MELANIE FIGUEROA v. SANTA ROSA COUNTY SHERIFF DEPARTMENT (2026)

ORDER ON SCHOOL BOARD'S MOTION FOR SUMMARY JUDGMENT

This case arises out of the purported mental health seizures of two autistic children at a school in Santa Rosa County. Plaintiffs include the minor children, C.B. and B.F., and their parents, who have sued the Santa Rosa County School Board for various state and federal claims arising out of the purported mental health seizures of both children. The School Board has moved for summary judgment as to all claims. ECF No. 188. This Court has considered, without hearing, the motion for summary judgment, id., Plaintiffs' response in opposition, ECF No. 202, and the School Board's reply, ECF No. 210. For the reasons set out below, the motion is due to be GRANTED.

Plaintiffs bring two types of claims against the School Board—namely, (1) Monell claims for procedural due process violations based on the mental health seizures of B.F. and C.B. without their parents' notice or consent (Counts XV, XVI, XXIII, and XXIV) and (2) disability discrimination claims under the Americans with Disabilities Act (“ADA”) and the Florida Educational Equity Act (“FEEA”) based on the mental health seizures and handcuffing of C.B. and B.F. (Counts IX, X, XII, XIV). This Court will address each category of claim in turn.¹

First, the parent Plaintiffs' Monell claims against the School Board based on the alleged deprivation of their parental rights without due process. To establish municipal liability, Plaintiffs must show that (1) their constitutional rights were violated, (2) the School Board had a policy (or custom) that constituted deliberate indifference to that constitutional right, and (3) the School Board's policy (or custom) caused the violation. Baker v. City of Madison, Ala., 67 F.4th 1268, 1282 (11th Cir. 2023). But “[t]here can be no policy-based liability ․ when there is no underlying constitutional violation.” Knight ex rel. Kerr v. Miami-Dade Cnty., 856 F.3d 795, 821 (11th Cir. 2017).

The parent Plaintiffs each assert that School Board violated their Fourteenth Amendment rights by depriving them of their parental rights to custody and control of their children and their children's medical decisions without due process when Deputy Daniels, the school resource officer, initiated a mental health seizure of their children without first notifying them or receiving their consent to do so. Their claims hinge on the supposition that “the children were improperly Baker Acted,” and thus there was no emergency permitting the seizures without notice or parental consent. ECF No. 202 at 30–31. Plaintiffs' proposed rule—notice and consent to seize in the absence of a “true emergency”—would require the School Board to have school resource officers first contact parents and receive their consent to seize their children in the event the law enforcement officers do not have probable cause for such seizures.² But this proposed rule is founded on the incorrect assumption that Deputy Daniels lacked probable cause to seize C.B. and B.F.³

Indeed, this Court, by separate Order, concludes that the undisputed facts demonstrate that Deputy Daniels had probable cause to arrest both children for criminal offenses, which immunizes Daniels from liability under section 1983. Likewise, inasmuch as probable cause supported both seizures, no constitutional violation occurred with respect to whether either child was wrongfully seized under the Fourth Amendment. Thus, to the extent the parent Plaintiffs' claims arise from the purported wrongful seizures of their children, they lack any foundation insofar as the undisputed facts demonstrate that Deputy Daniels had actual probable cause to seize both children. See Marbut, 176 F.4th at 1266 (holding that mental health seizure did not violate Fourth Amendment “[e]ven if the emergency-aid doctrine did not justify [the] seizure,” because “officers could seize [Appellant] because they had probable cause to believe she committed a criminal offense”); see also J.H. ex rel. J.P. v. Bernalillo Cnty., 806 F.3d 1255, 1258 (10th Cir. 2015) (holding that power to arrest based on probable cause “did not depend on classification of the arrestee (adult versus juvenile) or the crime (felony versus misdemeanor); law enforcement can arrest minors, as well as adults, even when the crime involves only a misdemeanor.”).

And Plaintiffs certainly do not suggest or cite any authority supporting the position that the School Board must first notify a parent and receive their consent before a law enforcement officer arrests a minor based on probable cause that the minor has committed a felony at school.⁴ In other words, insofar as Plaintiffs' procedural due process claims against the School Board are founded on the presumption that their children were wrongfully seized—“in the absence of a true emergency”—and thus, the seizure required their prior notice and consent to satisfy their procedural due process rights, this theory fails as a matter of law given the probable cause that supported both seizures. Ultimately, Plaintiffs identify no binding Circuit or Supreme Court authority holding that the School Board violates the constitution when school resource officers conduct mental health seizures of minors that are otherwise supported by probable cause to arrest without providing prior notice to or receiving consent from the minors' parents. Accordingly, Defendant School Board is entitled to summary judgment as to these counts in the absence of any authority supporting Plaintiffs' position that the facts in this record would permit a reasonable jury to find that they were deprived of their parental rights without due process. Defendant's motion is GRANTED as to the section 1983 procedural due process claims—namely, Counts XV, XVI, XXIII, and XXIV.

