Mary Stephens, Individually and as Guardian of A’Moriyah Stephens v. Helena-West Helena School District; Tony Roach, Principal in His Individual and Official Capacity; Xavier Hodo, Superintendent, in His Individual and Official Capacity; and Helena-West Helena School District Board of Directors, in Their Official Capacity

Summary

The United States District Court for the Eastern District of Arkansas addresses several motions in a pro se action concerning a student's education, including claims under Section 504 of the Rehabilitation Act, the Americans with Disabilities Act, and alleged denial of a free appropriate public education. The court denies motions to strike affirmative defenses and for service, conditionally grants motions to amend and supplement, and directs the plaintiffs to file a unified second amended complaint. The court also orders Mary Stephens to explain citations to two apparently nonexistent cases and refers her to the obligations and potential consequences under Federal Rule of Civil Procedure 11.

Holdings

1. The motion to strike the District defendants' affirmative defenses was denied because, at this early stage, the defendants needed only to assert that the defenses might apply.
2. The motion for service was denied as moot because all District defendants had already been served in state court.
3. The motions to amend and supplement the complaint were conditionally granted, subject to filing a second amended complaint by February 17, 2026 that consolidates all allegations and claims and identifies, for each claim, the claimant, supporting facts, and requested relief.
4. After the second amended complaint is filed, the District defendants may renew their standing arguments and raise other applicable threshold arguments in a motion to dismiss.
5. The court ordered Stephens to file an explanatory notice by February 6, 2026 concerning her citation of two cases that the court determined did not exist.

Questions Presented

1. Whether the plaintiff's motion to strike the defendants' affirmative defenses should be granted at the early pleading stage.
2. Whether the plaintiff's motion for service should be granted after all defendants had already been served in state court.
3. Whether the plaintiff should be allowed to amend and supplement the complaint to add her husband and A’Moriyah and to consolidate all allegations and claims in one pleading.
4. Whether the plaintiff must explain her citation of two cases that the court determined did not exist.

Disposition

other