Laney v. Farley

Victoria Laney’s (plaintiff) cell phone began ringing during class in a public middle school, and the teacher confiscated it according to the code of conduct of the Wilson County Board of Education (county board) (defendant). Laney’s father (plaintiff) met with the school principal three days later to request return of the cell phone, but the principal refused because the county board’s code of conduct required a 30-day confiscation period and a one-day in-school suspension. Students serving an in-school suspension in Tennessee had to remain in the school setting and remain academically active. The following day, Laney reported to school and served the in-school suspension during which she was required to complete schoolwork. Laney did not receive a written note for her parents regarding the in-school suspension until after it was over. The parents were not made aware of the in-school suspension until Laney informed them about it afterward. The father filed suit against the county board in district court and claimed that the failure to provide notice and an opportunity to be heard before Laney served the one-day in-school suspension violated due-process rights under the Fourteenth Amendment to the United States Constitution. The district court found that requiring Laney to serve the one-day in-school suspension without notice to her parents and an opportunity to be heard violated procedural-due-process rights under the Fourteenth Amendment. The county board filed an interlocutory appeal.