Labor & Employment Law Daily Wrap Up, INDIVIDUAL RIGHTS—D. Me.: Teacher who complained about allegedly ‘predatory’ student failed to state constitutional claims, (Sep 28, 2026)

By Jason Albright, J.D.

She reported that the student, who had an altercation with her son, “had a known history and reputation among students for sexually abusive and predatory behavior.”

A teacher who resigned after complaining about a student with whom her son was involved in an altercation, who she alleged was reputedly sexually abusive and predatory, failed to state First Amendment retaliation, procedural due process, equal protection, or ADA disability discrimination claims against the school district, a federal district court found. She did not plausibly allege that she made the report at issue as a private citizen; a public employee who voluntarily resigns cannot establish that the employer deprived her of a property interest within the meaning of the Due Process Clause; her “perceived status as an outsider” did not constitute a protected class or other impermissible consideration; and she failed to identify what disability she claimed other than describing general symptoms of severe anxiety and emotional distress (Leonforte v. Regional School Unit 19, No. 1:25-cv-00441-SDN (D. Me. Sept. 25, 2026)).

RSU 19. Regional School Unit 19 (RSU 19) and Nokomis Regional High School employed the plaintiff as a public school teacher at all times relevant to her complaint, according to the court. Although she was placed on a teacher improvement plan, which she successfully completed, sometime in 2024, her principal issued her a positive performance review in March 2025.

Son’s altercation. In April 2025, however, the teacher’s son engaged in an altercation with another student, and later that day, the principal sent a “written communication” to the teacher, “explicitly t[ying] the incident [with Ms. Leonforte’s son] to Plaintiff’s continued employment with the district.”

Report to superintendent. On April 14, the school district’s superintendent and other unnamed individuals called her into a meeting, during which she reported that the other student involved in the altercation “had a known history and reputation among students for sexually abusive and predatory behavior,” which “formed the basis for [Plaintiff’s] mandated report of sexual misconduct.”

Second administrative meeting. Two days later, she and other unnamed individuals convened a second administrative meeting, this time to discuss her employment with the district. The superintendent communicated that “he had already secured support from multiple school board members for the District’s intended outcome” and that “pursuing a school board hearing in an effort to preserve [Plaintiff’s] employment would be ‘dangerous for everyone.’”

Alleged forced resignation. She alleges that these statements “were used to exert pressure on Plaintiff to resign” and that her subsequent resignation was “not voluntary.” As a “direct result” of these events, she alleges, she suffered “severe anxiety and emotional distress that substantially limited major life activities” and experienced ongoing difficulty securing new employment.

Lawsuit. She sued the district, alleging First Amendment retaliation 42 U.S.C. § 1983, a procedural due process claim under Section 1983, and a Fourteenth Amendment equal protection claim. In addition, although not enumerated as a specific count, her first emended complaint’s prayer for relief asked the court to declare that the district’s acts and omissions violated her rights under the ADA. The district moved to dismiss.

First Amendment retaliation. Dismissing the former teacher’s First Amendment retaliation claim, the court found that she did not plausibly allege that she made the report at issue as a private citizen. Instead, her complaint asserted that she acted “as a mandated reporter” when she informed the district that one of the students in the altercation had engaged in sexual harassment. Maine, in turn, requires teachers to report suspected child abuse or neglect when acting in a professional capacity. See 22 M.R.S. § 4011-A(1)(A). By alleging that she made the report because her professional role required it, the court concluded, her “FAC places her speech entirely within the scope of her employment rather than outside it.”

Procedural due process. Her Fourteenth Amendment procedural due process claim was likewise inadequate. “A public employee who voluntarily resigns cannot establish that the defendant deprived her of a property interest within the meaning of the Due Process Clause,” the court observed, and that is what happened here. The district gave her two meetings before she resigned, and it “told her she could pursue a full evidentiary hearing before the school board to contest any termination.” Instead, she chose to resign rather than face the school board or pursue that administrative process.

Equal protection. Her Fourteenth Amendment equal protection claim was likewise inadequate. Here, she argued that the district subjected her to “adverse and disparate treatment” because of her “perceived status as an outsider within the local community,” notwithstanding her “compliance with Defendants’ directives” following the April 11, 2025, student altercation. Unpersuaded, the court observed that “perceived status as an outsider” is not a protected class or other impermissible consideration. Because she identified no membership in a protected class, her claim could proceed, if at all, only on a “class-of one basis,” which requires “an extremely high degree of similarity” between the plaintiff and her chosen comparators. Her first amended complaint, however, identified no similarly situated individuals, by name or by implication.

ADA claim. Turning to her free-floating ADA claim, the court found that dismissal was again appropriate. To successfully plead an ADA claim, a plaintiff must allege that she is “disabled within the meaning of the ADA.” Other than citing the ADA and describing general symptoms of severe anxiety and emotional distress, however, she failed to identify what disability she claimed, let alone allege facts fitting the statutory definition.

The case is No. 1:25-cv-00441-SDN.

Judge: Neumann, S.

Attorneys: Margo Leonforte, pro se. Melissa A. Hewey (Drummond Woodsum & MacMahon) for Regional School Unit 19, Mary Nadeau, and Michael Hammer.

Companies: Regional School Unit 19

Cases: IndividualRights PublicEmployees DisabilityDiscrimination Discrimination Discharge MaineNews