Plaintiff Cherie Boyer, individually and on behalf of her minor child S.B., sued Gateway Regional Young Men’s Christian Association (YMCA) and Hillsboro R-3 School District in the United States District Court for the Eastern District of Missouri, raising claims of disability discrimination and retaliation under the Americans with Disabilities Act (ADA) and the Missouri Human Rights Act (MHRA). Defendant Hillsboro R-3 School District moved to dismiss the claims against it under Rule 12(b)(6).
Factual Overview
The case arose from alleged discrimination and retaliation against Boyer’s minor son in an after-care program. The YMCA contracted with the School District to provide before- and after-school care services called “Y Care” at District facilities, including Hillsboro Primary School. Boyer’s son S.B., who has disabilities requiring accommodation, attended Y Care beginning in August 2022. Despite the YMCA’s initial agreement to provide a one-on-one aide to prevent elopement and moderate S.B.’s behaviors, the aide was frequently absent. In September 2022, S.B. wandered the halls unattended. After multiple incidents and complaints about S.B.’s behavior, which Boyer alleged were manifestations of his disabilities, the YMCA terminated S.B. from the program in December 2022.
Legal Analysis
MHRA Aiding and Abetting: The court applied the Restatement of Torts standard, which requires knowledge of the primary actor’s breach of duty and substantial assistance or encouragement. The court found Boyer’s conclusory allegation that the District “aided and abetted” the YMCA insufficient. The court emphasized that the sole action alleged against the District – contracting to provide space for the YMCA program – did not rise to the level of substantial assistance or encouragement of discriminatory conduct.
MHRA Discrimination: The court examined the requirements for an MHRA discrimination claim, which requires showing membership in a protected class, discrimination in public accommodation, and that protected status was a motivating factor. The court found Boyer failed to allege any facts showing the District took discriminatory actions against S.B., either directly or indirectly. The court determined that merely providing space through a contract was insufficient to state a discrimination claim.
MHRA Retaliation: The court outlined that an MHRA retaliation claim requires showing opposition to discrimination, adverse action, and a causal relationship. While Boyer alleged retaliatory actions by the YMCA, the court found the petition contained no allegations of retaliatory conduct by the District in response to Boyer’s complaints about discrimination.
ADA Failure to Accommodate: The court analyzed Title III of the ADA, which requires places of public accommodation to take necessary steps to avoid disability-based discrimination. The court found the petition, while alleging the YMCA failed to accommodate S.B., contained no allegations that the District took any action regarding accommodations or made any decisions about S.B.’s participation in the program. The court concluded that merely providing space through a contract was insufficient to create liability under the ADA.
The court granted the School District’s motion to dismiss all claims against it, finding that Boyer failed to state plausible claims under either the MHRA or ADA.
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