8th Circuit upholds dismissal of lawsuit against a Minnesota school district over a student's suicide…
Faith Elsharkawy v. Chisago Lakes Board of Education
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8th Circuit upholds dismissal of lawsuit against a Minnesota school district over a student's suicide, affirming summary judgment on Rehabilitation Act, ADA, and wrongful death claims.
Why it matters
The U.S. Court of Appeals for the Eighth Circuit affirmed the lower court's grant of summary judgment in favor of the Chisago Lakes School District and several school officials. Faith Elsharkawy had sued the district after her son J.L.E., a high school freshman with disabilities, died by suicide, alleging violations of the Rehabilitation Act, the ADA, and Minnesota's wrongful death statute. The appeals court agreed with the district court that the evidence did not support allowing the case to proceed to trial.
Who it affects
This ruling directly affects families who may seek to hold public school districts legally responsible under federal disability laws or state wrongful death statutes for a student's suicide. It also affects school districts and individual school employees in the Eighth Circuit regarding their potential liability in similar circumstances.
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Decision issued Jul 21, 2026
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- Decision issued Jul 21, 2026Published opinion
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Jul 21, 2026 · Published opinion
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DEEPER READ
This case arose after J.L.E., a student with multiple health and learning disabilities in the Chisago Lakes School District in Minnesota, died by suicide. His mother, Faith Elsharkawy, sued the school district and several school employees, claiming they violated the Rehabilitation Act of 1973, the Americans with Disabilities Act, and Minnesota's wrongful death law. She argued the district failed to properly serve her son and that those failures contributed to his death. The district court granted summary judgment to the defendants, meaning it found that even viewing the evidence in the light most favorable to Elsharkawy, no reasonable jury could rule in her favor. The district court also noted that Elsharkawy's legal filings contained inaccurate citations and exaggerated claims, which complicated the record. The Eighth Circuit reviewed that decision and affirmed it across all three claims. The appeals court noted that courts are not obligated to search the record on their own for evidence supporting a party's claims, particularly when that party's briefing is unreliable. The court's holding means the lawsuit ends in favor of the school district and the named officials. The source text does not detail the specific legal reasoning the court applied to each individual claim, nor does it describe any dissenting opinion among the three judges. The opinion was authored by Judge L.R. Smith, with Judges Loken and Stras also on the panel.
CITATION AND RECORD
Record source: CourtListener
United States Court of Appeals For the Eighth Circuit ___________________________ No. 24-3177 ___________________________ Faith Elsharkawy, as herself, in her individual capacity, and as Trustee for the Next-of-Kin of Jacob Monroe Letourneau-Elsharkawy, decedent Plaintiff - Appellant v. Chisago Lakes School District Board of Education, a municipality; jointly and severally; Independent School District No. 2144, Chisago Lakes Area Schools, a municipality; jointly and severally, doing business as Chisago Lakes Schools; Dave Ertl, Principal, Chisago Lakes High School, Independent School District No. 2144, Chisago Lakes Area Schools, in his individual capacity, only; jointly and severally; Jason Thompson, Associate Principal, Chisago Lakes High School, Independent School District No. 2144, Chisago Lakes Area Schools, in his individual capacity, only; jointly and severally; Carrie Hoffman, Associate Principal, Chisago Lakes High School, Independent School District No. 2144, Chisago Lakes Area Schools, in her individual capacity, only; jointly and severally; Jerilyn Mattson, Special Services Case Manager, Chisago Lakes High School, Independent School District No. 2144, Chisago Lakes Area Schools, in her individual capacity, only; jointly and severally; Angela Christenson, School Psychologist, Chisago Lakes High School, Independent School District No. 2144, Chisago Lakes Area Schools, in her individual capacity, only; jointly and severally; Shira Ben-Heim, Special Education Teacher, Chisago Lakes High School, Independent School District No. 2144, Chisago Lakes Area Schools, in her individual capacity, only; jointly and severally; Leah Taylor, Special Education Teacher, Chisago Lakes High School, Independent School District No. 2144, Chisago Lakes Area Schools, in her individual capacity, only; jointly and severally; Carter Vogt, Guidance Counselor, Chisago Lakes High School, Independent School District No. 2144, Chisago Lakes Area Schools, in his individual capacity, only; jointly