Newsome v. Batavia Local School District

A public high-school student (plaintiff) was accused by the principal of trying to sell a marijuana cigarette while at school, and the principal would not reveal the names of two student informants. The following week, the Batavia Local School District (school district) (defendant) superintendent held a suspension hearing at which the principal explained the accusations without naming the two informants, the student denied the accusations, and the superintendent ultimately expelled the student for the rest of the fall semester. The student appealed to the school-district board, which did not allow the student’s attorney to question the principal or superintendent regarding the evidence against the student before unanimously affirming the expulsion. The student filed an action in the district court against the school district. The student claimed that the administrative procedures violated procedural-due-process rights under the Fourteenth Amendment to the United States Constitution because the student was not informed of the evidence against him by school administrators. The district court conducted a hearing at which the superintendent admitted he presented evidence regarding the accusations and informants to the school-district board during closed deliberations. The district court found that the school district’s administrative procedures did not violate the student’s procedural-due-process rights. The district court denied the student’s request for an injunction to prevent expulsion and to receive financial compensation for injuries. The student appealed the matter.