Taylor v. Roswell Indep. Sch. Dist. - 713 F.3d 25 (10th Cir. 2013)

Rule:

Summary judgment is proper when the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law. Fed. R. Civ. P. 56(a). A fact is genuinely disputed if the evidence is such that a reasonable jury could return a verdict for the non-moving party. A fact is material if it might affect the outcome of the suit under the governing law. Courts draw all reasonable inferences from the evidence in favor of the nonmoving party. Summary judgment for the movant is appropriate only if the record taken as a whole could not lead a rational trier of fact to find for the non-movants.

Facts:

Plaintiff high school students from Roswell, New Mexico belonged to a religious group called "Relentless". They sued Roswell Independent School District and Superintendent Michael Gottlieb in his official capacity (collectively "the District") seeking declaratory and injunctive relief. Their complaint alleged that school officials violated their First and Fourteenth Amendment rights by preventing them from distributing 2,500 rubber fetus dolls to other students. It also challenged the District's policies requiring preapproval before distributing any non-school-sponsored material on school grounds. A magistrate judge granted summary judgment for the District on all claims, and Plaintiffs appealed.

Issue:

Was the grant of summary judgment on all claims raised by plaintiffs proper? 

Answer:

Yes.

Conclusion:

The court affirmed the grant of summary judgment on all claims, holding that the students’ free speech challenges failed because the school officials reasonably forecasted that the distribution would cause substantial disruption and because the distribution did cause substantial disruption. Moreover, the students' free exercise and equal protection claims failed because the decision to stop the distribution was not based on religion, and the students failed to show they were treated differently from similarly situated students. The students' facial challenge to the school policy also failed. The policy was not unconstitutional under the prior restraint doctrine because it constrained official discretion and contained adequate procedural safeguards—and because it applied to the school environment where greater deference was given to school officials. It was not void for vagueness because students of ordinary intelligence could understand its meaning and it neither authorized nor encouraged arbitrary or discriminatory enforcement. The policy requiring preapproval before distributing any non-school-sponsored material on school grounds contained adequate procedural safeguards to pass constitutional muster. It was not facially unconstitutional as a prior restraint or as vague.