H.P. v. Naperville Cmty. Unit Sch. Dist.
Opinion of the Court
*959The plaintiff H.P., a minor, through her father W.P., claims that the defendant Naperville Community Unit School District #203 violated H.P.'s rights under the Americans with Disabilities Act and the Rehabilitation Act by disallowing H.P. from completing high school in District #203 after she moved to another school district. In the case below, the district court granted summary judgment to the District and denied it to H.P. We affirm.
I. Background
The defendant Naperville Community Unit School District #203 (the District) is an Illinois public school district. One of the schools that the District operates is Naperville Central High School (NCHS), where the plaintiff H.P. attended her freshman, sophomore, and junior years of high school. In 2006, during her junior year, H.P.'s mother committed suicide and H.P. moved from her mother's home in Naperville, Illinois, which is part of the District, to her father's home in Lisle, Illinois, which is not part of the District. H.P. nonetheless completed her junior year at NCHS because the District did not immediately learn of H.P.'s change in residency.
Before the 2017-18 school year began, however, the District learned that H.P. no longer lived in the District. This happened when H.P.'s father asked the District to allow H.P. to attend her senior year at NCHS, instead of Downers Grove North High School (DGNHS), which is part of the district encompassing Lisle.
The District denied W.P.'s request because H.P. lived outside of its boundaries. Under the District's residency policy, "[a] student must establish residency within the School District boundaries in order to attend a School District School," with some exceptions not pertinent here. W.P. thereafter asked the District to waive its residency requirement to allow H.P. to attend NCHS as an accommodation for certain claimed disabilities under the Americans with Disabilities Act (ADA), and the Rehabilitation Act, including anxiety, depression, sleep disturbances, and seizures. The District again denied the request and in September 2017, H.P. enrolled in DGNHS, where H.P. appeared increasingly despondent over attending the new school but ultimately graduated.
On July 21, 2017, H.P., through her father W.P., filed this action against the District, asserting claims for disparate impact and disparate treatment under Title II of the ADA and Section 504 of the Rehabilitation Act.
*960II. Discussion
H.P. appeals the district court's grant of summary judgment for the District and related denial of summary judgment for her. We begin, however, with the District's motion to dismiss this appeal as moot on the basis that H.P. graduated from high school after filing this action. Mootness is a jurisdictional defect that may arise at any time. United States v. Sanchez-Gomez , --- U.S. ----,
We agree that H.P.'s request for injunctive relief-namely, that the court order the District to enroll H.P. at NCHS for her senior year-is moot.
Turning to the merits, "[w]e review a grant of summary judgment de novo , construing the facts and making reasonable inferences in favor of the nonmovant." Horton v. Pobjecky ,
H.P.'s claims at issue arise under the ADA and the Rehabilitation Act, both of which "prohibit discrimination against the disabled." Trebatoski ,
Regardless of a plaintiff's theory of liability, "[w]e have consistently held that the statutory language in both the Rehabilitation Act and the ADA requires proof of causation."
Our analysis begins and ends with the causation requirement. As the record makes clear, it is undisputed that the District disallowed H.P. from attending NCHS precisely because of its residency policy, and not because of H.P.'s alleged disability. The residency policy on its face treats identical non-residents the same. Indeed, the only reason H.P. could not attend NCHS is because she resided outside the District-a fact unrelated to her disability. In A.H. , for example, we rejected a claim that an athletic association should create special divisions for disabled runners at its championship because the plaintiff could not show that he would have been qualified if he were not disabled. A.H. ,
III. Conclusion
We DISMISS the appeal as to H.P.'s claims for equitable relief and otherwise AFFIRM the judgment of the district court.
H.P. also sought a preliminary injunction requiring the District to enroll her in NCHS for the 2017-18 academic year, and declaratory relief on an unrelated state law claim. The district court dismissed these counts and H.P. does not appeal the district court's dismissal of these claims nor did H.P. file an amended complaint.
Reference
- Full Case Name
- H.P., a Minor, BY AND THROUGH Her Father, W.P. v. NAPERVILLE COMMUNITY UNIT SCHOOL DISTRICT 203
- Cited By
- 24 cases
- Status
- Published