D.L., a minor, by and through his next-of-friends, S.L. and R.L. v. Hernando County Sheriff's Office, a public entity, Deputy Paul Smith, School Resource Officer, in his individual capacity, and Hernando County School Board, a public entity

Summary

The United States District Court for the Middle District of Florida addresses claims arising from the involuntary examination of an autistic minor under Florida’s Baker Act. The court grants summary judgment for the Hernando County Sheriff’s Office and Hernando County School Board, denies the minor’s motion for summary judgment, and concludes that Deputy Paul Smith is entitled to qualified immunity on the Fourth Amendment claims while the ADA claims fail.

Holdings

1. Deputy Smith was entitled to qualified immunity on D.L.'s unreasonable-seizure claim because he acted within his discretionary authority, had arguable probable cause to believe that D.L. met the Baker Act criteria, and D.L. failed to show that the seizure violated a clearly established right.
2. Deputy Smith was entitled to qualified immunity on D.L.'s excessive-force claim because restraining D.L.'s feet and arms and, assuming Smith applied the handcuffs, handcuffing him were objectively reasonable responses to D.L.'s continued violent resistance and did not violate clearly established law.
3. HCSO was entitled to summary judgment on D.L.'s Title II ADA claim because D.L. failed to establish deliberate indifference by an official with substantial supervisory authority and therefore could not recover compensatory damages.
4. HCSB was entitled to summary judgment on D.L.'s ADA discrimination and failure-to-accommodate claims because the record did not show intentional discrimination, deliberate indifference, a denied requested accommodation, or knowledge of an accommodation that would mitigate D.L.'s behavior.
5. HCSB was entitled to summary judgment on D.L.'s § 1983 claim because D.L. failed to establish an unconstitutional policy or custom, a pattern of similar violations, or an obvious need for Baker Act training, and HCSB was not responsible for Smith's law-enforcement actions.

Questions Presented

1. Whether Deputy Smith was entitled to qualified immunity on D.L.'s Fourth Amendment unreasonable-seizure claim arising from the Baker Act commitment.
2. Whether Deputy Smith was entitled to qualified immunity on D.L.'s Fourth Amendment excessive-force claim based on restraining and handcuffing D.L.
3. Whether HCSO violated Title II of the ADA by failing to adopt or apply reasonable modifications for schoolchildren with disabilities and whether D.L. could recover compensatory damages.
4. Whether HCSB violated Title II of the ADA through intentional discrimination or failure to accommodate D.L.
5. Whether HCSB could be held liable under 42 U.S.C. § 1983 for allegedly failing to train Deputy Smith on Baker Act procedures.

Disposition

other