Jane Doe v. Pine Richland School District

── Jane Doe v. Pine Richland School District ── Court: Court of Appeals for the Third Circuit Date: April 23, 2026 Category: General U.S. COURT OF APPEALS FOR THE THIRD CIRCUIT No. 24-3348 JANE DOE, Appellant v. PINE RICHLAND SCHOOL DISTRICT _____________________________ Appeal from United States District Court for the Western District of Pennsylvania Judge William S. Stickman IV No. 2:24-cv-00051 Before: Hardiman, Krause, and Freeman, Circuit Judges Argued Sep. 9, 2025; Decided: April 23, 2026 _____________________________ NONPRECEDENTIAL OPINION * FREEMAN, Circuit Judge. When Jane Doe’s child was a student in the Pine-Richland School District, Doe sued the District to challenge its nondiscrimination policy concerning students’ gender identity. The District Court dismissed the complaint in full for lack of standing. Because Doe was an object of the challenged policy while her child was enrolled in the District, she has standing to pursue damages. However, her child is no longer enrolled in the District, and Doe has not alleged that she would re-enroll her child if the policy is no longer in effect. Accordingly, she lacks Article III standing to pursue prospective relief. * This disposition is not an opinion of the full Court and, under I.O.P. 5.7, is not binding precedent.  We will reverse the District Court’s order insofar as it relates to Doe’s pursuit of damages. Doe’s claims for prospective relief were properly dismissed, but a dismissal for lack of standing should be without prejudice, so we will modify that part of the District Court’s order and affirm it as modified. I1 In 2017, the District passed Administrative Regulation 103(B) (hereafter, the “Policy”) “declar[ing] it the policy of the [D]istrict to provide an equal opportunity for all students” regardless of personal characteristics, including “gender or gender identity.” App. 137. The Policy states that the unauthorized disclosure of a student’s “transgender status, legal name, or birth-assigned sex” violates the student’s privacy rights and may harm the student’s health and safety. App. 138. It also provides that, if a student discloses their transgender status to District staff, “District personnel should not disclose a student’s transgender status to others, including the student’s parents/guardians . . . unless: (1) legally required to do so, or (2) the student has authorized such disclosure.” Id. The Policy requires each school to have a Student Support Team as a resource for transgender students. A Student Support Team is made up of “appropriate staff, such as the building principal, guidance counselor, nurse, school psychologist, and teacher(s).” Id. “When a student transitions during the school year” the Policy directs the Student Support Team to hold a meeting with the student and “discuss a timeline for the transition 1 We recount the facts as alleged in the complaint and accept them as true. See Hartig Drug Co. v. Senju Pharm. Co., 836 F.3d 261, 268 (3d Cir. 2016). 2 in order to create the conditions supporting a safe and accepting environment at the school.” Id. 2 The Student Support Team includes parents or guardians only “if they are involved in the process. Id. Jane Doe’s child was a student in a District school for the 2023–2024 school year. During that school year, Doe became concerned that her child might identify as transgender at school and the District, under the Policy, “would immediately begin affirming her before Doe knows and can take steps to help her child obtain appropriate medica