Summary
The United States District Court for the District of Connecticut considers Defendants’ motion to dismiss claims arising from enforcement of Connecticut’s child-care licensure requirements against three religious ministries. The court denies dismissal for lack of subject-matter jurisdiction, including under the Eleventh Amendment, but dismisses the federal claims under Rule 12(b)(6) for failure to plausibly allege violations of the First and Fourteenth Amendments. The court declines to exercise supplemental jurisdiction over the remaining state-law claims.
Topics
Practice areas
Questions Presented
- Whether the Eleventh Amendment deprived the court of subject-matter jurisdiction over plaintiffs' claims for prospective official-capacity relief and individual-capacity damages.
- Whether plaintiffs plausibly alleged that Connecticut's child-care licensure scheme or its application violated the First Amendment Free Exercise Clause.
- Whether plaintiffs plausibly alleged an Establishment Clause violation based on the agency's interpretation and enforcement of the religious-education exemption.
- Whether plaintiffs plausibly alleged an Equal Protection violation without identifying a similarly situated comparator.
- Whether plaintiffs plausibly alleged a procedural Due Process violation based on deprivation of a protected liberty or property interest.
- Whether the court should exercise supplemental jurisdiction over the state-law claims after dismissing all federal claims.
- Whether plaintiffs should receive leave to amend.
Holdings
- The Eleventh Amendment did not bar plaintiffs' claims for prospective injunctive and declaratory relief against defendants in their official capacities, nor their claims for damages against Audette and Proietti in their individual capacities. The Rule 12(b)(1) motion was therefore denied.
- Plaintiffs failed to plausibly allege that Connecticut's child-care licensing scheme is nonneutral or not generally applicable. The scheme is subject to rational-basis review and survives that review because licensing child-care services is rationally related to ensuring that providers meet children's health, educational, and social needs.
- Plaintiffs failed to plausibly allege an as-applied Free Exercise violation because the alleged statements that the exemption applied to services akin to Sunday or Hebrew School did not, without more, raise a slight suspicion of hostility toward plaintiffs' religious beliefs.
- Plaintiffs failed to plausibly allege that defendants preferred certain religions, acted with religious animus, or coerced plaintiffs to modify their religious practices. The Establishment Clause claim was dismissed under Rule 12(b)(6).
- Plaintiffs failed to plausibly allege an Equal Protection violation because they identified no similarly situated church, synagogue, or other comparator treated more favorably.
- Plaintiffs failed to plausibly allege a procedural Due Process claim because they did not establish a deprivation of a protected liberty or property interest; their asserted liberty interests were coextensive with the failed Free Exercise, Establishment Clause, and Equal Protection claims.
- After dismissing all federal claims, the court declined to exercise supplemental jurisdiction over the remaining state-law claims.
- Plaintiffs were granted leave to amend because they sought amendment for the first time in response to the motion to dismiss and represented that they could allege comparators supporting their federal claims.
Key quotations
“As discussed below, the motion to dismiss for lack of subject matter jurisdiction under Rule 12(b)(1) is denied. But the Court grants Defendants’ motion to dismiss for failure to state a claim under Rule 12(b)(6) on the ground that Plaintiffs fail to plausibly allege any of their federal claims.” (Section III)
“Specifically, all claims are dismissed without prejudice under Rule 12(b)(6) of the Federal Rules of Civil Procedure, but with leave to amend.” (Section IV)
Factual background
Plaintiffs are religious institutions providing educational and ministry activities for children of congregational members and claimed exemption from Connecticut's child-care licensure requirements under Conn. Gen. Stat. § 19a-77(b)(8). The Connecticut Office of Early Childhood investigated the programs, determined that plaintiffs did not qualify for the exemption, and issued notices or demands requiring them to cease unlicensed child-care operations or obtain licenses. Family Tree temporarily shut down while its license application was pending, and plaintiffs alleged that the agency provided no procedure to challenge or appeal the exemption determinations.
Procedural history
Plaintiffs filed the action on November 8, 2024, asserting federal Free Exercise, Establishment, Equal Protection, and Due Process claims, along with claims under the Connecticut Constitution and the Connecticut Religious Freedom Act. Their request for a temporary restraining order and preliminary injunction was denied as moot after defendants represented that they would not enforce the challenged licensure law against plaintiffs during the litigation. Defendants filed a motion to dismiss on March 3, 2025; the court denied dismissal for lack of jurisdiction, dismissed all claims without prejudice under Rule 12(b)(6), declined supplemental jurisdiction over the state claims, and permitted amendment.