IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA

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1 Case :-cv-0-jws Document Filed 0// Page of N. TH STREET, SUITE PHOENIX, ARIZONA 0 0 Robert E. Trop (SBN 0) Law Office Robert Evan Trop PLLC N. th Street, Suite Phoenix, Arizona 0 Tel.: (0) - Fax: (00) - Attorney for Plaintiff IN THE UNITED STATES DISTRICT COURT Sidney Ryan, Jodi Ryan (Mother and Natural Guardian of K.R.), and Jeffrey Hills (Father and Natural Guardian of B.H.), on behalf of themselves and all others similarly situated, v. Plaintiffs, Mesa Unified School District and Joseph Goodman, in his individual capacity, Defendants. FOR THE DISTRICT OF ARIZONA No. :-cv-0-phx-gms AMENDED COMPLAINT FOR INJUNCTIVE RELIEF; DECLARATORY RELIEF; AND COMPENSATORY DAMAGES - -

2 Case :-cv-0-jws Document Filed 0// Page of N. TH STREET, SUITE PHOENIX, ARIZONA 0 0 For their complaint against the Defendants, the Plaintiffs: () Sidney Ryan; () Jodi Ryan (Mother and Natural Guardian of K.R.); and () Jeffrey Hills (Father and Natural Guardian of B.H.), allege as follows: INTRODUCTION. This is a civil rights action to protect and vindicate the First, Fifth and Fourteenth Amendment rights of Plaintiffs, students of Mountain View High School in Mesa, Arizona. The Plaintiffs seek money damages for themselves; and for themselves and others similarly situated, declaratory relief, and injunctive relief, as well as attorney fees and costs. This civil rights action is brought pursuant to U.S.C. and.. The vigilant protection of constitutional freedoms is nowhere more vital than in the community of American schools. Shelton v. Tucker, U.S., (0). And students in public schools do not shed their constitutional rights to freedom of speech or expression at the schoolhouse gate. Tinker v. Des Moines Indep. Community School Dist., U.S. 0, 0, S.Ct.,, (). Schools are not enclaves immune from the sweep of the First Amendment, and a danger lurks in allowing a State actor the power to limit these freedoms. The Plaintiffs in this civil rights action seek to protect and vindicate their First Amendment rights of freedom of speech.. A policy of promoting or permitting student-led or student-initiated prayer at public school sporting events violates the Establishment Clause. - -

3 Case :-cv-0-jws Document Filed 0// Page of N. TH STREET, SUITE PHOENIX, ARIZONA 0 0 Santa Fe Independent School Dist. v. Doe, 0 U.S. 0 (00). Plaintiffs claim that the Defendants violated and continue to violate the Establishment Clause by allowing and promoting prayer at the Mountain View High School varsity girls softball games. The plaintiffs in this civil rights action seek to protect and vindicate their First Amendment rights regarding violations of the Establishment Clause of the First Amendment as related to the impermissible use of studentled group prayer at extracurricular sports events.. Public schools should seek to create an environment conducive to learning by all students and not act as vehicles for proselytizing religious belief. The Mountain View High School allows students to leave and come back to the locked school campus five days a week for six periods each day to attend seminary classes directly across the street. The seminary is operated by the Church of Jesus Christ of Latter-Day Saints ( LDS Church ). While a publicschool accommodation for religious beliefs through a released-time program can be constitutionally acceptable under proper circumstances, if implementation of the program nonetheless violates the Establishment Clause through excessive entanglement, it can be unconstitutional. Lemon v. Kurtzman, 0 U.S. 0, S.Ct. 0 (); Lanner v. Wimmer, F.d (0 th Cir. ). The logistics and administration of the released-time program at Mountain View High School as related to the LDS Church seminary involve an excessive entanglement with religion in violation of the First - -

