Parent of high school student who was transferred to another school for three months after hearing on allegations he engaged in sexual misconduct on school bus during field trip filed § 1983 action against public school board and its supervisor of administration, who was disciplinary hearing officer, alleging deprivation of First and Fourteenth Amendment rights and violation of student’s due process rights protected by Louisiana constitution. Parent also raised state law claims of intentional infliction of emotional distress (IIED) against supervisor of administration, negligence for board’s alleged failure to train and supervise employees, and defamation. The District Court granted summary judgment in favor of defendants. Parent appealed.
The Court of Appeals held that:
- Supervisor did not violate procedural due process;
- Board did not violate Louisiana law by failing to review supervisor’s finding that student engaged in sexual misconduct and determination that he would be transferred to another school for three months;
- Supervisor was entitled to immunity from liability for defamation; and
- One-year prescriptive period applied to claim for negligent failure to train.