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L.R. v. School District of Philadelphia

836 F.3d 235 (2016)

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L.R. v. School District of Philadelphia

United States Court of Appeals for the Third Circuit
836 F.3d 235 (2016)

Facts

Jane was a kindergarten student in a public school in the School District of Philadelphia (defendant). Reginald Littlejohn (defendant) was Jane’s teacher. An adult female went to Jane’s classroom and attempted to take Jane. Littlejohn asked the adult for identification and authorization that she was allowed to take Jane from the school. The adult did not provide any identification or authorization, but Littlejohn let her take Jane anyway. The adult was a complete stranger to Jane and sexually assaulted Jane later that day, severely injuring her. The adult released Jane early the next morning, and a sanitation worker found her after hearing her cries. Jane’s mother, L.R. (plaintiff), sued Littlejohn and the school district in federal district court under 42 U.S.C. § 1983. The complaint alleged that Littlejohn’s action of releasing Jane to an unidentified adult had violated Jane’s constitutional rights. Littlejohn moved to dismiss the claims against him, arguing that the doctrine of qualified immunity protected him from claims based on actions taken in his capacity as a state official, namely, a public-school teacher. The district court found that, under the doctrine of state-created danger, qualified immunity did not apply to these claims, and it denied Littlejohn’s motion. Littlejohn appealed.

Rule of Law

Issue

Holding and Reasoning (Fuentes, J.)

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