4 Case :-cv-0-jws Document Filed 0// Page of N. TH STREET, SUITE PHOENIX, ARIZONA 0 0 Amendment. The Plaintiffs in this civil rights action seek to protect and vindicate the First Amendment rights of themselves and others regarding this violation of the Establishment Clause.. The School District has rules and procedures regarding due process that the students are entitled to utilize if the school makes a charge of bullying due to the attendant stigmata of such an allegation. Due process rules and regulations in the public school environment stem from the requirements of the Fifth Amendment, made applicable to the states through the Fourteenth Amendment. Charges of bullying by students close to graduating high school and who may be attending college, playing college sports, or entering the workforce immediately, results in a stigmata that can follow the student beyond high school. As such, notice and an opportunity to be heard are critical when potentially jeopardizing the reputation of that student, which reputation is a protected liberty interest. Since the Plaintiffs individual reputations also are a protected liberty interest, and hence a fundamental right under the Fifth Amendment, that fundamental right was violated by the Defendants actions. Accordingly, the Plaintiffs procedural and substantive due process rights secured by the Fifth and Fourteenth Amendments were violated. JURISDICTION and VENUE. This Court has original jurisdiction over these federal claims pursuant to U.S.C. and. - -

5 Case :-cv-0-jws Document Filed 0// Page of N. TH STREET, SUITE PHOENIX, ARIZONA 0 0. This Court has authority to grant the requested declaratory judgment pursuant to U.S.C. and and Federal Rule of Civil Procedure.. This Court has authority to issue the requested injunctive relief pursuant to U.S.C. and Federal Rule of Civil Procedure.. This Court has authority to award attorneys fees and costs pursuant to U.S.C.. 0. The Court has personal jurisdiction over the defendants because the alleged incidents occurred within the district of this Court.. Venue is proper in the District of Arizona pursuant to U.S.C. (b). PARTIES. Plaintiff, Sidney Ryan, is a citizen of the United States, and a graduating senior at the Mountain View High School, located at 00 East Brown Road, Mesa, Arizona.. Plaintiff, K.R., is a citizen of the United States, and a junior at the Mountain View High School, located at 00 East Brown Road, Mesa, Arizona, and is a minor, and as such is represented by her Mother and Natural guardian, Jodi Ryan.. Plaintiff, B.H., is a citizen of the United States, and a sophomore at the Mountain View High School, located at 00 East Brown Road, Mesa, - -

6 Case :-cv-0-jws Document Filed 0// Page of N. TH STREET, SUITE PHOENIX, ARIZONA 0 0 Arizona, and is a minor, and as such is represented by her Father and Natural Guardian, Jeffrey Hills.. Mesa Unified School District ( the School District ) is a public school district in the County of Maricopa, State of Arizona.. Joseph Goodman is a teacher at the Mountain View High School, and was and still is the coach of the varsity girls softball team ( the Team ), known as the Mountain View Toros. Joseph Goodman is sued in his individual capacity. FACTS. Sidney Ryan, K.R., and B.H., were all selected to play on the Mountain View High School varsity girls softball team ( the team ) for the season.. During the season in, as well as in, certain students who played on the team were appointed prayer leaders to lead a group prayer at the beginning of each game.. Joseph Goodman was the coach for both the and seasons.. In, Sidney Ryan, a team captain, announced that there would not be any team prayer.. K.R. and B.H. supported the intention not to have team prayer. - -

7 Case :-cv-0-jws Document Filed 0// Page of N. TH STREET, SUITE PHOENIX, ARIZONA 0 0. The Plaintiffs were identified by other members of the LDS Church as being responsible for dispensing with the use of team prayer.. Joseph Goodman, a member of the LDS Church, and a proponent of team prayer became aware of the Plaintiffs involvement and participation with extinguishing the use of team prayer.. Terry Richardson, a member of LDS Church, is the father of another team player, C.R., and became aware of the extinguishment of team prayer by Sidney Ryan, with the support of her teammates K.R. and B.H.. Terry Richardson, along with another parent, Kelly Roberts (also an LDS Church member) expected that team prayer would be part of the activities of the team prior to the games.. The expectation that there would be team prayer was communicated to Joseph Goodman by LDS parents.. On or about March,, the team played several games against other public schools in Tucson.. During the tournament, contemporary hip-hop and other popular music liked by teenage girls was played and used as expressive speech to get in the zone performing at the competitive varsity school level.. The music, a form of expressive student speech, was deemed objectionable by C.R., the daughter of Terry Richardson, because the music offended her religious sensitivities. - -

