Dismissal of Class Action Suit Involving Special Education Upheld
SPRINGFIELD — Springfield Mayor Domenic J. Sarno announced that the Federal Appeals Court upheld the dismissal of a class-action suit that had been brought by special education advocates against the city of Springfield and Springfield Public Schools.
The United States Court of Appeals for the First Circuit Court entered judgment on August 8 affirming the decision of Judge Mark G. Mastroianni to dismiss the class action.
The underlying suit alleged that the city of Springfield, and Springfield Public Schools (SPS) violated Title II of the ADA by unnecessarily segregating students with mental health disabilities in a separate and inferior school, the Springfield Public Day School (SPDS).
A student brought the suit on his own behalf and on behalf of a class of all students with a mental health disability who are or have been enrolled at SPDS. Two associations, the Parent/Professional Advocacy League (PPAL) and Disability Law Center (DLC), joined as plaintiffs seeking injunctive and declaratory relief, including an order that defendants provide the class plaintiffs with “school-based behavior services in neighborhood schools to afford them an equal educational opportunity and enable them to be educated in neighborhood schools.” The United States District Court, in an opinion by Judge Mastroianni, denied class certification. The court later ruled that the associations had standing but granted the defendants’ motion for judgment on the pleadings as to the associations.
The plaintiffs’ appeal challenges the district court’s denial of class certification. The City appeal argued that the district court erred in concluding that PPAL and DLC had standing. The Court of Appeals agreed that these organizations lack standing to pursue the claims in the complaint, and affirmed the district court’s grant of judgment on the pleadings as to PPAL and DLC on that ground.
The case was argued by Deputy City Solicitor Lisa deSousa and Attorney Stephen Holstrom with whom City Solicitor Edward Pikula, and Attorney Melinda Phelps, of Bulkley, Richardson & Gelinas LLP were on the brief.