Background
Jennifer Brantley, a student at the University of Texas at Austin, sued the university alleging disability discrimination and retaliation under the Rehabilitation Act and a due process claim under Section nineteen eighty-three. Brantley claimed the university discriminated against her by disciplining her for sending excessive emails to a professor, Dr. Scott Wolford, despite her disabilities including ADHD and PTSD. The district court dismissed the suit for lack of subject matter jurisdiction due to sovereign immunity and denied leave to amend as futile.
The court’s reasoning
The Fifth Circuit agreed with the district court that federal disability law does not prohibit an institution from disciplining a student for inappropriate behavior, even if that behavior results from a disability. The court noted that the university provided adequate procedural due process through notice, an opportunity to respond, and an appeal process. Regarding the retaliation claim, the court found that the faculty report was not an adverse action and that the disciplinary referral was caused by Brantley’s failure to cease contact, not by her prior complaints.
What it means going forward
The ruling clarifies that students cannot use federal anti-discrimination statutes to avoid consequences for harassing conduct, reinforcing the university’s authority to maintain a safe educational environment.