Fields v. Palmdale School District

A mental-health counselor at an elementary school within the Palmdale School District (the district) (defendant) sent letters to the parents of students in the first, third, and fifth grades. The letters requested that the parents consent to allowing their children to participate in a survey related to early trauma. The letter informed the parents that the survey contained questions that may make students feel uncomfortable but did not expressly inform the parents that the survey asked the students questions of a sexual nature. Following the administration of the survey, multiple parents discovered that the survey had asked their children questions that were sexual in nature. In response, a group of parents (plaintiffs) filed an action in federal court against the district. The parents claimed that they would have withheld their consent had they known that the survey asked questions of a sexual nature and that their constitutional right to control their child’s upbringing under the Due Process Clause of the Fourteenth Amendment to the United States Constitution had been violated. The district court dismissed the claim for failure to state a cause of action. The parents appealed to the United States Court of Appeals for the Ninth Circuit. The court of appeals affirmed. The parents filed a petition for a rehearing. The petition was granted.