Crockett v. Mayor

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA JAWANZAH CROCKETT, Plaintiff, v. Civil Action No. 16-1357 (RDM) MAYOR OF THE DISTRICT OF COLUMBIA, et al. Defendants. MEMORANDOM OPINION AND ORDER Plaintiff Jawanzah Crockett, proceeding pro se, brings this action against the District of Columbia Public Schools (“DCPS”); various school administrators, managers, and teachers; and the Mayor of the District of Columbia. The case focuses on a series of events occurring over the course of Crockett’s tenure as a student at Wilson Senior High School (“Wilson H.S.”). DCPS determined that Crockett was entitled to special education services under the Individuals with Disabilities Education Act (“IDEA”), 20 U.S.C. § 1400 et seq., and he eventually received an Individualized Education Plan (“IEP”). Crockett alleges, however, that Defendants failed to accommodate his disability; that Wilson H.S. did not properly implement the IEP; that he was otherwise denied the Free Appropriate Public Education (“FAPE”) to which he was entitled; that DCPS unlawfully disclosed portions of his protected educational records; and that Defendants inaccurately reported his attendance and grades. Based on these factual allegations, he asserts claims under Title II of the Americans with Disabilities Act (“ADA”), 42 U.S.C. § 12131 et seq.; the IDEA; the D.C. Student Grievance Procedures, D.C Mun. Regs. tit. 5B, § 2405; the Family Educational Rights and Privacy Act (“FERPA”), 20 U.S.C. § 1232g; the D.C. Human Rights Act (“DCHRA”), D.C. Code § 2-1401.01 et seq.; and an array of common law torts. In an equally multifaceted response, Defendants move to dismiss or, in the alternative, for summary judgment, raising a host of defenses. Their central argument is that Crockett brought a similar action in D.C. Superior Court in June 2015; that he was unsuccessful there; and that he is now barred by the doctrines of claim and issue preclusion from litigating his case before this Court. In addition to that argument, Defendants contend that Crockett’s current lawsuit should be dismissed for failure to exhaust administrative remedies under the IDEA; that his complaint fails to state a claim of negligence or neglect of duty; that his remaining tort claims are barred by a one-year statute of limitations; that DCPS is non sui juris and thus not subject to suit; and that the complaint fails to include any factual allegations directed at the Mayor. For the reasons explained below, the Court will GRANT in part and DENY in part Defendants’ motion. I. BACKGROUND Crockett began attending Wilson H.S. in the fall of 2011. Dkt. 1 at 3 (Compl. ¶ 15). He struggled during that first year, and his mother asked that he be tested to determine eligibility for special education services. Id. (Compl. ¶¶ 15–16). An accommodations plan drafted under Section 504 of the Rehabilitation Act, 29 U.S.C. § 794, led to improved performance in his sophomore year. Id. Still, miscommunications and disagreements about the plan hampered its implementation, and Crockett’s mother continued to push for further evaluation of her son. Id. (Compl. ¶¶ 17–24). Eventually, DCPS conceded that Crockett was ...

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