Jackson v. Indian Prairie School Dist. 204

Dist. Ct. did not err in granting defendant-school district's motion for summary judgment in section 1983 action by plaintiff-special ed. teacher, alleging that defendant violated her substantive due process where: (1) school principal directed her to tend to autistic student, who had long history of verbal and physical outbursts and who subsequently injured plaintiff during violent outburst; and (2) prior to incident, defendant repeatedly failed to transfer student to alternative school in spite of complaints registered by other teachers, who had witnessed student's outbursts, as well as parents of classmates of student. While defendant's conduct might have been negligent, it did not rise to "shock the conscious" level required to impose liability for substantive due process violation where student appeared to be calm just prior to instant incident and where, prior to incident, student's behavior had generally improved in terms of fewer number of incidents.