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La Dell Grizzell, on Behalf of Her Minor Children v. San Elijo Elementary School, et al.

Paid petition · United States Court of Appeals for the Ninth Circuit, No. 21-55956 · judgment August 7, 2024


Certiorari denied · May 19, 2025
Pre-decision estimate: 12% cert probability (95% interval 8%–16%)

Before the decision, about 2.8× the 4.1% base rate. The model weighted this up for counsel with five or more prior petitions here, a Ninth Circuit decision below, and a circuit split argued in the petition.

Question presented

Since the Judiciary Act of 1789, all natural persons suing in federal court have held the right to conduct their cases “personally,” i.e., pro se. 28 U.S.C. §1654. Nothing in the statutory text limits that right to those who are at least 18 years old. And, under Federal Rule of Civil Procedure 17 and this Court’s precedents, parents have the authority to initiate litigation on behalf of their minor children and to exercise their children’s procedural rights during such litigation. Nevertheless, the Ninth Circuit has adopted a judge-made rule that parents may not conduct pro se litigation on behalf of their children. This puts indigent children in a Catch-22: Sue with counsel, or do not sue at all. It also conflicts with decisions from other courts of appeals that have refused to bar the courthouse doors to minors whose parents cannot afford adequate representation. The question presented is: Whether children must retain an attorney to pursue claims in federal court, or whether their parents may instead litigate pro se on their behalf.

Counsel of record

For petitioner
Erin E. Murphy
Clement & Murphy, PLLC

For respondent
Jennifer Savage Creighton
Winet Patrick Gayer Creighton & Hanes

Case

Conference history
Distributed for 2 conferences

Amicus briefs
3 cert-stage

Linked docket
24A589

Proceedings

  1. May 19 2025
    Petition DENIED.
  2. Apr 29 2025
    DISTRIBUTED for Conference of 5/15/2025.
  3. Apr 28 2025
    Rescheduled.
  4. Apr 16 2025
    DISTRIBUTED for Conference of 5/2/2025.
  5. Apr 16 2025
    Reply of petitioner La Dell Grizzell filed. (Distributed)
  6. Apr 02 2025
    Brief of respondents San Elijo Elementary School, et al. in opposition filed.
  7. Mar 03 2025
    Brief amici curiae of Advancing American Freedom, et al. filed.
  8. Mar 03 2025
    Brief amicus curiae of Religious Freedom Institute filed.
  9. Feb 28 2025
    Brief amici curiae of Tammy Fournier, et al. filed.
  10. Feb 18 2025
    Motion to extend the time to file a response is granted and the time is extended to and including April 2, 2025 (30-day extension).
  11. Feb 14 2025
    Motion to extend the time to file a response from March 3, 2025 to April 2, 2025, submitted to The Clerk.
  12. Jan 29 2025
    Petition for a writ of certiorari filed. (Response due March 3, 2025)
  13. Dec 17 2024
    Application (24A589) granted by Justice Kagan extending the time to file until January 29, 2025.
  14. Dec 13 2024
    Application (24A589) to extend the time to file a petition for a writ of certiorari from December 30, 2024 to January 29, 2025, submitted to Justice Kagan.