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Williams v. Christina School District

United States District Court, D. Delaware

December 31, 2014

LISA A. WILLIAMS, Plaintiff,
v.
CHRISTINA SCHOOL DISTRICT; DANA CRUMLISH, in her individual capacity; MERRIDITH MURRAY, in her individual capacity; JANE SMITH, in her individual capacity., Defendant

For Lisa A. Williams, Plaintiff: Jeffrey K. Martin, LEAD ATTORNEY, Martin & Associates, P.A., Wilmington, DE.

For Christina School District, Dana Crumlish, in her individual capacity, Merridith Murray, in her individual capacity, Jane Smith, in her individual capacity, Defendants: James H. McMackin, III, LEAD ATTORNEY, Allyson Britton DiRocco, David H. Williams, Morris James LLP, Wilmington, DE.

MEMORANDUM ORDER

Leonard P. Stark, UNITED STATES DISTRICT JUDGE.

Pending before the Court is Defendants Christina School District (" District"), Dana Crumlish, Merridith Murray, and Jane Smith's Motion to Dismiss. (D.I. 8) Defendants seek dismissal of all three counts in the Complaint filed by Plaintiff Lisa A. Williams. (D.I. 1)

BACKGROUND

On March 5, 2012, Williams began working as a secretary for Stubbs Elementary School (" Stubbs"), which is within the Christina School District. (Id. ¶ ¶ 1, 21, 24) As part of her employment, Williams was required to provide a background check within thirty days. (Id. ¶ 22) She visited the Delaware State Police several times to complete her background check. (Id. ¶ 25) Plaintiff had been convicted of misdemeanors, a fact of which she believed the District was aware due to her prior employment with the District. (Id. ¶ 21)

Upon completion of her background check, Plaintiff was called into a conference room by Defendants Crumlish, Murray, and Smith (collectively, the " Individual Defendants"). (Id. ¶ 29) This meeting occurred on May 9, 2012. (Id.) At the time, Crumlish was supervisor of the District's Human Resources Department, Murray was principal of Stubbs, and Smith was assistant principal. (Id. ¶ ¶ 7-9) At the meeting, the Individual Defendants informed Plaintiff that, due to her unsatisfactory background check, she was no longer an employee of the District. (Id. ¶ 29) Plaintiff received no additional information about why she was being fired, despite her efforts to obtain it. (Id. ¶ 30, 32)

Williams filed suit on September 3, 2013. (Id. at 1) In her Complaint, she asserts three claims. Count I, arising under 42 U.S.C. § 1983, alleges violation of Plaintiff's right to due process under the United States and Delaware Constitutions, by each of the Individual Defendants (as well as by the now-dismissed defendants Marcia Lyles, Josette Johnson, and Kelli Racca). In Count II, Plaintiff alleges that the Individual Defendants (and Lyles, Johnson, and Racca) failed to follow the District's Termination Proceedings (D.I. 9, ex. A), again resulting in a violation of her rights under § 1983. Finally, Count III alleges that the District violated Delaware's Freedom of Information Act by not providing public records in response to Plaintiff's request.

On October 24, 2013, Defendants filed their motion to dismiss the Complaint for failure to state a claim. (D.I. 8) Briefing was completed on November 18, 2013. (D.I. 10, 12)

LEGAL STANDARDS

Evaluating a motion to dismiss under Federal Rule of Civil Procedure 12(b)(6) requires the Court to accept as true all material allegations of the complaint. See Spruill v. Gillis, 372 F.3d 218, 223 (3d Cir. 2004). " The issue is not whether a plaintiff will ultimately prevail but whether the claimant is entitled to offer evidence to support the claims." In re Burlington Coat Factory Sec. Litig., 114 F.3d 1410, 1420 (3d Cir. 1997) (internal quotation marks omitted). Thus, the Court may grant such a motion to dismiss only if, after " accepting all well-pleaded allegations in the complaint as true, and viewing them in the light most favorable to plaintiff, plaintiff is not entitled to relief." Maio v. Aetna, Inc., 221 F.3d 472, 481-82 (3d Cir. 2000) (internal quotation marks omitted).

However, " [t]o survive a motion to dismiss, a civil plaintiff must allege facts that 'raise a right to relief above the speculative level on the assumption that the allegations in the complaint are true (even if doubtful in fact).'" Victaulic Co. v. Tieman, 499 F.3d 227, 234 (3d Cir. 2007) (quoting Bell A. Corp. v. Twombly, 550 U.S. 544, 555, 127 S.Ct. 1955, 167 L.Ed.2d 929 (2007)). A claim is facially plausible " when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged." Ashcroft v. Iqbal, 556 U.S. 662, 678, 129 S.Ct. 1937, 173 L.Ed.2d 868 (2009). At bottom, " [t]he complaint must state enough facts to raise a reasonable expectation that discovery will reveal evidence of [each] necessary element" of a plaintiff's claim. Wilkerson v. New Media Tech. Charter Sch. Inc., 522 F.3d 315, 321 (3d Cir. 2008) (internal quotation marks omitted).

The Court is not obligated to accept as true " bald assertions, " Morse v. Lower Merion Sch. Dist., 132 F.3d 902, 906 (3d Cir. 1997) (internal quotation marks omitted), " unsupported conclusions and unwarranted inferences, " Schuylkill Energy Res., Inc. v. Pa. Power & Light Co., 113 F.3d 405, 417 (3d Cir. 1997), or allegations that are " self-evidently false, " Nami v. Fauver, 82 F.3d 63, 69 (3d Cir. 1996). Because Plaintiff proceeds pro se, her pleading is liberally construed and her Complaint, " however inartfully pleaded, must be held to less stringent standards than ...


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