(CN) – A former track coach who claims an Arizona charter school falsely labeled him a pedophile and blocked him from getting another job can’t sue in federal court, the 9th Circuit ruled, because the school and its director are not “state actors.”
Michael Caviness accused Horizon Community Learning Center and executive director Lawrence Pieratt of refusing to renew his contract after a female student complained that “the student-teacher boundary had been crossed.”
When the school investigated, it learned that the student had a crush on Caviness and had filed the grievance in retaliation for his having an adult girlfriend.
Nonetheless, the school questioned Caviness’ communication with the student and decided not to renew his contract.
Caviness claimed that Horizon employees called him a pedophile, and that Pieratt refused to give him a fair assessment for a prospective teaching job.
His attorney sent Horizon a letter demanding “written representations from Horizon that it had instructed all of its agents and employees to cease and desist from making any further false and defamatory statements to anyone.”
Pieratt allegedly ignored the request, prompting Caviness to demand a hearing to clear his name. He said Horizon never responded.
The district court dismissed his claims for lack of subject-matter jurisdiction, saying Horizon and its administration were not state actors, even though charter schools are considered “public schools” under Arizona law.
The 9th Circuit agreed that Horizon, a private nonprofit corporation, was not acting under the color of state law when dealing with Caviness.
“Horizon is a private entity that contracted with the state to provide students with educational services that are funded by the state,” Judge Sandra Ikuta explained.
“Ultimately, Horizon’s actions and personnel decisions were ‘made by concededly private parties, and turn[ed] on judgments made by private parties without standards established by the state,'” Ikuta added, citing Supreme Court precedent.