Next, B.F. and C.B. also allege in Counts IX, X, XII, and XIV that the School Board violated the FEEA and Title II of the ADA based on the use of handcuffs during each child's seizure. ECF No. 74 ¶¶ 304–34, 338–68, 378–81, 390–93. They claim the School Board failed to accommodate B.F.'s and C.B.'s disabilities by not providing a modification to handcuffing during the purported mental health seizures, denying both children the opportunity to participate in education services, and intentionally discriminating against both children because of their disabilities. As explained below, Plaintiffs fail to identify any record evidence creating a dispute of material fact to defeat the School Board's motion for summary judgment as to these claims.

Title II of the ADA provides that “no qualified individual with a disability shall, by reason of such disability, be excluded from participation in or be denied the benefits of the services, programs, or activities of a public entity, or be subjected to discrimination by any such entity.” 42 U.S.C. § 12132. “[C]ourts have read Title II to impose a duty on public entities to provide ‘reasonable’ accommodations to qualifying individuals with a disability as to their services.” Laubscher v. Gwinette Cnty., 2026 WL 1897046, at *6 (11th Cir. July 1, 2026) (listing cases). To state a Title II claim, Plaintiffs generally must prove that they are qualified individuals with a disability, that they were either excluded from participation in or denied the benefits of the School Board's services, programs, or activities, or were otherwise discriminated against by the School Board, and that the exclusion, denial of benefit, or discrimination was by reason of their disability. Bircoll v. Miami-Dade Cnty., 480 F.3d 1072, 1083 (11th Cir. 2007). “In the ordinary course, proof of a Title II ․ violation entitles a plaintiff only to injunctive relief.” Silberman v. Miami Dade Transit, 927 F.3d 1123, 1134 (11th Cir. 2019).

Here, Plaintiffs seek damages under the ADA, which requires them to also prove that the School Board “engaged in intentional discrimination, which requires a showing of ‘deliberate indifference.’ ” Id. (quoting Liese v. Indian River Cnty. Hosp. Dist., 701 F.3d 334, 348 (11th Cir. 2012)). Plaintiffs' FEEA claims also require a showing of “deliberate indifference” as a basis for recovery. Hawkins v. Sarasota Cnty. Sch. Bd., 322 F.3d 1279, 1286 (11th Cir. 2003). And deliberate indifference requires proof that “an ‘official who at a minimum has authority to address the alleged discrimination and to institute corrective measures on the entity's behalf’ had ‘actual knowledge of discrimination in the entity's programs and failed adequately to respond.’ ” Id. (quoting Liese, 701 F.3d at 349).

Here, Plaintiffs' disability discrimination claims fail for several reasons. A Title II violation occurs only when the qualified individual with a disability is excluded, denied the benefits of a service or program, or otherwise discriminated against by the public entity. Laubscher, 2026 WL 1897046, at *9. Likewise, the School Board's duty to accommodate B.F. and C.B. with respect to its services “is only triggered once the person with a disability makes clear to the public entity his need for an accommodation to enjoy the benefits of the public entity's services.” Id. (citing Gaston v. Bellingrath Gardens & Home, Inc., 167 F.3d 1361, 1363 (11th Cir. 1999)). In this case, the alleged Title II violations could only have occurred when C.B. and B.F. were handcuffed during their mental health seizures, not at some earlier time when the challenged policies were enacted. Moreover, Plaintiffs point to no record evidence demonstrating that either Plaintiff or their parents requested any accommodation to handcuffing in the event of a mental health seizure. Nor do Plaintiffs point to any evidence that Deputy Daniels was aware of C.B.'s or B.F.'s asserted disabilities or was intentionally discriminating against either child because of their asserted disabilities.⁵ Additionally, Plaintiffs identify no other evidence suggesting that anyone in a supervisory or policy-making role was aware of or indifferent to a pattern of similar Baker Act seizures involving other children on the autism spectrum to allow a reasonable jury to conclude that the School Board was deliberately indifferent to the alleged discrimination. See Laubscher, 2026 WL 1897046, at *8 (“To show actual knowledge and hold a public entity liable for compensatory damages under the ADA and RA, plaintiffs asserting claims like the Laubschers' based on a public entity's upstream policies must show a pattern of incidents and ADA violations similar to the underlying alleged discrimination.”). Ultimately, Plaintiffs do not point to even a scintilla of evidence to demonstrate actual knowledge of any request for accommodation, any intentional discrimination, or any deliberate indifference to disability discrimination that would create a dispute of material fact for a jury to resolve. See ECF No. 210 at 12–14. Accordingly, inasmuch as there is no dispute of material fact, Defendant School Board is entitled to summary judgment on the Title II and FEEA claims—Counts IX, X, XII, and XIV.

