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S. P. v. Boule
No. SJC-06746 (Mass. Sup. Jud. Ct. filed Dec. 19, 1994) ; Clearinghouse Number: 50714
Description
Student Who Brought a 1¼-Inch Blade in a Lipstick Case to School Challenges Her Expulsion for Possession of a Dangerous Weapon
Abstract
Plaintiff student has filed her brief on appeal in this suit
challenging defendant school officials’ decision to expel
her. Plaintiff, a 16-year-old high school student had been
suspended for five days after school officials discovered her in
possession of a lipstick containing a small blade. Subsequently,
the school principal held a hearing and expelled student, found to
have been in possession of a weapon on school grounds. The trial
court upheld student’s expulsion. On appeal, student argues
that she has a fundamental interest in her education, and therefore
the decision to expel her from school is subject to strict scrutiny
analysis. Student asserts that the expulsion was not justified
because she was not in possession of a dangerous weapon, did not
intend to harm or threaten anyone, and had no history of aggressive
behavior. Student maintains that a suspension would have preserved
defendants’ interests without totally denying student her
education. Student also argues that the lipstick case containing a
1¼-inch blade did not constitute a “dangerous
weapon” under state law and that defendants abused their
discretion by expelling her. Finally, student argues that if
defendants consider the lipstick case with blade a dangerous weapon
under state law and deprive her of her education as a result, then
the statute is void for vagueness. The Center for Law and Education
in its amicus brief on student’s behalf argues that permanent
expulsion or other long-term exclusion from public education is an
impermissible infringement on the right to education, in violation
of the Massachusetts Constitution. Amicus also argues that
student’s emotional problems and suicide attempts render her
a protected individual with a disability under Section 504 of the
Rehabilitation Act and the Americans with Disabilities Act and that
defendants may not expel or otherwise discipline her for conduct
related to these problems.
