Timothy Williams v. Houston Community College, et al.

Summary

The United States District Court for the Southern District of Texas grants defendants’ Rule 12(b)(6) motion in Timothy Williams’s action concerning his suspension from Houston Community College. The court dismisses Williams’s federal claims, including claims under 42 U.S.C. § 1983, the ADA, and the Rehabilitation Act, with prejudice, and dismisses his Texas-law claims without prejudice under 28 U.S.C. § 1367(c).

Holdings

1. Williams failed to state a Section 1983 claim against HCC because he did not identify a policymaker or plead facts showing that an official policy or custom was the moving force behind a constitutional violation.
2. Williams failed to overcome the employees' qualified-immunity defense because he did not plead specific facts showing both a constitutional or statutory violation and violation of a clearly established right.
3. Williams failed to state a procedural due process claim sufficient to overcome qualified immunity because he did not plausibly allege denial of an opportunity to be heard at a meaningful time and in a meaningful manner, and no clearly established precedent made the alleged procedures unconstitutional.
4. Williams failed to state an equal protection claim because he did not identify a similarly situated comparator treated differently or plead facts demonstrating discriminatory intent.
5. Williams could not maintain a Fifth Amendment due process claim against the HCC employees because he did not allege that they were federal actors.
6. Williams failed to state a Section 1983 claim based on the FAFSA Simplification Act or the Higher Education Act because he did not show that either statute unambiguously created privately enforceable substantive rights.
7. Williams failed to state a First Amendment retaliation claim because he did not plausibly allege that retaliatory animus was the but-for cause of his suspension.
8. Williams failed to state claims under Title II of the ADA or Section 504 of the Rehabilitation Act because he did not adequately allege a qualifying disability or that his suspension was because of that disability.
9. Williams failed to state a Title VI claim because he did not identify his race, color, or national origin and did not plead facts showing intentional discrimination or disparate treatment because of a protected characteristic.
10. The court declined to exercise supplemental jurisdiction over the remaining Texas-law claims after dismissing all federal claims and dismissed those claims without prejudice under 28 U.S.C. § 1367(c).

Questions Presented

1. Whether Williams adequately pleaded Section 1983 claims against HCC for municipal liability.
2. Whether Williams adequately pleaded Section 1983 claims against HCC employees despite their qualified-immunity defense.
3. Whether Williams stated procedural due process, equal protection, Fifth Amendment, FAFSA Simplification Act, or First Amendment retaliation claims under Section 1983.
4. Whether Williams adequately pleaded claims under Title II of the ADA and Section 504 of the Rehabilitation Act.
5. Whether Williams adequately pleaded a Title VI claim based on intentional race, color, or national-origin discrimination.
6. Whether the court should exercise supplemental jurisdiction over the Texas-law claims after dismissing all federal claims.

Disposition

dismissed