Pagan-Negron v. Seguin Independent School District

What This Case Is About

Pagan-Negron v. Seguin Independent School District involves a parent’s claims against a school district for alleged disability-based discrimination and a § 1983 substantive due process violation arising from a disciplinary incident. The court granted summary judgment to the school district on all claims.

The Facts

C.M.P. was a student at Seguin Independent School District (SISD) who received special education services from 2006 until he withdrew in January 2012. He was initially identified as having a speech impairment. A disciplinary incident on January 14, 2010 is the underlying cause of this lawsuit. Plaintiffs contend that Principal Yomeida Guerra publicly humiliated C.M.P. by bringing him before his class and asking for a show of hands of students who were tired of C.M.P. and his behavior. The principal denied this occurred.

C.M.P. was not diagnosed with Asperger’s Disorder until August 2010 — almost eight months after the incident. Pagan-Negron filed claims under Section 504 of the Rehabilitation Act, the ADA, and § 1983, alleging disability-based discrimination and a violation of C.M.P.’s substantive due process rights. Pagan-Negron also brought an individual ADA accessibility claim regarding SISD’s facilities.

What the Court Decided

The court granted summary judgment to SISD on all claims.

ADA and Section 504 claims: The court found that Pagan-Negron could not demonstrate intentional discrimination because C.M.P.’s behavior-related disability (Asperger’s) was not known to exist at the time of the incident. The court relied on D.A. v. Houston Independent School District, noting that a student “cannot be discriminated against because of his disability until it has been demonstrated to exist.”

Section 1983 claim: The court found that Principal Guerra’s alleged disciplinary actions, even if true, did not rise to the level of a substantive due process violation. The conduct was not “wholly unrelated” to maintaining an atmosphere conducive to learning and did not “shock the conscience.” The court also found Pagan-Negron’s allegations of a municipal policy of intimidation were conclusory and unsupported.

Pagan-Negron’s individual ADA claim: The court found this claim time-barred under the two-year statute of limitations because the accessibility violations she identified occurred outside the limitations period.

Why This Case Matters for Your § 1983 Case

• Municipal liability requires a policy or custom: Conclusory allegations of a policy of “intimidation” without specific supporting facts are insufficient to survive summary judgment under § 1983.
• Substantive due process has a high bar: School disciplinary actions, even if inappropriate, must “shock the conscience” to rise to a constitutional violation. Conduct related to maintaining classroom order will not meet this standard.
• Disability discrimination requires knowledge of the disability: A claim that an entity discriminated based on a disability that was not yet diagnosed will fail because intentional discrimination cannot be shown.

Key Takeaway

To prevail on a § 1983 claim against a school district, you must show that the entity’s policies or customs caused a deprivation of constitutional rights, and the alleged conduct must be so egregious as to “shock the conscience” — not merely reflect poor disciplinary judgment.