petition.
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