Muskrat v. Deer Creek Public Schools

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Paul and Melinda Muskrat brought a civil rights action on behalf of their disabled son against the school district where he attended school for several years and against certain school district employees. The Muskrats alleged that the defendants unconstitutionally subjected their son to timeouts and physical abuse. The school district moved to dismiss, arguing that the Muskrats had not exhausted their claims through administrative procedures established by the Individuals with Disabilities Education Act (IDEA). The district court denied this motion, ruling that the Muskrats had no obligation to exhaust their claims. The case then proceeded to discovery and the defendants eventually moved for summary judgment, arguing that no constitutional violation occurred. The district court agreed and granted defendants' motions. The Tenth Circuit affirmed in all respects. "First, plaintiffs' claims [did] not fail for lack of exhaustion. Second, reaching the merits, the district court did not err in concluding the defendants' conduct did not shock the conscience, nor did it have an obligation to evaluate the claims under the reasonableness standard of the Fourth Amendment." View "Muskrat v. Deer Creek Public Schools" on Justia Law