Filed Date: Jan. 19, 2018
Closed Date: Oct. 30, 2020
Clearinghouse coding complete
This case concerns a legal challenge brought against the Williamston Community School District for its nondiscrimination and anti-bullying policies.
On January 19, 2018, four parents, with two suing individually and on behalf of their minor children who appeared through a next friend, brought suit in U.S. District Court in the Western District of Michigan, Southern Division, against the Williamston Community School District and six members of the School District Board individually and in their official capacity. The School District had adopted seven new policies mandating non-discrimination on the basis of sexual orientation, gender identity, and gender expression: Policy 4900 (the Fair Employment Clause), Policy 7500 (the Guidance Program), Policy 8010 (Equal Educational Opportunity), Policy 8011 (Gender Identity), Policy 8040 (School Admissions), Policy 8260-R (Bullying), and Policy 8720 (Student Organizations). Plaintiffs argued that these policies promote alternative sexual lifestyles and behavior, in a manner that discriminates against and unconstitutionally prohibits the expression of plaintiffs’ personal identity, autonomy, and sincerely held religious beliefs – violating federal and state law. In their complaint, plaintiffs alleged that the implementation of these policies, which mandate affirmation and approval of alternative sexual lifestyles, constitutes harassment and bullying against students and parents who disagree with such viewpoints, permitting School District staff who identify speech that they interpret as bullying, hate speech, homophobic, or otherwise in disagreement with the policies to stop such speech, impose disciplinary measures, or otherwise label such speech as harassment or bullying.
Plaintiffs alleged the following claims: (1) The School District acted beyond its statutory authority in adding the new “non-discrimination” policies. (2) The School District violated state law (MCL 380.1310b), which imposes a requirement that school district bullying policies is content-neutral. (3) The policies infringe upon the parent plaintiffs’ fundamental constitutional right under the Fourteenth Amendment and state law (MCL 380.10) to control and direct the upbringing and education of their children. (4) Defendants’ new policies violate the constitutional right under the Fourteenth Amendment to privacy, personal identity, and personal autonomy, and under the First Amendment to freedom of speech and the free exercise of religion. (5) Defendants deprived plaintiffs of their rights under state constitutional law which guarantees freedom from discrimination, freedom of religious belief and speech, and free public schools without discrimination as to religion or other protected basis. (6) Defendants’ policies constitute violations of parent and student rights under Title IX of the Education Amendments of 1972 by permitting trans children to participate in athletics programs for their chosen gender. (7) The school policies are sufficiently ambiguous as to violate due process, and therefore be void for vagueness. (8) And the School District violated state civil rights law (the Elliott-Larsen Civil Rights Act), depriving plaintiff of certain civil rights via the implementation of the new policies. Two of the named plaintiff parents transferred their children from Williamston School District as a result of the policies. Plaintiffs sued under the First and Fourteenth Amendments, and 42 U.S.C. §1983, and sought declaratory injunctive relief, nominal damages, and compensatory damages for their claims. The case was assigned to District Judge Paul L. Maloney.
On February 28, 2018, defendants filed a motion to dismiss plaintiffs’ claims, alleging plaintiff failure to state a claim on which relief could be granted.
On March 12, 2018, Stand with Trans, a nonprofit organization that provides services to transgender youth, and the Williamston High School Gay-Straight Alliance, a non-profit organization at the school which advocates for LGBT youth, submitted motions to intervene as defendants, under the argument that defendants' anti-discrimination policies provide critical protections to members of both organizations and that their defenses of defendants' policies share common issues of fact and law with the main action. The motion to intervene was referred to Magistrate Judge Phillip J. Green, who on July 12, 2019, granted in part and denied in part the motion to intervene. Magistrate Judge Green ordered that Williamston High School Gay-Straight Alliance be granted leave to intervene as a defendant, but that Stand with Trans is not.
The case was re-assigned from District Judge Maloney to District Judge Hala Y. Jarbou.
On October 30, 2020, the court issued its decision to grant defendants’ motion to dismiss. With respect to plaintiffs’ claims grounded in federal law, the court held that plaintiffs (1) lacked standing as they failed to allege a specific “actual” or imminent injury, as the challenged School District policies had never in fact been applied in the ways that plaintiffs alleged they would be, and plaintiffs failed to otherwise allege a credible threat of enforcement; and (2) that the challenged policies were not unconstitutionally vague: that the School District had provided clear definitions for what constitutes misconduct, and therefore the policies were not void for vagueness. The court also opined that two of the parents’ decision to transfer their children from Williamston School District in anticipation of School District policy enforcement did not constitute an injury in fact, as they did not demonstrate any actual imminent injury. With respect to plaintiffs’ state law claims, the court held that ordinarily, federal courts lack jurisdiction to adjudicate state law claims, and supplemental jurisdiction is inappropriate here as all of the federal claims dropped out. The court therefore found it appropriate to dismiss all state law claims. Therefore, with all of the plaintiffs’ claims dismissed, the court dismissed plaintiffs’ complaint for lack of jurisdiction and failure to state a claim. No appeal has been filed, and no further developments have occurred in the case as of March 7, 2025.
This case is now closed.
Summary Authors
Keren Yi (3/7/2025)
For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/14499722/parties/reynolds-v-talberg/
Jarbou, Hala Yalda (Michigan)
Kallman, David A. (Michigan)
Chapie, Kenneth B. (Michigan)
Allen, Christopher M. (Michigan)
Kaplan, Jay David (Michigan)
See docket on RECAP: https://www.courtlistener.com/docket/14499722/reynolds-v-talberg/
Last updated Sept. 2, 2025, 9 a.m.
State / Territory: Michigan
Case Type(s):
Key Dates
Filing Date: Jan. 19, 2018
Closing Date: Oct. 30, 2020
Case Ongoing: No reason to think so
Plaintiffs
Plaintiff Description:
Plaintiffs are four parents, with two suing individually and on behalf of their minor children who appeared through a next friend
Plaintiff Type(s):
Public Interest Lawyer: Unknown
Filed Pro Se: No
Class Action Sought: No
Class Action Outcome: Not sought
Defendants
Williamston Community School District (Williamston), City
Members of the Williamston Community School District Board (Williamston), City
Defendant Type(s):
Case Details
Causes of Action:
Constitutional Clause(s):
Available Documents:
Outcome
Prevailing Party: Defendant
Nature of Relief:
Source of Relief:
Issues
General/Misc.:
Discrimination Basis:
LGBTQ+: