Reported / Citable
Background
Deborah Painter and other plaintiffs sued Celina Independent School District, alleging violations of the Americans with Disabilities Act.
After the case was referred to a magistrate judge, the school district moved to dismiss the plaintiffs’ request for punitive damages. The magistrate judge recommended granting that motion and denying leave to amend. No party objected to the report.
The Court’s Holding
District Judge J. Campbell Barker accepted the magistrate judge’s findings and recommendation after reviewing the record for clear error.
The court held that punitive damages are unavailable under the ADA against a political subdivision such as a school district. It granted the district’s motion to dismiss, dismissed the punitive-damages request with prejudice, and denied the plaintiffs’ request for leave to amend.
Key Takeaways
- ADA plaintiffs cannot obtain punitive damages from a school district, a political subdivision.
- The punitive-damages claim was dismissed with prejudice.
- With no objections to the magistrate judge’s report, the court reviewed the record for clear error before adopting it.
Why It Matters
The order eliminates a category of damages from the case while leaving the plaintiffs’ underlying ADA claims unaddressed. It also underscores that parties should timely object to a magistrate judge’s recommendation if they seek more searching district-court review.