Jeremy Hurd

School Law

Case Review #5

3-16-04

 

I.  Origins

 

A.       Name, location, and date of the case.

The name of the case is Wallace v Batavia School District 101.  The case resided in the U.S. Court of Appeals for the Seventh Circuit and was argued on April 20, 1995 and was decided on October 19, 1995.  An appeal was filed from a decision given by the United States District Court for the Northern District of Illinois, Eastern Division.

 

B.       Level of Court that issued the decision.

The court issuing the decision in the case was the United States Court of Appeals for the Seventh Circuit.

 

C.       Level of control of the school over the conditions of the case.

  The level of control of this situation was given solely to the teacher.  The school should have had policies in place as to the proper conduct that a teacher could initiate given this particular situation where two students were almost in a fight.  The school should have given training to the teachers as to their conduct and at the same time, the teachers should have been aware what reasonable force that they could use to maintain control within their classroom environment.  These issues can also be discussed by school boards and be declared within state statutes.

 

II.    Analysis of Conditions

 

A.      What area of school law does this case relate to or involve.  How?

The area of school law that this case involves is the area of Student Discipline and the issue of the use of force to control students.  The parents in the case also alleged violations of her daughter’s Fourth Amendment right against unreasonable seizures and her Fourteenth Amendment right to substantive due process.  The teacher used minimal force to advance a student out of a classroom for disrupting the class and proceeded to help advance her by grabbing her by the wrist and elbow, which the student claimed was unreasonable.

B.        What are the major arguments for the plaintiffs?

 

Wallace claims the contact with the teacher, James Cliffe, caused injury to her elbow. Through her mother, she sued Cliffe and the Batavia School Corporation alleging violations of her Fourth Amendment right against unreasonable seizures and her Fourteenth Amendment right to substantive due process. She claimed that the force used against her was unreasonable and the primary issue was the violation of her Fourth Amendment rights.

 

C.       What are the major arguments for the defendants?

 

The defendants claimed that there could be no Fourth Amendment violation in this case. The supported their claim by a case that was decided in the U.S. 9th Circuit Court of Appeals named United States v. Attson, which the defendants claim shields public school officials from the application of the Fourth Amendment unless the school officials act in conjunction with law enforcement agents with the purpose of enforcing the law.  The defendants did not argue that the teacher ordered Wallace out of the classroom and grabbed her in order to prevent a fight and restore order and discipline, and the school claimed that this action was necessary to restore order to the classroom in order with school policies and standards.

 

D.        What was the decision made in this case?

 

The court decided in favor of the defendants in this case.  The court concluded that public school students have protection of their liberty rights under the Fourth Amendment, but they also concluded that they would make judgments that would undermine the necessary authority that teachers and school administrators exert over students. They affirmed that public school teachers and administrators

must have considerable latitude in performing their educational responsibilities, including maintaining order and discipline by reasonably restraining the liberty of students.  They concluded that the teacher in this case was confronted in his classroom with a situation were a fight was about to break out and that the actions of the teacher did not constitute a matter rising to the level of a constitutional violation. They claimed that the litigation in this case degrades the Constitution and is a disservice to school systems, the federal courts, and the public they serve.

 

III.                      Personal Reaction

 

A.      What is your personal reaction to the decision made in this case?

 

I agree with the courts decision.  I think that the school official’s right to maintain control within a school system is a very important right.  To an extent, the Fourth Amendment must protect students in school.  Also, if a teacher or school official is not granted the right to maintain control to prevent violence and other school disruption, total chaos could become a result.  The teacher acted appropriately and was helping to advance the student’s progress out of a room to break up the fight.  Had the teacher not acted, a fight could have broke out and both students would have acted in violence.  The teacher then would have been neglectful for not doing something earlier.  I do think that the teacher could have acted much sooner by escorting both students to the office or having an official deal with the issue so that the teacher could proceed with his teaching.  I can not imagine if the use of reasonable force by teacher was taken away, how out of control that a school would become.  Having this right protects the interest of the students, the teachers, and everyone involved at the school to insure a safe, comfortable, educational environment conducive to learning.

 

B.        What are the implications of this case for you as a future school

administrator?

 

This is an issue that could come up at any time for an administrator. School teachers and administrators must use their best judgment in deciding whether or not that their force or actions are reasonable based upon the situation at hand.  It would not be safe to say that this type of particular situation may never be placed in an administrators hands.  Not being able to hold the hand of every teacher to make sure that their temper or actions do not fog their best judgement really is out of control on an administrator’s part.  The administrator must use good judgment in hiring and also training teachers to make sure that they are aware of what their legal rights are regarding situations such as this.  I think that this a great burden for both administrators and teachers to always act appropriately.  Student’s actions are something that can not always be controlled either, and the ability of a teacher or school official to act with appropriate force and action given a high adrenaline situation is a difficult task.  What is important is that all parties understand the laws and that school officials do their best to follow the laws placed on them by the constitution and state statutes.