A former student has filed a lawsuit against The Hawbridge School in Saxapahaw – one of the four public charter schools in Alamance County – alleging that an English teacher and several school officials discriminated against him, “unilaterally reduced” his grade point average, and took retaliatory actions that resulted in all 16 of his college transcripts arriving late and him being denied admission by all 16 universities, including Brown University.
The lawsuit – which lays out a laundry list of nearly 100 alleged acts of malfeasance – has been filed in Alamance County superior court by Todd Madison, apparently graduated from The Hawbridge School in 2020.
In addition to The Hawbridge School, the suit lists several individual defendants, including: the charter school’s executive director, Mya Ciccotti Geiss; the now-former chairman of the school’s board of directors, Lori M. Edmonds; and three employees, Cameron L. Ratliff, Donna R. Rascoe, and Emily C. Martin.
In his suit, Madison contends that the defendants failed to use due care in handling and accommodating students with disabilities. Specifically, Madison had suffered lifelong post-traumatic seizures resulting from a “closed-head traumatic brain injury” sustained during childhood that subsequently affected his short-term memory and got worse over the course of his four years at The Hawbridge School, according to his suit.
By the time he turned 14, Madison had been hospitalized a half-dozen times. He was diagnosed in December 2010 with a generalized seizure disorder following an EEG administered at a pediatric hospital in Madera, California.
During the summer between eighth and ninth grades, Madison was admitted to the Pediatric ICU at UNC Children’s Hospital, in August 2015, and spent four days in the pediatric ICU as his cardiac team struggled to stabilize his heart, he recalls in his suit. He was subsequently hospitalized from August through September 2015 and for another eight days in October 2015, the complaint states.
The following year, Madison was hospitalized for a total of six months at Brenner’s Children’s Hospital at Wake Forest Baptist Health, from early April until May 2016, and at another hospital in Asheville from early May 2016 to mid-August 2016. Much of that period coincided with his freshman year at The Hawbridge School, based on the suit that Madison has filed in superior court.
‘Son may not make it to adulthood’
As Madison suffered repeat seizures and extreme weight loss that left him struggling with basic daily activities, his mother was advised by Hawbridge officials to “stop focusing on college and begin accepting that your son may not make it to adulthood,” the complaint states.
According to the account he gives in his suit, prior to his admission to the pediatric ICU (PICU) in August 2015, Madison had performed at an academically-advanced level; had been reading since age 5; and had been placed in “gifted and talented programs” in schools in several states.
All that apparently changed when Madison enrolled at Hawbridge for the 2015-16 and began struggling academically for the first time, which he initially attributed to extended inpatient care and his short-term memory “no longer functioning as it had the prior eight years.”
Madison entered ninth grade at Hawbridge in August 2016, when he was 14, according to his suit. Because he had been discharged from the hospital four days earlier, he was placed in “his regular grade” in order to make up material he had missed at another school while hospitalized the previous school year.
“He routinely played one to three sports a year in elementary and middle school, was consistently named to the principal’s honor roll, received the highest award provided by the school district in sixth grade for…academics, leadership, character, and service, and was the student body president in eighth grade,” Madison recounts in his suit.
For his freshman year of high school, Madison was placed in Ratliff’s ninth grade English class and requested certain accommodations (i.e., an Individual Education Plan, or IEP) due to his ongoing medical treatment and short-term memory loss.
“Defendant Ratliff was requested to provide accommodations for [Madison] which took into account his recent significant life events, including nearly losing his life, extended inpatient care, ongoing treatment, current deficiencies…and medications, and to abide by the written restrictions of [his] physicians,” the lawsuit alleges.
Madison claims that Ratliff ultimately provided none of the accommodations to which he was entitled, as a student with disabilities, under federal law.
Madison claims Ratliff later asked to meet with his parents, at which point she “denigrated, criticized and insulted” the boy and even threatened him with “discipline for days in which he was excused from class by his physician due to medical appointments and treatment,” the complaint states.
Suit alleges that parents didn’t receive son’s report cards for three years of high school
Madison’s parents turned in his assignments for him, while he was either hospitalized or undergoing medical treatment, according to his suit. But he claims that Ratliff failed to properly credit him for the assignments and eventually “stopped sending progress reports, report cards, updates or communications of any kind,” the complaint states.
Madison was also placed in Ratliff’s English class for his junior year, and she allegedly “retaliatorily assigned [him] a grade of 77 for the school year, a grade [he] had never made in a class before his disability required educational accommodations nor since,” he asserts in his suit.
According to his suit, neither his teachers nor the administrators at Hawbridge had provided his parents with access to Power School (an online platform used to distribute progress reports, general updates, class schedules, and other important information) until he reached his senior year of his school.
