Carlsbad, California – August 7, 2017. In July, Carlsbad attorneys Neal Meyers and Daniel Modafferi obtained summary judgment in favor of their clients, Redondo Beach Unified School District (“RBUSD”) and four of its individually-named school administrators. The plaintiffs in the case, Corey and Misty Camfield, are the parents of three children who attend schools within RBUSD. During the 2014-2015 school year, RBUSD issued what are commonly known as “Disruptive Parent Letters” to both Mr. and Mrs. Camfield, which restricted the parents’ access to a public elementary school campus following repeated disruptive incidents.
The Camfields filed suit in the United States District Court for the Central District of California, alleging that the Disruptive Parent Letters were issued in retaliation for their advocacy on behalf of their disabled son, and that the issuance of the letters violated various state and federal constitutional rights. In December 2016, the court dismissed the plaintiffs’ state law causes of action for failure to state a claim. Then, in July, the court granted summary judgment in favor of the defendants as to the federal claims.
As to plaintiffs’ claims of disability discrimination, the court held that the plaintiffs’ admitted disruptive behavior was a lawful basis on which RBUSD could restrict their access to the public school campus, and there was no evidence that plaintiffs’ son’s disability was a factor in RBUSD’s decision to issue the Disruptive Parent Letters.
With regard to plaintiffs’ claims under 42 U.S.C. section 1983 for deprivation of constitutional rights, the court held that parents do not have a constitutionally-protected right to access public school campuses. Indeed, the court observed that the Supreme Court has held school administrators have the right to immediately remove from school grounds individuals who pose a threat to the academic process. Reading the constitution to grant individuals – even parents – an unfettered liberty interest in access to sensitive places like an elementary school campus would leave school administrators powerless to protect the students therein.
The court’s ruling in this case re-affirms the authority of public school administrators to exclude disruptive persons from campuses. It further upholds the practice of restricting disruptive parents’ access to public school campuses through the summary issuance of Disruptive Parent Letters, a practice which is common among public school districts throughout California. A complete copy of the court’s ruling is available as follows: Order Granting Motion for Summary Judgment
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