No Qualified Immunity for School Administrators Where the Law Is Clearly Established

In its opinion of February 3, 2026, the court denied qualified immunity for the individual defendants on the free speech (viewpoint discrimination) and expressive association claims because the law was sufficiently clear but granted qualified immunity on the free exercise, RFRA, and Equal Access Act claims because the law was not sufficiently clear with respect to those claims. Additionally, the District of Columbia Public Schools (DCPS) claimed its revisions to its “Student Organizations and Clubs Guidance” that exempted religious groups from its anti-discrimination policy mooted the case. The court, however, disagreed, ruling that the revised guidance does not moot FCA’s claims because the revised guidance does not explicitly prohibit DCPS from enforcing its anti-discrimination policy or the D.C. Human Rights Act against a religious student organization that requires its student leaders agree with the organization’s beliefs.

This case, Fellowship of Christian Athlete v. District of Columbia, involves a fact pattern familiar to CLS: public educators enforcing their nondiscrimination policy in a way that clearly discriminates against student religious groups. Here, FCA sued the DCPS and two DC public school officials after they derecognized the FCA club at a high school in D.C., claiming FCA violated the school district’s anti-discrimination policy by requiring its student leaders adhere to standards limiting sexual conduct to marriage between a man and woman. Defendants asked the court to dismiss the claims against the individual defendants alleging they had qualified immunity. The Center had filed an amicus brief in support of FCA.

 

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