Case: Galeas v. Law School Admission Council

4:14-cv-00651 | U.S. District Court for the Southern District of Texas

Filed Date: March 14, 2014

Closed Date: 2014

Clearinghouse coding complete

Case Summary

On March 14, 2014, a female student filed this lawsuit in the United States District Court for the Southern District of Texas against The Law School Admission Council (LSAC) and The American Bar Association (ABA). The student sued under the Americans with Disabilities Act, Section 504 of the Rehabilitation Act, Title IX, and 42 U.S.C. § 1983. Representing herself, the student asked for injunctive relief and monetary damages for the alleged discrimination. Specifically, the student alleged that …

On March 14, 2014, a female student filed this lawsuit in the United States District Court for the Southern District of Texas against The Law School Admission Council (LSAC) and The American Bar Association (ABA). The student sued under the Americans with Disabilities Act, Section 504 of the Rehabilitation Act, Title IX, and 42 U.S.C. § 1983. Representing herself, the student asked for injunctive relief and monetary damages for the alleged discrimination. Specifically, the student alleged that the defendants delayed and denied accommodation requests by the plaintiff, causing her to incur numerous fees and to miss administration of the Law School Admission Test (LSAT). She claimed this violated the equal protection clause of the 14th Amendment as well as the other federal statutes she sued under.

The student claimed that she submitted numerous medical documents that attested to her Inattentive Type of ADHD and that both defendants failed to review the documentation so as to provide her with testing accommodation. She also claimed that her denial of accommodation was based on a test (the Woodcock Johnson assessment) that was not the preferred instrument listed in the LSAC guidelines. The student also alleged that the defendants' denial of necessary services and accommodations constituted discrimination based on sex as well as disability. She claimed that her male counterparts were given accommodations due to their Hyperactivity Type of ADHD, which can be diagnosed at a younger age and therefore provide more medical documentation.

The ABA filed a motion to dismiss due to a failure to state a claim. The ABA claimed no part in developing or administering the LSAT, nor involvement in the offer of accommodations for the test. As such, the ABA could not have been subject to the court's jurisdiction or able to provide redress. The LSAC also filed a motion to dismiss for failure to state a claim. It stated that the plaintiff did not follow through on her claim under Section 504 of the Rehabilitation Act; that the LSAC is not a state actor and therefore not subject to the Equal Protection Clause; that her allegations are insufficient for relief under Title IX, in part because LSAC was not alleged to be an educational program or a recipient of federal aid; and that Title III of the ADA does not provide for monetary damages.

On September 3, 2014, the Court (Judge Melinda Harmon) granted the LSAC's motion to dismiss. On September 22, 2014, the Court granted the ABA's motion to dismiss. These orders were both granted pursuant to joint stipulations of dismissal from the plaintiff and each defendant.

Summary Authors

Carolyn Weltman (10/26/2015)

People


Judge(s)

Harmon, Melinda (Texas)

Attorneys(s) for Defendant

LeRoy, Tracy N (Texas)

Suh, Eun Ae (Texas)

Judge(s)

Harmon, Melinda (Texas)

Attorneys(s) for Defendant

LeRoy, Tracy N (Texas)

Suh, Eun Ae (Texas)

Documents in the Clearinghouse

Document

4:14-cv-00651

Docket

Galeas v. Law School Admission Council et al

Sept. 22, 2014

Sept. 22, 2014

Docket
1

4:14-cv-00651

Original Complaint

Galeas v. Law School Admission Council, Inc.

March 14, 2014

March 14, 2014

Complaint
17

4:14-cv-00651

Order of Dismissal (LSAC)

Sept. 3, 2014

Sept. 3, 2014

Order/Opinion
19

4:14-cv-00651

Order of Dismissal (ABA)

Sept. 22, 2014

Sept. 22, 2014

Order/Opinion

Docket

Last updated Aug. 30, 2022, 3:05 a.m.

ECF Number Description Date Link Date / Link
1

COMPLAINT against All Defendants (Filing fee $ 400) filed by Jessica Galeas. (Attachments: # 1 Civil Cover Sheet)(olindor, 4) (Entered: 03/14/2014)

March 14, 2014

March 14, 2014

Confirmation of receipt of payment from Jessica Galeas in the amount of $ 400 Receipt date: 3/14/2014. Receipt number HOU043846, HOU043847, HOU043848. Purpose Description: filing fee. (olindor, 4) (Entered: 03/14/2014)

March 14, 2014

March 14, 2014

2

ORDER for Initial Pretrial and Scheduling Conference and Order to Disclose Interested Persons. Initial Conference set for 8/26/2014 at 10:00 AM in Courtroom 704 before Judge Stacy (Signed by Judge Melinda Harmon) Parties notified.(olindor, 4) (Entered: 03/14/2014)

March 14, 2014

March 14, 2014

***Set/Reset Hearings: Initial Conference set for 8/26/2014 at 10:00 AM in Courtroom 704 before Magistrate Judge Frances H Stacy (olindor, 4) (Entered: 03/17/2014)

March 17, 2014

March 17, 2014

4

MOTION for Extension of Time To Answer or Otherwise Plead by American Bar Association, filed. Motion Docket Date 6/6/2014. (Attachments: # 1 Proposed Order)(LeRoy, Tracy) (Entered: 05/16/2014)

May 16, 2014

May 16, 2014

5

ORDER granting 4 Motion for Extension of Time; Answer due for American Bar Association 6/20/2014.(Signed by Judge Melinda Harmon) Parties notified.(rhawkins, 4) (Entered: 05/22/2014)