and severally; Laura Gustafson, School District Nurse, Chisago Lakes High School, Independent School District No. 2144, Chisago Lakes Area Schools, in her individual capacity, only; jointly and severally; Jane and John Does, in their individual capacities, only; jointly and severally Defendants - Appellees ____________ Appeal from United States District Court for the District of Minnesota ____________ Submitted: February 10, 2026 Filed: July 21, 2026 ____________ Before LOKEN, L.R. SMITH, and STRAS, Circuit Judges. ____________ L.R. SMITH, Circuit Judge. J.L.E., a freshman in the Chisago Lakes School District, tragically took his own life. J.L.E.’s mother, Faith Elsharkawy, 1 sued Appellees 2 alleging, among other claims, violations of Title V of the Rehabilitation Act of 1973, 3 the Americans with Disabilities Act of 1990 (ADA), 4 and Minnesota’s wrongful death statute. 5 On 1 Elsharkawy sued in her individual capacity and as trustee for the next-of-kin of J.L.E. 2 Appellees are the Chisago Lakes School District Board of Education; Independent School District No. 2144, Chisago Lakes Area Schools, d/b/a Chisago Lakes Schools (collectively, “the District”); Jason Thompson; and Carrie Hoffman. Several individually named defendants were voluntarily dismissed at the district court level. 3 29 U.S.C. § 791, et seq. 4 42 U.S.C. § 12101, et seq. 5 Minn. Stat. § 573.02. -2- appeal, Elsharkawy argues that the district court 6 erred when it granted Appellees’ motion for summary judgment on these three claims. We affirm. I. Background 7 In 2015, J.L.E. transferred to a middle school in the District as a seventh grader. Because J.L.E. suffered from several longstanding health and learning disabilities, the District placed him on an individualized education plan (IEP). The District modeled J.L.E.’s IEP after those he had at previous school districts. The District also determined that J.L.E. was eligible for special educational services. Elsharkawy agreed with the District’s academic plan. J.L.E. frequently missed school, often due to his health conditions. As a result of J.L.E.’s absences, in January 2016, the District recommended that it provide him homebound educational services. Elsharkawy agreed with the District’s recommendation. During homebound instruction, a District-hired tutor visited J.L.E. for five hours each week to help him with his homework and answer any questions he had. J.L.E.’s doctor and the District viewed homebound instruction as temporary. It was understood that J.L.E. should return to in-person instruction unless health concerns prevented his school attendance. Accordingly, after about a month, J.L.E. returned to in-person education. J.L.E.’s frequent absenteeism resumed. This led to truancy concerns. During her deposition, Elsharkawy ascribed J.L.E.’s absences to his medical conditions. She testified that the District sometimes excused J.L.E.’s absences when he brought a 6 The Honorable David S. Doty, United States District Judge for the District of Minnesota, now deceased. 7 The district court’s summary judgment order noted that Elsharkawy’s summary judgment brief contained “inaccurate citations” and “exaggerated claims.” R. Doc. 197, at 5 n.5. Elsharkawy’s appellate brief contains much of the same. “Courts have neither the duty nor the time to investigate the record in search of an unidentified genuine issue of material fact to support a claim or a defense.” Libel v. Adventure Lands of Am., Inc., 482 F.3d 1028, 1032 (8th Cir. 2007). -3- doctor’s note but at other times the District would lose J.L.E.’s doctor’s notes, resulting in unexcused absences. Elsharkawy acknowledged during her deposition that “sometimes when [J.L.E.] would seem stressed out with school . . . [she] would let him have a mental health day off.” Appellees’ App. 1604. Before J.L.E. started eighth grade, the IEP team, including Elsharkawy, added more accommodations to his plan. The District also recommended that J.L.E. receive in-school counseling provided by Therapeutic Services Agency (TSA), a third-party counseling agency. Elsharkawy agreed with the District’s recommendation. Additionally, J.L.E.’s IEP mandated that he could not enroll in art class until he completed his work on time for two weeks for his other classes. During that school year, J.L.E.’s absenteeism, tardiness, and incomplete school assignments persisted. Elsharkawy believed that the District was responsible and accused it of not following certain aspects of J.L.E.’s IEP. For example, she believed that the District was not permitting J.L.E. to wear either his hat or hood, not allowing him to take naps as needed, not breaking down his assignments to a more understandable level, nor providing him with unlimited access to the bathroom and nurse. The District responded by reminding individual teachers of accommodations that J.L.E.’s plan required be made for him due to his disabilities. J.L.E. also experienced behavioral and peer-related incidents while in school. Examples of these incidents included sleeping in class, inc
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