His parents later discovered that Ratliff “had never updated [Todd Madison’s] excused medical visits, never updated his completed assignments, nor altered the assignment list…to provide for his disability, medical restrictions, need for accommodations, nor completed work provided Defendant Ratliff as requested and confirmed in writing,” the suit asserts.
Madison claims this alleged retaliatory behavior by Ratliff began not long after a public dispute over the prices of snacks and “school lunch food items” charged in a “store and restaurant” housed in the same building as the charter school – which the plaintiff claims is leased to and operated by Ratliff.
“Following the incident,” that student, “who was at the top of his class,” began receiving zero grades for homework that Ratliff claimed had not been turned in; accused the student of shoplifting; “had him followed” on school property; revoked his outdoor lunch privileges; banned him from her store/restaurant, Madison alleges.
The suit doesn’t explicitly state whether Madison had been involved in the earlier public dispute over prices in her restaurant/store.
However, the plaintiff contends,“ Ratliff used the same retaliatory tactic on [Madison] when he reached his senior year and successfully overrode [his] disability accommodations and medical restrictions that called for frequent change of environment throughout the day in order to increase visual and auditory reinforcement to assist with [his] short-term memory processing disorder.”
Other Hawbridge officials later failed to adhere to the charter’s school’s grievance policy and even went so far as to remove it from the student handbook at one point, according to the suit.
Late transcripts blamed for his being turned down by 16 universities
Madison contends that the executive director, Geiss, failed to acknowledge or respond to numerous written requests to meet and refused to intervene in Ratliff’s alleged “illicit conduct,” and that ongoing retaliatory actions at The Hawbridge School ultimately resulted in his transcripts arriving late to 16 universities he’d applied to and in his subsequent rejection by all 16.
“[Madison] had a compelling application to many of those 16 schools, including Brown as he had attended and excelled at Brown University Pre-College programs earning excellent scores in his mathematics and probability course,” the complaint states. “Had defendants not denied [Madison] access to his transcript and responded timely, he would have been provided a full ride upon admission to five of the 16 schools as they provided financial aid without student loans.”
Madison contends that his medical conditions, which his suit describes as debilitating, got worse as a result of the defendants’ alleged conduct.
“The retaliation and discrimination Defendant Geiss presided over increased to such an extent that [Madison] began writing to his parents and physicians that he did not feel safe at school,” he claims in his suit. “The atmosphere created…exacerbated [Madison’s] seizures, acute anxiety, inability to process stressful situations and short-term memory processing disorder to a point where [he] was unable to attend school, frequently broke down and began having difficulty with activities of daily living.”
The plaintiff is seeking more than $25,000 in damages under each of multiple claims, including alleged negligence, which the suit asserts was the “direct and proximate cause of [Madison’s] injuries, harm, and damages, including reasonable medical treatment and possible future medical treatment, the possibility of permanent impairment, learning loss, supplemental education professionals, activities and plans, loss of opportunity, and the pain and suffering he has endured and may endure in the future.” Madison is also seeking an award for punitive damages, court costs, and attorney’s fees.
Madison allegedly denied hearing before board of directors on ‘no less than 18 issues’
The suit accuses Rascoe of “intervening and blocking” a hearing before the charter school’s board of directors on “no less than 18 issues.”
Edmonds allegedly “admitted verbally and in writing” that Madison and his parents were entitled to a hearing (over the requested accommodations and related issues) but “illicitly gave the entire contents” of an appeal file to Rascoe, whom Madison claims denied him equal access under the law as provided for all North Carolina charter school students. Edmonds is also accused of failing to send Madison’s college transcripts prior to the application deadlines.
The suit accuses Martin of refusing to “calculate [Madison’s] second semester grades, denying him the option provided all North Carolina students [during] the pandemic to elect pass/fail or actual grades.” Madison claims that Martin’s actions “unilaterally reduced” his GPA by two-tenths of a percentage point.
Madison contends that, as a result of the defendants’ “illicit and discriminatory conduct” his family spent thousands on educational services, “was hampered in his education, suffered learning loss, suffered future earnings [loss], accumulated unnecessary student loans, and was denied educational opportunities at elite universities.”
Several of the defendants, including Geiss, have since filed motions requesting an extension of the customary 30-day deadline in which to file a response.
The Hawbridge School is located at 1735 Saxapahaw-Bethlehem Church Road in Saxapahaw.
The court file lists Madison’s address in the care of his attorney, Caryn Madison, of 1183 University Drive, Suite 105-121 in Burlington; the court file gives no indication of whether the plaintiff and attorney are related.
The court file lists the following addresses for the individual defendants: Lori Edmonds, 2401 Brook Run in Birmingham, Alabama; Emily Martin, 1024 River Road in Pittsboro; Donna Rascoe, 7013 Tanbark Way in Raleigh; Cameron Ratliff, 3054 Ocher Street in Graham; and the court file lists the address for Geiss as in care of the charter school.