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34,
See Troxel v. Granville, 530 U.S. 57 (2000); Meyer v. Nebraska, 262 U.S. 390
(1923).
By failing to provide any safe accommodations or lawful alternatives for
school-related access, Respondents unlawfully burdened Petitioner’s ability to
fulfill essential parental responsibilities. This interference with core family
rights constitutes a violation of substantive due process under the Fourteenth
Amendment.
VI. RELIEF REQUESTED
WHEREFORE, Petitioner respectfully requests that this Court:
35.
36.
37.
38.
39.
Declare that the April 4, 2025, trespass citation was unlawful and issued
without due process;
Declare that the April 14, 2025, “temporary ban” is invalid, retroactive, and
unenforceable;
Declare that the failure to provide any accommodations or lawful alternatives
for school access violates Petitioner’s constitutional and statutory rights;
Issue temporary injunctive relief allowing Petitioner to access designated
school property solely for the purposes of student pickup and drop-off,
pending the outcome of this case;
Issue temporary injunctive relief prohibiting Respondents from initiating or
enforcing any further disciplinary action, exclusion, or permanent ban arising
from the April 4, 2025 incident or related protected activities, until this matter
is resolved. Such actions would only compound the harm, prejudice this
litigation, and further violate Petitioner’s due process and parental rights.
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