United States District Court Northern District of New York
UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF NEW YORK ) I.S., a minor by and through her mother and ) next friend, ANAIS DISLA; J.B., a minor by ) and through her parents and next friends, ) IBELYH DISLA and JOSE BRISTOL; I.M., ) a minor by and through her mother and next ) friend, ZULAYKA MCKINSTRY; A.S., a ) minor by and through her mother and next ) ) friend, CHANDERLIA SILVA, ) Plaintiffs, ) ) v. ) _____ Civ. __________ (_____) ) BINGHAMTON CITY SCHOOL ) Jury Trial Demanded ) DISTRICT; BINGHAMTON BOARD OF ) EDUCATION; TIM SIMONDS, in his ) individual and official capacity; MICHELLE ) RALEIGH, in her individual and official ) capacity; MARY ELLEN EGGLESTON, in ) her individual and official capacity, ) ) Defendants. ) ) COMPLAINT PRELIMINARY STATEMENT Plaintiffs I.S., a minor by and through her mother and next friend, Anais Disla; J.B., a minor by and through her parents and next friends, Ibelyh Disla and Jose Bristol; I.M., a minor by and through her mother and next friend, Zulayka Mckinstry; and A.S., a minor by and through her mother and next friend, Chanderlia Silva (collectively “Plaintiffs”), bring this action against the Binghamton City School District, the Binghamton Board of Education, Tim Simonds, Michelle Raleigh, and Mary Ellen Eggleston (collectively “Defendants”), for the discriminatory, dehumanizing, and unlawful strip searches and other unreasonable searches of their daughters— four Black and Latina girls who were twelve years old at the time of the searches—in violation of their federal statutory and constitutional rights under the Fourth and Fourteenth Amendments to the U.S. Constitution, Title VI of the Civil Rights Act of 1964, the Individuals with Disabilities Education Act (“IDEA”), Section 504 of the Rehabilitation Act, and all relevant implementing regulations.
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