C.M., a former student at Dayspring Christian Academy, a private Christian school in Pennsylvania, sued the school and several administrators after allegedly enduring years of disability-based bullying, harassment, and physical abuse while enrolled from approximately 2018 through 2025. C.M., who has hydrocephalus, autism, and ADHD, attended a classroom designated for students with disabilities. He alleged that another student repeatedly subjected him to verbal harassment, physical assaults, inappropriate touching, and other mistreatment, and that school administrators were repeatedly notified that disabled students in the classroom were being targeted but failed to take adequate corrective action.
The complaint asserted claims under Title III of the Americans with Disabilities Act (“ADA”), Section 504 of the Rehabilitation Act (“RA”), negligence, breach of contract, and assault and battery against the former student. C.M. alleged that Dayspring participated in Pennsylvania’s Educational Improvement Tax Credit (“EITC”) and Opportunity Scholarship Tax Credit (“OSTC”) programs and also received Paycheck Protection Program (“PPP”) funds during portions of the relevant time period.
Dayspring moved to dismiss the complaint, arguing, among other things, that it was exempt from Title III of the ADA as a religious organization, that C.M. lacked standing to seek injunctive relief because he had already graduated, and that the School was not subject to Section 504 because it did not receive qualifying federal financial assistance during the relevant period.
The Court first addressed the ADA claim. Title III exempts “religious organizations or entities controlled by religious organizations” from its coverage. Dayspring argued that its Christian mission, curriculum, admissions materials, and governing documents established that it fell within this exemption. C.M. responded that discovery was necessary because Dayspring was governed by an independent board rather than a church and participated in certain government-funded educational programs. The Court observed that determining whether an organization qualifies for the religious exemption requires a fact-intensive analysis under the Third Circuit’s LeBoon factors, including the School’s purpose, governance structure, affiliation with organized religion, religious instruction, and how religion permeates its operations. Although the Court acknowledged that Dayspring had presented substantial evidence of its religious character, it concluded that dismissal based solely on the religious-organization exemption would be premature at the pleading stage because of the fact-intensive analysis required.
Nevertheless, the Court dismissed the ADA claim on a different ground. The Court explained that Title III authorizes only prospective injunctive relief, not compensatory or punitive damages. Because C.M. had already graduated from Dayspring and did not plausibly allege any real and immediate threat of future discrimination, he lacked standing to pursue the only relief available under Title III. His speculation that he might attend future school events was insufficient to establish standing. Accordingly, the ADA claim was dismissed with prejudice.
The Court reached a different conclusion under Section 504 of the Rehabilitation Act. Unlike Title III, Section 504 permits monetary damages where a plaintiff can establish intentional discrimination through deliberate indifference. Dayspring argued that any PPP funding had been received and forgiven before the alleged events and therefore could not establish Section 504 coverage. The Court concluded that at this stage, it could not resolve factual disputes regarding the timing or effect of the School’s receipt of federal financial assistance. Accepting the allegations as true, the Court held that C.M. had plausibly alleged that Dayspring received federal financial assistance during portions of the relevant period, allowing the Rehabilitation Act claim to proceed.
The Court also held that C.M. sufficiently alleged deliberate indifference. The complaint asserted that administrators received repeated notice over multiple years that C.M. and other students in the disability classroom were being bullied and physically mistreated yet failed to implement effective corrective measures. Although Dayspring argued that these allegations reflected, at most, imperfect responses rather than deliberate indifference, the Court concluded that those factual disputes could not be resolved at the pleading stage.
In addition, the Court rejected Dayspring’s argument that C.M. failed to allege discrimination because of his disability. The complaint alleged that the harassment specifically targeted students in the disability classroom because of their disabilities and perceived vulnerabilities, and that School officials knew disabled students were being targeted but failed to intervene. These allegations were sufficient to plausibly allege disability discrimination under Section 504.
Finally, the Court allowed C.M.’s negligence and breach of contract claims to proceed, concluding that they arose from duties independent of the federal disability statutes.
CM v. Dayspring Christian Acad. (E.D.Pa. June 12, 2026) 2026 WL 1707161.
Note: Relief under Title III of the ADA is limited to injunctive relief rather than monetary damages. Religious schools should also note that the ADA’s religious exemption does not automatically resolve disability discrimination claims, particularly where factual disputes exist regarding the school’s structure or operations.