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Qualifying our Coaches for Immunity: The Unlikely Application of the §1983 Defense in the School Sports Context

The doctrine of qualified immunity protects state and local officials from civil liability unless the official violated a clearly established constitutional right.[1] Due to the Supreme Court’s narrow definition of “clearly established,” the doctrine has come under fire for essentially alleviating accountability from state actors who violate individuals’ constitutional rights.[2] Police officers, specifically, have been found to be entitled to qualified immunity from civil liability in cases where they have either seriously injured or taken the lives of others.[3] However, the doctrine extends to more than just police officers. This article analyzes the application of qualified immunity in the school sports context, and how the legal system’s handling of these claims fits into the larger discussion of students’ ability to remedy constitutional violations.

 

In cases filed by student athletes alleging constitutional violations on behalf of coaches, athletic trainers, and other school personnel, several federal and state courts have found these defendants entitled to qualified immunity. In Davis v. Carter, a high school football player, Tyler Davis, died as a result of a workout session for the football team.[4] Davis’s parents brought suit alleging that their son was subjected to an intense and unreasonable practice that caused him to collapse and die the next morning, that coaches failed to provide enough water to keep Davis hydrated, ignored signs as well as Davis’ complaints that he was becoming dehydrated, subjected Davis to rigorous conditioning drills at the end of a two-hour practice, and failed to attend to his condition until after a team meeting, even though Davis had collapsed in the middle of drills.[5] Here, Plaintiffs argue that the coaches’ deliberate decisions resulted in the deprivation of Davis’s right to life, liberty, health, bodily integrity, and safety as guaranteed by the 14th Amendment.[6] The Eleventh Circuit found that the coaches were entitled to qualified immunity.[7]

 

In Mann v. Palmerton Area School District, the parents of Sheldon Mann brought suit against both the school district and the football coach after their son was diagnosed with a traumatic brain injury due to sustaining multiple “hard hits” during football practice.[8] Mann’s parents alleged that Appellees had deprived Mann of his constitutionally protected right to bodily integrity, arguing that Appellees required Mann to continue participating after sustaining a hard hit and exhibiting signs of a concussion, that they failed to assure that Mann was medically cleared to resume participation in the sport, failed to enforce and enact proper concussion policies, and failed to train the coaches on the safety protocol for head injuries.[9] Again, the circuit court found that the coach was entitled to qualified immunity.[10]

 

In Armstrong v. Estate of Star Ifeacho, a high school sophomore died after attending an after-school basketball “open gym.”[11] Here, Ifeacho’s parents alleged that both the coach who was supervising the open gym, Armstrong, as well as the athletic trainer, Begley, were negligent in providing medical aid to Ifeacho after he complained of chest pains.[12] The Kentucky Court of Appeals held that both Armstrong and Begley made discretionary judgement calls and were both entitled to qualified immunity.[13]

 

The application of qualified immunity in this context is particularly problematic, given how often students have been less protected or even unprotected by the courts in the event of constitutional violations. While the Supreme Court has assured that students do not “shed their constitutional rights … at the schoolhouse gate,”[14] it has also clarified that “the nature of those rights is what is appropriate for children in school.”[15] The law has indicated that students have limited rights while in school, “in light of the special characteristics of the school environment.”[16] This is due in large part to the unique supervisory role of school officials, including teachers, coaches, and other staff, and has led to adjusted standards for evaluating students’ rights and constitutional violations in public schools. Even if the constitutional standard is not adjusted, as in the case of evaluating 14th Amendment violations, the reality that students have limited rights within the public-school setting contributes to an overall lax attitude exhibited by schools and courts when analyzing violations. This undeniably limits students’ ability to rectify situations in which their rights are violated. The doctrine of qualified immunity takes this burden to redressability a step further, protecting “all but the plainly incompetent or those who knowingly violate the law.”[17]

 


[1] Qualified Immunity, Nat’l Conf. of State Legislatures (Jan. 12, 2021), https://www.ncsl.org/research/civil-and-criminal-justice/qualified-immunity.aspx.

[2] Qualified Immunity, Equal Just. Initiative, https://eji.org/issues/qualified-immunity/.

[3] Id.

[4] Davis v. Carter, 555 F.3d 979, 980 (11th Cir. 2009).  

[5] Id. at 980–81.

[6] Id. at 981.

[7] Id. at 984.

[8] Mann v. Palmerton Area Sch. Dist., 872 F.3d 165, 169 (3d Cir. 2017).

[9] Id. at 169–70.

[10] Id. at 174.

[11] Armstrong v. Estate of Star Ifeacho, 633 S.W.3d 333, 336 (Ky. Ct. App. 2021).

[12] Id. at 337.

[13] Id. at 341–42. 

[14] Tinker v. Des Moines Indep. Cmty. Sch. Dist., 393 U.S. 503, 506 (1969).

[15] Veronica Sch. Dist. 47J v. Acton, 515 U.S. 646, 656 (1995).

[16] Tinker, 393 U.S. at 506.

[17] Malley v. Briggs, 475 U.S. 335, 341 (1986).

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