Jason R. Pajtas v. Jonathan Bryant, Lincoln Charter School, and Trisha Amos

Pajtas v. Bryant · United States District Court for the Western District of North Carolina, Charlotte Division · March 10, 2026 · No. 3:25-CV-00930-KDB-DCK

Summary

The United States District Court for the Western District of North Carolina granted defendants’ motion to dismiss a pro se parent’s action arising from his minor son’s school suspension. The court held that the non-attorney parent could not litigate his son’s claims and lacked standing to assert individual claims because he alleged no legally cognizable injury of his own. The dismissal was without prejudice, and the Clerk was directed to close the matter.

Holdings

  1. A pro se, non-attorney parent may not generally litigate the claims of a minor child in federal court, and Plaintiff could not prosecute his son's claims without securing counsel.
  2. Plaintiff lacked Article III standing to assert individual claims because he alleged no cognizable injury to himself; the alleged harms belonged solely to his minor child.

Questions Presented

  1. Whether a pro se, non-attorney parent may litigate claims belonging to a minor child in federal court.
  2. Whether Plaintiff had Article III standing to assert individual claims when the alleged injuries belonged solely to his minor child.

Disposition

dismissed

Cases Cited (7)

  • Wojcicki v. SCANA/SCE&G, 947 F.3d 240, 243 (4th Cir. 2020)(followed)
  • Pridgen v. Andresen, 113 F.3d 391, 393 (2d Cir. 1997)(followed)
  • Myers v. Loudoun County Public Schools, 418 F.3d 395, 400-01 (4th Cir. 2005)(followed)
  • L.C. by & through Dunbar v. Charter School USA at Cary, LLC, No. 5:24-CV-66-FL, 2025 WL 819116, at *2 (E.D.N.C. Mar. 13, 2025)(followed)
  • Spokeo, Inc. v. Robins, 578 U.S. 330, 338, 341 (2016)(followed)
  • TransUnion LLC v. Ramirez, 141 S. Ct. 2190, 2204 (2021)(followed)
  • Garey v. James S. Farrin, P.C., 35 F.4th 917 (4th Cir. 2022)(followed)

Cited In (0)

No citing cases on record yet.

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