A.S. v. Point Quest et al.

Summary

The United States District Court for the Eastern District of California denied Point Quest and Hannah Smith’s motion for partial judgment on the pleadings. The court held that the allegations plausibly supported a 42 U.S.C. § 1983 claim against Smith based on state-action theories, a Rehabilitation Act claim against Point Quest, a California Education Code § 220 claim, and an intentional infliction of emotional distress claim against Point Quest. The action concerns alleged physical restraints and mistreatment of a minor student with autism and intellectual disabilities at a non-public special-education school.

Holdings

1. A.S. plausibly alleged that Smith acted under color of state law because the complaint supported the joint-action, governmental-compulsion, and governmental-nexus tests.
2. A.S. plausibly alleged a Rehabilitation Act claim because the alleged repeated restraints supported an inference that she was denied meaningful access to educational services because of her disability, that the conduct was intentional or deliberately indifferent, and that Point Quest received federal financial assistance.
3. A.S. plausibly alleged that Point Quest was a recipient of state financial assistance, defeating the Rule 12(c) challenge to the section 220 claim.
4. A.S. plausibly alleged an intentional infliction of emotional distress claim against Point Quest because the complaint identified the claim as asserted against all defendants and alleged that Smith committed the conduct within the scope of her employment, permitting attribution to Point Quest under respondeat superior.

Questions Presented

1. Whether A.S. plausibly alleged that Smith, a private-school employee, acted under color of state law for purposes of the section 1983 claim.
2. Whether A.S. plausibly alleged that Point Quest intentionally discriminated against her because of her disability and received federal financial assistance, as required for the Rehabilitation Act claim.
3. Whether A.S. plausibly alleged that Point Quest received or benefited from state financial assistance for purposes of California Education Code section 220.
4. Whether A.S. plausibly alleged an intentional infliction of emotional distress claim against Point Quest based on Smith's alleged conduct and respondeat superior.

Disposition

other