Lucas v. Henrico Cty. Pub. Sch. Bd. (U)

The district court erred in concluding that it lacked subject-matter jurisdiction over the plaintiffs’ federal civil rights claims.

The plaintiffs, a parent and two education advocates, raised numerous claims against the Henrico County School Board and related defendants arising from a protest the plaintiffs staged at the parent’s child’s former elementary school. The school had involuntarily unenrolled him, which the plaintiffs attribute to disability discrimination. The protest led to the plaintiffs’ arrest and convictions for trespassing.

The relief the plaintiffs sought for their federal civil rights claims would have been against the defendants; it did not include modifying their state court convictions. Thus, the district court didn’t lack subject-matter jurisdiction under the Rooker-Feldman doctrine.¬†Moreover, even if Younger abstention was proper, as the district court concluded, the district court should have stayed rather than dismissed the civil rights claims, because the plaintiffs sought damages as well as declaratory and injunctive relief. Finally, because the erroneous dismissal of all federal claims led the district court to decline supplemental jurisdiction over the plaintiffs’ state law claims, that portion of the judgment will be vacated.

However, the district court properly dismissed claims against Henrico prosecutors and a judge based on prosecutorial and judicial immunity.

Affirmed in part, vacated in part, and remanded.

Lucas v. Henrico Cty. Pub. Sch. Bd. (U), No. 18-2215, Apr. 12, 2019. 4th Cir. (per curiam) from EDVA at Richmond (Hudson).



Categories: 4th U.S. Circuit Court of Appeals, Opinions, Unpublished

Tags: , ,

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