## Facts

- C.N., a minor student receiving special-education services, attended a Minnesota school district from mid-kindergarten through mid-third grade.
- C.N. had an individualized education program (IEP) that included a behavior intervention plan (BIP) authorizing restraint holds and seclusion in response to specified behaviors.
- After behavioral concerns, C.N. received an outside evaluation; the IEP/BIP was revised, and the IEP team repeatedly adjusted C.N.’s program while continuing to authorize “controlled procedures.”
- C.N. worked with a special-education teacher and later alleged that the teacher improperly used restraint and seclusion (including use of a time-out/quiet room), causing emotional harm and loss of educational benefit.
- C.N.’s parent withdrew C.N. from the district and enrolled her in a different district.
- Only after the transfer, C.N. requested an IDEA due-process hearing challenging the adequacy of the former district’s services; the administrative law judge dismissed for lack of jurisdiction because C.N. was no longer enrolled in the district when the request was filed.
- C.N. then sued in federal court asserting an IDEA claim against the district and federal civil-rights claims (including § 1983) against the district and individual officials; the district court dismissed all claims.

## Issues

1. Whether an IDEA claim may proceed in federal court when the parent sought a due-process hearing only after the student transferred out of the challenged school district and the administrative proceeding was dismissed for lack of jurisdiction.
2. Whether § 1983 and related federal civil-rights claims based on restraint and seclusion could proceed despite IDEA exhaustion requirements and absent allegations meeting the substantive due process “shocks the conscience” standard.
3. Whether the pleadings sufficiently alleged district or supervisory liability for unconstitutional conduct through policy, custom, or deliberate indifference.

## Decision

- The Eighth Circuit affirmed dismissal of the IDEA claim because C.N. did not properly exhaust IDEA administrative remedies.
- The court upheld the ALJ’s lack-of-jurisdiction dismissal under Minnesota’s due-process framework where the student was no longer enrolled in the district when the hearing was requested.
- The court affirmed dismissal of the § 1983 substantive due process claim because the alleged restraint and seclusion, as pleaded, did not meet the “shocks the conscience” threshold in the school context.
- The court affirmed dismissal of claims against supervisory officials and the district because the pleadings did not sufficiently allege deliberate indifference, or a policy/custom causing a constitutional violation.

## Legal Principles

- IDEA generally requires exhaustion of state administrative due-process procedures before filing a federal action seeking relief for denial of a free appropriate public education (FAPE).
- When the governing state administrative scheme does not provide jurisdiction for a post-transfer due-process complaint against a former district, an untimely or improper hearing request does not satisfy IDEA exhaustion.
- Claims styled as constitutional or civil-rights claims may still be subject to IDEA exhaustion when the gravamen concerns the adequacy or implementation of special-education services under an IEP/BIP.
- Substantive due process liability for school discipline or control measures requires conduct so brutal, demeaning, or harmful that it “shocks the conscience”; authorization within an IEP/BIP and absence of sufficiently extreme factual allegations weigh against constitutional liability.
- Municipal or supervisory liability under § 1983 requires plausible allegations of an underlying constitutional violation and causation through a policy, custom, or deliberate indifference in training/supervision.

## Conclusion

Because C.N. sought an IDEA due-process hearing only after transferring out of the district, she failed to exhaust IDEA remedies, and her related civil-rights claims were also properly dismissed where the alleged conduct did not plausibly meet the high constitutional standard or establish district/supervisory liability.


C.N. v. Willmar Pub. Schs., Indep. Sch. Dist. No. 347, 591 F.3d 624 (8th Cir. 2010)