8 Case :-cv-0-jws Document Filed 0// Page of N. TH STREET, SUITE PHOENIX, ARIZONA During the tournament, Terry Richardson and/or other LDS Church members, at the direct or indirect request of Joseph Goodman, followed the expressive speech of Plaintiff, B.H., made on the social media site, Twitter.. Social media postings made by B.H. were reported by certain LDS Church members to Joseph Goodman at his direction and request.. The social media postings were generic, and not directed to any particular students, and were not disruptive to any school purpose.. Upon returning from the games on Saturday March,, there was a meeting between parents who are members of the LDS Church and Joseph Goodman.. The parents of Plaintiffs nor other non-lds parents were not made aware of this meeting.. Shortly thereafter, the Plaintiffs were dismissed from the team upon the grounds of not respecting religious views of others, and for off-campus speech usage that did not disrupt the normal school atmosphere.. The dismissal of the Plaintiffs was claimed to be bullying by the School District when the Plaintiffs asked for evidence and proof of not respecting religious views and for using improper expressive speech during offcampus events.. The School District did not provide any evidence of bullying or improper direct speech or expressive speech. - -

9 Case :-cv-0-jws Document Filed 0// Page of N. TH STREET, SUITE PHOENIX, ARIZONA 0 0. The Plaintiffs in fact were penalized for not conducting team prayer in accordance with the directive of Joseph Goodman, acting for himself and at the behest of certain parents that were part of the LDS Church.. The Plaintiffs in fact were penalized because the parents of certain LDS students on the team complained to Joseph Goodman about the speech and expressive speech of the Plaintiffs, which actual and expressive speech events were perfectly acceptable and within the bounds of a secular society and that of a public school system. 0. The Establishment Clause provides a right of freedom from religion in the public school system, whether during academic sessions, or, during extra-curricular activities.. By Defendants treating Plaintiffs in the foregoing manner, dismissing them from the Team for not conducting team prayer, for utilizing certain speech and expressive speech through pop music, social media, and otherwise, the First and Fourteenth Amendment rights of the Plaintiffs were violated.. The LDS Church operates a seminary across the street from Mountain View High School.. The LDS Church has a policy and practice of setting up seminary buildings directly across from other public schools in the Mesa Public School District. - -

10 Case :-cv-0-jws Document Filed 0// Page 0 of N. TH STREET, SUITE PHOENIX, ARIZONA 0 0. LDS Church students participate in a released-time program through the school district, involving students being released from the school five days a week for six periods of the day, and then re-admitted to the school.. Accordingly, the released-time for the LDS Church seminary program is in effect simply another class that is taken with the imprimatur of the School District, rather than a program where students are released early from school.. The Mountain View High School is a locked-campus, during the school day for student safety, except for seniors during their lunch periods.. The LDS Church seminary students often are locked outside of the gate after attending seminary.. When LDS Church seminary students are locked outside the gate, public school personnel have to be called upon to open the gate to let the LDS Church seminary students back onto the public school property to resume their regular classes, albeit being late.. Some non-seminary students say they are going to seminary when in fact they are not, using it as an excuse to leave the school property on a frolic and detour during normal school hours. 0. When LDS Church seminary students are tardy in getting to class after seminary, there is a pattern and practice of excusing the lateness.. When non-seminary students are tardy, there is a pattern and practice of not excusing the lateness

11 Case :-cv-0-jws Document Filed 0// Page of N. TH STREET, SUITE PHOENIX, ARIZONA 0 0. Personnel of the LDS Church also have a key to the gate, and are thus allowed by the School District to open the gate of the public school for purposes of allowing seminary students back onto campus.. The School District does not adequately keep track of the students that leave campus, and then re-enter the campus for purposes of attending seminary. CAUSES OF ACTION COUNT I - U.S.C. Establishment Clause Violation - Prayer. Plaintiffs reallege and incorporate by reference all allegations set forth in each of the preceding paragraphs of the Complaint.. The First Amendment of the United States Constitution provides as follows: Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise thereof; or abridging the freedom of speech, or of the press; or the right of the people peaceably to assemble, and to petition the government for a redress of grievances.. The "establishment of religion" clause of the First Amendment means that the government cannot indirectly endorse or prefer one religion over another, and in the words of Jefferson, the clause against establishment of religion by law was intended to erect 'a wall of separation between church and State, which must be kept high and impregnable, with the Courts not approving the slightest breach. Everson v. Board of Education, 0 U.S. (). - -

