Hatfield v. O'Neill

TH was a severely disabled student in the elementary school classroom of Diana O’Neill (defendant) for six years. TH was blind, nonverbal, and used a wheelchair. TH had the intellect of a one-year-old and suffered from seizures. In an effort to alleviate the seizures, surgeons removed a portion of TH’s brain, leaving TH with a soft, tender spot on her skull. The spot was so sensitive that even having her hair brushed caused TH pain. O’Neill was fully aware of TH’s condition. Two teacher aides were troubled by O’Neill’s treatment of TH. The aides reported that rather than apply Vaseline, per TH’s parents’ request, to TH’s severely chapped lips, O’Neill would rip the dry skin from TH’s lips, causing TH to bleed. The aides also reported that O’Neill would jam spoons violently into TH’s gums when feeding the child, causing bleeding. The aides reported that, in efforts to cease TH’s thumb sucking, O’Neill would stick O’Neill’s own thumb down TH’s throat, causing TH to gag and cry out in pain. Finally, the aides reported that, on one occasion, O’Neill backhanded TH on the soft spot on TH’s head in response to O’Neill’s frustration at TH failing a feeding exercise. After the aides submitted their reports, the school fired O’Neill. O’Neill was also charged with four counts of child abuse but was acquitted at trial. TH’s parents (plaintiffs) sued O’Neill pursuant to 42 U.S.C. § 1983, alleging that O’Neill violated TH’s substantive-due-process rights. The district court denied O’Neill’s motion for summary judgment, and O’Neill appealed.