Kroupa v. Nielsen, et al.

After 15-year-old B.K. was barred from showing livestock at 4-H exhibitions, B.K.'s father filed suit under 42 U.S.C. 1983 against the unincorporated 4-H Association and two 4-H officials. The district court granted preliminary injunctive relief from the claimed denial of B.K.'s constitutional right to procedural due process. The court inferred that 4-H membership and participation was a "right or status" open to all South Dakota children interested in a career in agriculture, subject to reasonable, non-discriminatory terms; the record clearly demonstrated that the ban deprived B.K. of the opportunity to participate in a public program that was important to her education and career development and from which she obtained significant personal income; and, therefore, the district court did not abuse its discretion in concluding that B.K. had a fair chance of proving that defendants published a defamatory ruling that deprived her of a right or status conferred by state law and that she was entitled to the constitutional protection of the Due Process Clause. Further, B.K. was not afforded minimal procedural due process protection; there was a sufficient showing of the threat of irreparable injury; and the balance of the equities and the public interest supported the issuance of the injunction. Accordingly, the court affirmed the judgment of the district court. View "Kroupa v. Nielsen, et al." on Justia Law