November 30, 2021, Los Angeles, CA. Golnar Fozi, Jeremy Dwork, and Daniel Modafferi secured a directed verdict in favor of their clients, administrators of the Chaffey Joint Union High School District, in a civil rights lawsuit brought by a teacher employed by the District, in the United States District Court for the Central District of California.
The teacher, who was represented by Brandi Harper of Castillo Harper, APC, is a high school science teacher who also moonlights as a reserve police officer. In May 2019, the San Bernardino County Sheriff’s Department received an anonymous tip that a teacher at Rancho Cucamonga High School was in possession of a loaded firearm on campus. Sheriff’s Deputies responded to the school and informed the Principal of the report.
School officials escorted students out of the teacher’s classroom, and the Sheriff’s Deputies then conducted an investigation through which they confirmed that the teacher in fact had a loaded semi-automatic handgun in his classroom. As a general rule, possession of any firearm or ammunition on the grounds of any public or private K-12 school is a felony. However, the law makes exceptions for certain individuals, such as law enforcement officers. The Sheriff’s Deputies therefore detained the teacher until they could confirm his status as a reserve police officer and whether or not that status exempted him from the criminal penalties of the Gun Free School Zone Act.
Regardless of whether or not it was a felony for this teacher to possess a firearm in a school zone, however, Chaffey Joint Union High School District has a long-established policy that prohibits anyone from possessing any weapon on its campuses. This prohibition is broader than the Gun Free School Zone Act, as it also prohibits possession of firearms by off-duty law enforcement officers such as parents who attend their children’s sporting events. The school district has made only one exception to its general prohibition of firearms. The district’s Director of Campus Safety, who is himself a retired law enforcement officer, was explicitly granted permission to possess a firearm on school grounds, after he completed a series of safety certifications and training.
Evidence showed the teacher was aware of the school district’s policy prohibiting firearms but had nevertheless brought a loaded firearm to school on multiple occasions without notifying his administration or asking for an exception from the school district’s policy. Therefore, although the Sheriff’s Department decided not to move forward with criminal charges against the teacher, the school district disciplined the teacher for his violation of school district policy. The teacher received a written letter of warning and was transferred to a different high school within the district.
The teacher initially apologized to school district administrators, ostensibly acknowledging that it was a mistake to bring a loaded firearm onto a high school campus. Months later, however, the teacher filed a civil lawsuit against the school district, the Superintendent, the Assistant Superintendent, and the Principal, alleging that they had violated his Constitutional rights. In particular, the lawsuit alleged that the defendants had violated the teacher’s Fourth Amendment right to be free from unreasonable searches and seizures, as well as his First Amendment right to free speech.
The defendants successfully defeated the Fourth Amendment search and seizure claim on summary judgment, as the Court concluded that the Sheriff’s Deputies had probable cause sufficient to detain the teacher and seize his firearm while they investigated whether or not he had committed a felony by bringing the loaded firearm to school. The case therefore proceeded to trial on the First Amendment claim only.
Under the First Amendment claim, the teacher alleged that his possession of the firearm on school grounds was merely a pretext for the defendants’ true motivation, which was to punish the teacher for holding conservative political beliefs. At trial, testimony of the teacher, the Principal, the Assistant Superintendent, and the Superintendent were presented to the jury. However, none of these witnesses provided any testimony that proved retaliatory animus against the teacher’s political beliefs. At the conclusion of the plaintiff’s case, therefore, the defendants moved for a directed verdict. The Court granted a directed verdict in favor of all defendants, concluding that the plaintiff had not proffered evidence sufficient for any reasonable juror to find in his favor.
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