May 20, 2014

May 20, 2014

6

MOTION to Dismiss 1 Complaint by Law School Admission Council, filed. Motion Docket Date 6/20/2014. (Attachments: # 1 Memorandum of Law in Support of ISAC's Motion to Dismiss, # 2 Proposed Order)(Suh, Eun) (Entered: 05/30/2014)

May 30, 2014

May 30, 2014

7

CORPORATE DISCLOSURE STATEMENT by Law School Admission Council, filed.(Suh, Eun) (Entered: 05/30/2014)

May 30, 2014

May 30, 2014

8

Unopposed MOTION for Extension of Time To Answer or Otherwise Plead by American Bar Association, filed. Motion Docket Date 7/8/2014. (Attachments: # 1 Proposed Order)(LeRoy, Tracy) (Entered: 06/17/2014)

June 17, 2014

June 17, 2014

9

ORDER granting 8 Defendant American Bar Association's Second Unopposed Motion for Extension of Time to Answer or Otherwise Plead. Answer due by 7/7/2014. (Signed by Judge Melinda Harmon) Parties notified. (rosaldana, 4) (Entered: 06/20/2014)

June 20, 2014

June 20, 2014

10

MOTION to Dismiss Plaintiff's Complaint by American Bar Association, filed. Motion Docket Date 7/28/2014. (Attachments: # 1 Supplement Memorandum in Support of Motion to Dismiss, # 2 Exhibit, # 3 Proposed Order)(LeRoy, Tracy) (Entered: 07/07/2014)

July 7, 2014

July 7, 2014

11

MOTION to Vacate by American Bar Association, filed. Motion Docket Date 9/2/2014. (LeRoy, Tracy) (Entered: 08/11/2014)

Aug. 11, 2014

Aug. 11, 2014

12

STATEMENT Regarding A Discovery/Case Management Plan Under Rule 26(F) re: 11 MOTION to Vacate by American Bar Association, filed.(LeRoy, Tracy) (Entered: 08/15/2014)

Aug. 15, 2014

Aug. 15, 2014

13

PROPOSED ORDER On American Bar Association's Motion To Vacate Initial Pretrial and Scheduling Conference re: 11 MOTION to Vacate, filed.(LeRoy, Tracy) (Entered: 08/19/2014)

Aug. 19, 2014

Aug. 19, 2014

14

NOTICE of Referral of Motion to Magistrate Judge Frances H. Stacy re 11 MOTION to Vacate, filed. (rvazquez) (Entered: 08/21/2014)

Aug. 21, 2014

Aug. 21, 2014

15

STIPULATION of Dismissal −− JOINT Stipulation of Dismissal between Plaintiff Jessica Galeas and Defendant Law School Admission Council by Law School Admission Council, filed.(Suh, Eun) (Entered: 08/22/2014)

Aug. 22, 2014

Aug. 22, 2014

16

NOTICE of Resetting. Parties notified. Initial Conference set for 10/7/2014 at 10:00 AM in Courtroom 704 before Magistrate Judge Frances H Stacy, filed. (bwhite, 4) (Entered: 08/25/2014)

Aug. 25, 2014

Aug. 25, 2014

17

ORDER OF DISMISSAL re: 15 Stipulation of Dismissal. Case terminated on September 3, 2014(Signed by Judge Melinda Harmon) Parties notified.(rvazquez) (Entered: 09/04/2014)

Sept. 3, 2014

Sept. 3, 2014

18

STIPULATION of Dismissal Joint Stipulation of Dismissal by American Bar Association, filed. (Attachments: # 1 Proposed Order)(LeRoy, Tracy) (Entered: 09/15/2014)

Sept. 15, 2014

Sept. 15, 2014

19

ORDER OF DISMISSAL(Signed by Judge Melinda Harmon) Parties notified.(marflores, 4) (Entered: 09/23/2014)

Sept. 22, 2014

Sept. 22, 2014

Case Details

State / Territory: Texas

Case Type(s):

Disability Rights

Special Collection(s):

Multi-LexSum (in sample)

Key Dates

Filing Date: March 14, 2014

Closing Date: 2014

Case Ongoing: No

Plaintiffs

Plaintiff Description:

A female student diagnosed with Inattentive Type of ADHD

Plaintiff Type(s):

Private Plaintiff

Public Interest Lawyer: No

Filed Pro Se: Yes

Class Action Sought: No

Class Action Outcome: Not sought

Defendants

Law School Admission Council (LSAC) (Newton), Private Entity/Person

American Bar Association (ABA) (Chicago), Private Entity/Person

Case Details

Causes of Action:

42 U.S.C. § 1983

Americans with Disabilities Act (ADA), 42 U.S.C. §§ 12111 et seq.

Section 504 (Rehabilitation Act), 29 U.S.C. § 701

Constitutional Clause(s):

Equal Protection

Availably Documents:

Trial Court Docket

Complaint (any)

Outcome

Prevailing Party: None Yet / None

Nature of Relief:

None

Source of Relief:

None

Form of Settlement:

Voluntary Dismissal

Amount Defendant Pays: 0

Issues

General:

Access to public accommodations - privately owned

Disparate Treatment

Education

Test or device

Discrimination-area:

Accommodation / Leave

Discrimination-basis:

Disability (inc. reasonable accommodations)

Race:

Race, unspecified

Disability:

Mental impairment

Mental Disability:

Developmental disability without intellectual disability