Accordingly,

IT IS ORDERED:

1. Defendant School Board's motion for summary judgment, ECF No. 188, is GRANTED.

2. This Court does not direct entry of judgment on the issues decided in this Order under Federal Rule of Civil Procedure 54(b).

SO ORDERED on September 3, 2026.

FOOTNOTES

1.   This Court reiterates that the record demonstrates a basis for establishing an injury in fact traceable, in part, to the School Board based on its partnership with the Sheriff's Office and the Camelot School and its responsibility for implementing policies and overseeing its school resource officer program, and redressable, in part, by damages against the School Board. However, simply because Plaintiffs have demonstrated a basis in the record to demonstrate Article III standing, that does not translate to success on the merits of their claims against the School Board.

2.   Of course, this Court recognizes that the Eleventh Circuit has recently articulated a more flexible standard than probable cause, which now applies when evaluating the constitutionality of a mental health seizure under the Fourth Amendment. See Marbut v. Phillips, 176 F.4th 1256, 1265 (11th Cir. 2026) (mental health seizures do not violate the Fourth Amendment when officers “have an ‘objectively reasonable basis for believing’ that intervention is needed to ‘prevent serious harm.’ ”).

3.   Moreover, as Defendant School Board points out, Florida law provides that school resource officers can simultaneously act as law enforcement while performing their duties as school resource officers and otherwise maintain their “powers and duties of a law enforcement officer ․ throughout [their] tenure as a school resource officer.” D.L. ex rel. S.L. v. Hernando Cnty. Sheriff's Office, 2025 WL 3763912, at 5 (M.D. Fla. Dec. 30, 2025) (quoting § 1006.12(1)(a), Fla. Stat.)).

4.   Again, this Court reiterates that Florida law does not prohibit school resource officers from simultaneously acting as law enforcement officers while performing their duties as school resource officers. See § 1006.12(1)(a), Fla. Stat.).

5.   Regardless of whether Deputy Daniels qualifies as “school personnel” who is not permitted to use mechanical restraints on disabled students under Florida law, see § 1003.573(3), Fla. Stat., Plaintiff has identified no binding authority for the proposition that his use of handcuffs in effecting the seizures, on its own, constitutes disability discrimination. As this Court has explained in its Order granting Defendant Daniels's motions for summary judgment, in effecting the mental health seizure, Daniels was constitutionally permitted to use some level of force—including handcuffing—to secure both children at the moment of the seizure and pursuant to Sheriff's Office policies regarding transportation. Moreover, Deputy Daniels, as the school resource officer, maintained his “powers and duties of a law enforcement officer ․ throughout [his] tenure as a school resource officer.” § 1006.12(a)(a), Fla. Stat. Although his power to conduct mental health seizures and arrests arguably conflicts with Florida law prohibiting the use of mechanical restraints, this conflict, on its own, does not constitute intentional disability discrimination that can be imputed to the School Board. Nor can the School Board be held liable for failing to train Daniels on Baker Act procedures. See D.L., 2025 WL 3763912, at *17 (“As a preliminary matter, the Court acknowledges that HCSB cannot be held liable for failing to train an SRO on Baker Act procedures.”). And the record demonstrates, without genuine dispute, that Daniels determined that the Sheriff's Office policy required both boys to be handcuffed while being transported to the receiving facility. In short, although Plaintiffs focus heavily on the fact that school staff and Daniels both made troubling comments regarding “consequences” during the seizures of both boys, Plaintiff has failed to point to any evidence demonstrating that either boy was handcuffed because of his asserted disabilities, rather than the myriad other, non-discriminatory reasons, including recent conduct—e.g., battery on school staff and Deputy Daniels—and for safe transport to the receiving facility.

Mark E. Walker United States District Judge