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A Naperville high school student tragically took his own life after being questioned and threatened by school personnel because of a video recording he made of himself and a female student having sex. School officials interrogated the student in a manner that “caused him to suffer extreme psychological distress and fear.” He was accused of possessing and disseminating child pornography, and the school further threatened that he would be registered as a sex offender because of the incident. The student was held in the principal’s office during the interrogation, and while left unattended he left the school premises, walked to a nearby parking garage, and jumped off of the fifth floor. He later died from injuries sustained in the fall.

The student’s parents filed suit against the school district for the events leading up to their son taking his own life. They asserted claims alleging violations of the Fourth and Fourteenth Amendments of the US Constitution, based on “unreasonable conditions of confinement, deliberate indifference to serious medical needs, statute created danger, intentional interference with the child-parent relationship, and conscience-shocking coercive interrogation.” A federal district court found that the parents’ complaint failed to fully allege any liability for the school.

Specifically, the court found that the complaint failed to establish an illegal seizure under the Fourth Amendment because there was no indication that the school’s holding of the student for interrogation in the principal’s office was unreasonable. Further, the court found the parents also failed to establish that the school had deliberate indifference to the student’s serious medical needs because there was no evidence to prove that the school had actual notice of the student’s mental state to suggest he was suicidal. Additionally, the school’s confinement of the student did not rise to the level of intentional interference with the child-parent relationship because the school’s confinement of the student was reasonably pursuant to their investigation. Therefore, the court found that the student’s parents had failed to establish that the school committed constitutional violations in how it handled the investigation. The federal district court of Illinois dismissed the parents’ complaint against the school, but the parents do have the option to amend and refile their complaint to cure the defects of their original complaint.

It is important to note that, whereas the court determined that the parents had failed to establish any violations by the school in their complaint, the court’s opinion did not condone the “interrogation tactics” used by the school—there was simply nothing to suggest that they were not within the range of normal police interrogation tactics and did not rise to a level to “shock the conscience.” Therefore, whereas the school officials who confined, interrogated, and threatened the student did not violate the constitution, the court noted the school lacked judgment in how it handled the situation.