12 Case :-cv-0-jws Document Filed 0// Page of N. TH STREET, SUITE PHOENIX, ARIZONA 0 0 Allowing any coercion for participation in religious activities strikes at the core of the Establishment Clause of the First Amendment. Inouwe v. Kenna, 0 F.d 0, ( th Cir. 0).. "Perhaps in the early days of the Republic [the] words [of the Establishment Clause] were understood to protect only the diversity within Christianity, but today they are recognized as guaranteeing religious liberty and equality to the infidel, the atheist, or the adherent of a non-christian faith such as Islam or Judaism." (internal marks omitted); Wallace v. Jaffree, U.S. -, 0 S.Ct., -, L.Ed.d ().. "[T]he [Supreme] Court has unambiguously concluded that the individual freedom of conscience protected by the First Amendment embraces the right to select any religious faith or none at all.") (footnote omitted); Torcaso v. Watkins, U.S.,, S.Ct. 0, -, L.Ed.d ().. The Fourteenth Amendment, Section, of the United States Constitution provides as follows: All persons born or naturalized in the United States, and subject to the jurisdiction thereof, are citizens of the United States and of the state wherein they reside. No state shall make or enforce any law which shall abridge the privileges or immunities of citizens of the United States; nor shall any state deprive any person of life, liberty, or property, without due process of law; nor deny to any person within its jurisdiction the equal protection of the laws. - -

13 Case :-cv-0-jws Document Filed 0// Page of N. TH STREET, SUITE PHOENIX, ARIZONA The denial of constitutional rights is irreparable injury per se.. The acts of the Defendant, Joseph Goodman, were made with a reckless indifference to Plaintiffs clearly established federal constitutional rights, warranting an award of punitive damages.. The actions of the Defendant, Joseph Goodman, were based upon the Plaintiffs not being members of the LDS Church and who did not accede to having and allowing student-led group team prayer.. A reasonable educator in the position of Defendant, Joseph Goodman, would know and should have known that they were violating clearly established constitutional rights of Plaintiffs and others under the First and Fourteenth Amendments, and accordingly they are liable to Plaintiffs under U.S.C... As a direct and proximate result of the actions of Defendant, Joseph Goodman, Plaintiffs suffered emotional upset and anguish.. As a direct and proximate result of the actions and conduct of Defendant, Joseph Goodman, rights of Plaintiffs and others secured by the First and Fourteenth Amendments by virtue of the team prayer and the Plaintiffs treatment as a result thereto resulted in a deprivation of Plaintiffs fundamental constitutional rights secured by the First Amendment. - -

14 Case :-cv-0-jws Document Filed 0// Page of N. TH STREET, SUITE PHOENIX, ARIZONA 0 0 indirectly. COUNT II - U.S.C. Establishment Clause Violation Released-Time for the LDS Church Seminary Program. Public schools exist to educate, not to proselytize, either directly or. Students in public schools are a captive audience, and any endorsement of religion, either directly or indirectly, is coercive and invasive.. "The clearest command of the Establishment Clause is that one religious denomination cannot be officially preferred over another. "Larson v. Valente, U.S.,, 0 S.Ct.,, L.Ed.d ().. The operation of released-time for the LDS Church seminary program through and with the imprimatur of the School District, including the logistics in implementation and lack of accountability of the students regarding attendance, is a violation of the Establishment Clause. 0. The operation of released time program for the LDS Church seminary program is a violation of the Establishment Clause because taxpayers squander the use of classrooms and other fixed costs so the LDS Church can operate its seminary training program, inculcating students who are required to be at school pursuant to mandatory state laws.. As a direct and proximate result of the violation of the First and Fourteenth Amendment rights of Plaintiff and others similarly situated by the Defendant, Mesa Unified School District, Plaintiffs and other students similarly situated are entitled to injunctive and declaratory relief. - -

