Joshua Harrell v. Andrew Coop, et al.

Summary

The United States District Court for the District of Maryland considers Defendants’ motion to dismiss a pro se plaintiff’s 42 U.S.C. § 1983 claims arising from disciplinary proceedings at the University of Maryland School of Pharmacy. The court addresses Eleventh Amendment immunity, including the Ex parte Young exception, and grants Defendants’ motion to dismiss while denying Plaintiff’s motion for sanctions.

Holdings

1. The individual defendants were immune under the Eleventh Amendment from the plaintiff's § 1983 claims to the extent they were sued in their official capacities, and those claims had to be dismissed for lack of subject matter jurisdiction.
2. Qualified immunity barred the plaintiff's individual-capacity claims for monetary relief because the alleged disciplinary actions did not violate a clearly established First Amendment right.
3. The plaintiff's request for injunctive relief was moot, and declaratory relief was improper because there was no continuing violation, damages were unavailable, and the request for injunctive relief was moot.
4. The plaintiff was not entitled to Rule 11 sanctions because the challenged discrepancies in the defendants' filings were minor and did not establish that the factual assertions lacked an objective factual basis.

Questions Presented

1. Whether the individual defendants were immune under the Eleventh Amendment from official-capacity claims under 42 U.S.C. § 1983.
2. Whether qualified immunity barred individual-capacity claims for damages based on the defendants' initiation of disciplinary proceedings in response to alleged disruptive student conduct.
3. Whether the plaintiff's requests for injunctive and declaratory relief were moot or otherwise unavailable after the plaintiff stopped attending the university and the disciplinary process was halted.
4. Whether the defendants' alleged factual discrepancies in motion papers warranted sanctions under Federal Rule of Civil Procedure 11.

Disposition

dismissed