Ratner v. Loudoun County Public Schools

A public-middle-school student, Benjamin Ratner (plaintiff) was told by a classmate that she had contemplated suicide the night before and had unintentionally brought a knife to school in her binder that morning. Ratner had known the classmate for two years and was aware of her previous suicide attempts, so he took the binder from her and put it in his school locker without ever opening the binder. Ratner intended to tell his parents and the classmate’s parents about the knife after school, but he did not report the knife to school authorities. The school dean received information about the knife and asked Ratner about it. Ratner admitted that the binder and knife were in his locker and, at the dean’s direction, got the binder and knife and gave them to the dean. The assistant principal suspended Ratner for 10 days for possessing a knife on school grounds in violation of the zero-tolerance policy of the Loudon County Public Schools (school district) (defendant). The school district held a hearing and suspended Ratner for the rest of the school term, or nearly four months. Ratner and his mother (plaintiff) brought an action in the district court and argued that Ratner’s suspension under the zero-tolerance policy for possession of weapons on school grounds violated Ratner’s due-process rights under the Fourteenth Amendment to the United States Constitution. The district court concluded that the school district’s notices and hearings during suspension proceedings to enforce the zero-tolerance policy met procedural-due-process requirements. The district court dismissed the complaint for failure to state a claim. Ratner and his mother appealed.