15 Case :-cv-0-jws Document Filed 0// Page of N. TH STREET, SUITE PHOENIX, ARIZONA 0 0 COUNT III - U.S.C. - Violation of Free Speech. Plaintiffs reallege and incorporate by reference all allegations set forth in each of the preceding paragraphs of the Complaint.. Plaintiffs and other students similarly situated in the School District have a right under the First Amendment to be free from speech and expressive speech constraints when off campus that do not materially and substantially disrupt the normal work and discipline of the school s functions and activities.. The Defendants took adverse action and penalized the Plaintiffs by removing them from the team because of off-campus speech that was neither disruptive to normal school functions nor other students.. Defendants penalized the Plaintiffs by restricting their expressive speech so that it would conform with the predilections of the LDS Church.. The actions of Defendants were motivated at least in part by the Plaintiffs exercise of their speech and expressive speech rights protected by the First Amendment.. Any prior restraint or as-applied restriction of expressive student speech off-campus that is not disruptive to the school community is unconstitutional.. As a direct and proximate result of the actions of Defendant, Joseph Goodman, acting in his individual capacity, the Plaintiffs had their First and - -

16 Case :-cv-0-jws Document Filed 0// Page of N. TH STREET, SUITE PHOENIX, ARIZONA 0 0 Fourteenth Amendment rights violated, as related to speech and expressive speech.. As a direct and proximate result of the actions of Defendant, the School District, the Plaintiffs had their First and Fourteenth Amendment rights violated. COUNT IV - U.S.C. Fifth and Fourteenth Amendment Violations 0. Plaintiffs reallege and incorporate by reference all allegations set forth in each of the preceding paragraphs of the Complaint.. Dismissal and adverse actions can invoke a liberty interest in reputation if the dismissal is for dishonesty, moral turpitude, or other reasons bearing such stigmata as might foreclose other opportunities.. The School District has rules and procedures that are supposed to be utilized in the event that a student is to be removed from any class or the Team if there were issues related to improper speech or expressive speech that could be deemed bullying.. These rules exist to comply with the requirements of the Fifth Amendment s requirements of due process, made applicable to the states through the Fourteenth Amendment.. The Defendant, Mesa Unified School District, did not comply with its own rules to comply with the Plaintiffs due process rights. - -

17 Case :-cv-0-jws Document Filed 0// Page of N. TH STREET, SUITE PHOENIX, ARIZONA 0 0. As a direct and proximate result of the School District s actions, the Fifth and Fourteenth Amendment procedural due process rights of the Plaintiffs were violated.. As a direct and proximate result of the School District s actions, the Plaintiffs Fifth and Fourteenth Amendment substantive constitutional right in their reputations, a protected liberty interest, were violated.. As a direct and proximate result of the actions of Defendant, Joseph Goodman, acting in his individual capacity, the Plaintiffs Fifth and Fourteenth Amendment substantive constitutional rights in their reputations, a protected liberty interest, were violated. REQUESTS FOR RELIEF WHEREFORE, Plaintiffs respectfully requests the Court to: A. Issue a Judgment on Counts I and IV awarding compensatory and punitive damages to Plaintiffs against Defendant, Joseph Goodman, in his individual capacity, for violation the rights of Plaintiffs secured by the First, Fifth and Fourteenth Amendments; B. Issue a Declaratory Judgment on Counts I, II and III that the Defendants, Joseph Goodman, and Mesa Unified School District violated the rights of Plaintiffs and others similarly situated that are secured by the First and Fourteenth Amendments; - -

18 Case :-cv-0-jws Document Filed 0// Page of N. TH STREET, SUITE PHOENIX, ARIZONA 0 0 C. Issue a Declaratory Judgment on Count IV that the Defendant, Mesa Unified School District, violated the rights of Plaintiffs secured by the Fifth and Fourteenth Amendments; D. Issue an Injunction against all Defendants to prevent any continued violation of the rights of Plaintiffs and others similarly situated secured by the First and Fourteenth Amendments as referable to the Establishment Clause; E. Appoint a Monitor to Oversee the Mesa Unified School District for a period of () three years to ensure compliance with the Establishment Clause as related to its released-time program and its relationship with the seminary program of the LDS Church; F. An award of reasonable attorney's fees, costs and disbursements, pursuant to U.S.C. ; and G. Such other and further relief as this Court may deem just and proper under the circumstances. Dated this th of June,. Law Office Robert Evan Trop PLLC By: s/ Robert E. Trop Robert E. Trop - -

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