In Henson v. Dwight Common School District No. 232, the Seventh Circuit affirmed the dismissal of a parent’s lawsuit challenging the district’s policy that barred him from volunteering at his child’s school because of his criminal history. The parent initially asserted procedural due process, equal protection, and Illinois Uniform Conviction Information Act (“UCIA”) claims and later amended his complaint to pursue substantive due process, equal protection, state-law, and irreparable-injury theories. Applying “rational-basis review,” the Seventh Circuit agreed that the district’s policy of excluding volunteer applicants with criminal histories was reasonably related to the legitimate goal of protecting student safety.
The parent sought placement on the district’s approved volunteer list so that he could chaperone his child’s school activities, but his application was denied under the district’s policy excluding applicants with criminal histories. The parent characterized his record as involving only an old nonviolent conviction.
The court noted that he had several felony convictions in 2021, which the district considered when applying its policy, and emphasized that its decision did not depend on the specific nature of those offenses; it distinguished between applicants with criminal histories and those without on a reasonable and rational basis to protect student safety. The court dismissed his claims, and on appeal the Seventh Circuit affirmed the lower court’s decision. The Seventh Circuit emphasized that while parents have constitutional rights concerning the upbringing and education of their children, those rights do not extend to serving as school volunteers or attending school functions whenever they choose.
As a result, this case reinforces the principle that school districts have broad discretion to establish volunteer-screening policies, including criminal-history restrictions, so long as those policies are rationally connected to legitimate educational and safety interests.
Source:
Henson v. Dwight Common Sch. Dist. No. 232, No. 25-3276, WL 2170864 (7th Cir. July 28, 2026)
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