Doe V. Knox County Board Of Education

Case Background

On February 17, 2022, Jane Doe, a minor student, through her parents K.M. and A.M. filed a civil rights lawsuit against the Knox County Board of Education for failing to accommodate her misophonia disorder. She alleged disability discrimination and violation of the Americans with Disabilities Act (ADA) in her lawsuit.

The lawsuit was filed in the United States District Court, Tennessee Eastern (Knoxville). The case was assigned to District Judge Katherine A Crytzer and referred to Magistrate Judge Debra C Poplin. [Case Number: 3:22cv63]

Cause

In the fall of 2021, Jane Doe, a 14-year-old freshman at L&N Stem Academy in Knoxville, faced challenges at school due to her misophonia disorder. This condition caused her to experience extreme emotional reactions, such as fear and anxiety, when exposed to specific sounds, particularly chewing and eating noises. While her middle school had a policy that prohibited eating in class, L&N Stem did not have such a rule. Instead, the school left this decision to individual teachers.

Doe’s exposure to eating sounds in class interfered with her learning. Her parents, both professors at the University of Tennessee, contacted school officials to request an accommodation. They asked for a policy that would prevent students from eating or chewing gum during class.

The school declined their request. The principal argued that enforcing a “no eating in class” policy would be too disruptive. She claimed it would be impractical to monitor snacks, like potato chips, and that it would require creating eight separate lunch periods, which would disrupt the school schedule. The school offered to let Doe leave the classroom if she was triggered by certain sounds.

However, the Doe family felt the school misunderstood their request. They did not seek to ban food altogether, only to prevent eating and chewing during class. The plaintiffs believed the principal had exaggerated the difficulties of implementing their accommodation.

Damages

Because the case did not involve intentional discrimination, Doe could not receive compensatory damages even if she won. Since Doe could not receive compensatory damages, she would likely be entitled to attorney’s fees and case-related costs if she won.

Key Arguments and Proceedings

Legal Representation

  • Plaintiff(s): Jane Doe The Student | next friend | K.M. (Parent) | next friend | A.M. (Parent) |
    • Counsel for Plaintiff(s): Justin S. Gilbert | Jessica F. Salonus
  • Defendant(s): Knox County Board of Education
    • Counsel for Defendant(s): Amanda Lynn Morse | Jessica Jernigan-Johnson

Claims

After the principal issued a final decision in February 2022, the Pla sued the Knox County Board of Education in federal court. They claimed the school failed to accommodate Doe, violating the ADA or Section 504 of the Rehabilitation Act which is a federal law that protects qualified individuals from discrimination based on their disability.

In April 2022, Judge Crytzer granted the school board’s motion to dismiss. She ruled that Doe had not fully pursued administrative remedies under the IDEA. The court emphasized that federal courts lack the expertise to handle such disputes, making the exhaustion of remedies essential.

The Plaintiffs appealed, and the Sixth Circuit reversed the decision on January 6, 2023. Judge Murphy, joined by Judges Sutton and Donald, wrote the opinion. The court determined that a ban on eating in class did not involve instruction. Because the issue was unrelated to instruction, exhaustion of remedies was unnecessary.

The Plaintiffs had also requested a preliminary injunction. However, by the time the appellate court issued its decision, Doe had enrolled in an out-of-state boarding school, rendering the request moot.

Defense

The case proceeded to trial on Doe’s failure to accommodate claims under the ADA and Section 504. The board of education argued that the requested accommodation was unreasonable and would fundamentally alter school operations. It also claimed the accommodation would be ineffective because sounds could still trigger Doe. Finally, the board asserted that the school had already provided a reasonable accommodation.

Jury Verdict

The trial took place in Knoxville over four days. On January 14, 2025, the jury rejected the ADA and Section 504 claims. Since damages were not at issue, deliberations ended there. The court entered judgment in favor of the school board.

Court Documents:

Documents are available for purchase upon request at jurimatic@exlitem.com