John and Jane Doe are parents of James, a Black student at The Haverford School, an all-boys private school in Pennsylvania. James attended the School since pre-kindergarten under yearly Enrollment Contracts requiring satisfactory academic progress, timely payment, and appropriate behavior by student and parents, and authorizing the Head of School, in his sole discretion, to require withdrawal if continuing enrollment was not in the best interests of the student or the School. The family also agreed to abide by the behavioral standards in the Lower School Student and Family Handbook.
James had a history of behavioral difficulties, including hitting, kicking, biting, pushing, and disrupting his classmates. At the start of his third-grade year, his behavior worsened, with repeated conflicts involving classmates and multiple incidents of physical aggression.
The School implemented a support plan and interventions (e.g., self-regulation charts, task-based de-escalation, and designated staff check-ins) while also adding classroom observation and a ticket-recognition system to reinforce expectations. Despite these supports, incidents continued. Tensions peaked in November 2022 when James and another student, referred to as Student #1, began arguing and physically confronting each other. After one such altercation in P.E. class, James told his parents that Student #1 had called him the “n word.”
James’s parents reported the incident to the School’s Lower School Head, Dr. Pam Greenblatt, but they alleged the follow-up was slow and disorganized. Some administrators thought the slur occurred off campus, and the School did not immediately interview the accused student. When Haverford’s diversity director eventually met with Student #1, he denied using the slur, though she discussed why such language was harmful. The School took some steps to separate the boys and monitor their interactions, but James’s behavioral struggles continued and intensified. Over a three-day period at the end of November, he hit and threatened classmates, threw scissors across the room, and disrupted lessons. Haverford concluded it could no longer maintain a safe and effective learning environment and asked James’s parents to withdraw him from the School.
The Does filed suit in federal court, alleging race discrimination and retaliation under 42 U.S.C. §1981, along with various state law claims, including breach of contract, negligence, breach of fiduciary duty, and intentional infliction of emotional distress. Haverford sought summary judgment on all claims.
The Court found that while the School’s slow and uncoordinated response to the reported slur was troubling and sufficient to raise an inference of discrimination for purposes of a prima facie case, the School offered a legitimate, non-discriminatory reason for its decision: James’s escalating behavioral problems. The record showed repeated incidents of hitting, threatening, and disrupting class, culminating in several serious episodes immediately before the withdrawal request. The Court held that the parents presented no evidence suggesting this justification was a pretext for discrimination, noting that the family’s belief that the School used discipline as a cover for racial bias was unsupported by the record.
The Court also dismissed the retaliation claim, finding no causal link between the parents’ report of racial harassment and the withdrawal request. Twenty-two days elapsed between the report and the School’s action, and in that period, James’s conduct had significantly deteriorated. The Court concluded these intervening events broke any possible causal chain.
Having granted summary judgment for Haverford on the federal claims, the Court declined to exercise jurisdiction over the remaining state law claims, which could be refiled in state court.
Doe v. Haverford Sch. (E.D.Pa. Oct. 27, 2025) 2025 LX 447070.
Note: Schools should ensure that complaints of bias or racial harassment are promptly and thoroughly investigated, and when a student has behavioral challenges, the conduct and any interventions should be well-documented to support the School against potential legal claims.