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1 INTRODUCTION
2 1. The Community Care Facilities Act requires that private boarding
3 schools allow students full autonomy on matters of religion and sexual identity. No
4 exception is provided for religious educational institutions. A religious ministry
5 that operates a Christian boarding school brings a facial and as applied
6 constitutional challenge to the Community Care Facilities Act and its regulations.
7 2. The school has a statement of faith, employs only Christians, and
8 intertwines a Christian perspective in all subjects taught. Further, the school deals
9 with negative behaviors through spiritual guidance, schedules daily religious
10 devotions, and provides opportunities for: (1) the study of Christian courses, (2) a
11 weekly Wednesday evening Bible study, and (3) a Christian church service on
12 Sunday. It does not provide equal opportunities for other religions or secular
13 worldviews. As part of its structured environment, the school houses the boys and
14 girls separately and has sex-segregated learning environments. The theological
15 position of the school is conservative. Specifically as it relates to human sexuality,
16 it holds a hetero-normative view of relationships. Sexual relationships are confined
17 to a man and a woman who are married to each other. In order to help pupils stay
18 focused on their studies, it discourages, and indeed prohibits, physical and romantic
19 entanglements between or among the sexes. This biblically-based manner of
20 running the school places the institution in conflict with the Community Care
21 Facilities Act. Violation of the Community Care Facilities Act is a criminal
22 offense.
23 3. A class representative of the parents and guardians of the students
24 challenges the Community Care Facilities Act because of the unconstitutional
25 interference with the free exercise of religion and parental rights. In sum, the
26 parents choose to enroll their children in this private Christian school because of
27 the academic course of study, the structured environment, to encourage their
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Verified Amended Complaint
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1 children in elements of proper social behavior necessary for good citizenship, and
2 the desire to inculcate in their children the moral standards and religious beliefs
3 provided by this religious institution.
4 JURISDICTION AND VENUE
5 4. This Court has jurisdiction over this action under 28 U.S.C. §§ 1331and
6 1343(3)-(4) which confer original jurisdiction on federal district courts in suits to
7 reduce the deprivation of rights, privileges and immunities secured by the United
8 States Constitution and federal law.
9 5. The Court has jurisdiction over the request for declaratory relief
10 pursuant to 28 U.S.C. §§ 2201 and 2202 and Rule 57 of the Federal Rules of Civil
11 Procedure, and includes a request for a speedy decision and an advance on this
12 Court’s calendar under FRCP 57.
13 6. Venue is proper under 28 U.S.C. § 1391(b) because the acts giving rise
14 to the claims alleged herein has occurred, and continues to occur, in the Eastern
15 District of California.
16 PARTIES
17 Plaintiffs
18 7. Plaintiff, Teen Recuse, is a religious California corporation established
19 pursuant to section 501(c)(3) of the Internal Revenue Code. Part of its ministry is
20 the establishment of a Christian boarding school as explained in detail below.
21 8. Plaintiff, Carlton Williams, individually and on behalf of all other
22 persons similarly situated, by Plaintiff’s undersigned attorneys, brings this
23 complaint as a class action. He is the custodial parent of a child who boards at, and
24 is enrolled in, the school.
25 Defendants
26 9. Defendant, Xavier Becerra is now, and at all times mentioned herein,
27 the Attorney General of California. The Attorney General, by and through his
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Verified Amended Complaint
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1 agents, has enforced and continues to enforce the law subject to constitutional
2 challenge herein, the Community Care Facilities Act. The acts of the Attorney
3 General and his agents as described herein were done under color of state law.
4 General Becerra is sued in his official capacity.
5 10. Defendant, William Lightbourne is now, and at all times mentioned
6 herein, the Director of the State Department of Social Services. The Director, by
7 and through his agents, has enforced and continues to enforce the law subject to
8 constitutional challenge herein, the Community Care Facilities Act. Under the
9 Community Care Facilities Act the Director heads the State Department of Social
10 Services. The Department sets standards and makes determinations regarding the
11 applicability of the Community Care Facilities Act. The acts of the Director and
12 his agents as described herein were done under color of state law. Director
13 Lightbourne is sued in his official capacity.
14 11. Defendant, Butte County Department of Children’s Services Division,
15 through its employees, has acted as an agent for the co-Defendants, General
16 Becerra and Director Lightbourne, to enforce the Community Care Facilities Act.
17 12. Plaintiffs are ignorant of the true names and capacities, whether
18 governmental, individual, corporate, associate, or otherwise, of DOES 1 through
19 50, inclusive. Plaintiffs are informed and believe and thereon allege that each of
20 the fictitiously named Defendants is in some way responsible for or participated in,
21 or contributed to, the matters and things complained of herein, and are legally
22 responsible in some manner therefor. Plaintiffs will seek leave to amend this
23 Complaint when the true names, capacities, participation, and responsibilities have
24 been ascertained.
25
26
27
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Verified Amended Complaint
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1 STATEMENT OF FACTS
2 History of the River View Christian Academy
3 23. River View Christian Academy is a Christian school that is one of the
4 ministries of Teen Rescue. Started in 1993, the school ministry of Teen Rescue
5 was operated in southern California as Julian Christian High School dba Julian
6 Youth Academy until a wild fire (called the Cedar Fire) in southern California
7 destroyed the campus in 2003. It moved to a 250 acre campus in northern
8 California and in 2012 took its current name.
9 24. River View Christian Academy is financed through a combination of
10 tuition and donations from private nongovernmental sources. All income is
11 through the private sector. To be clear, River View Christian Academy does not
12 receive any money from federal, state, county or municipal sources.
13 Courses of Instruction & Other Activities
14 25. The courses of instruction at the River View Christian Academy
15 include Language Arts (English I-IV, American Literature, English Literature,
16 English 800); Science (Integrated Physics and Chemistry, General Science III,
17 Biology, Earth Science, Chemistry, Physics, Astronomy); Social Science (Civics,
18 World History, World Geography, American History, Government and Economics,
19 20th Century American History); Mathematics (Pre-Algebra, Algebra I-II,
20 Geometry, Pre-Calculus, Trigonometry, Consumer Math); Foreign Language
21 (Spanish I-III, French I-II); Electives (Personal Financial Literacy, College Planner,
22 High School Health, Careers in Nursing, Careers in Manufacturing, Digital Art,
23 Culinary, Dog Breeding, Music Appreciation, New Testament Survey, Old
24 Testament Survey).
25 26. Plans are being made for the installation of greenhouses for the
26 inclusion of agricultural studies.
27 27. The school has athletic teams. Moreover, some students performed
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Verified Amended Complaint
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1 2. There is only one God, eternally existing in three persons: God the
Father, God the Son, and God the Holy Spirit (Matt 28:19; John 15:26;
2 I John 5:7).
3 3. We believe in the deity of our Lord Jesus Christ, in His virgin birth, His
sinless life, His miracles, His vicarious and atoning death, His bodily
4 resurrection, His ascension to the right hand of the Father, and in His
5 personal future return to this earth (Matt 1:18-23; 16:16; 28:6-7; Heb
4:15; Luke 1:26-27; 8:22-25; John 2:11; 14:13; Isaiah 53:7; I John 2:1-
6 2; I Cor. 15:3; Eph. 4:8-10; Rom. 8:3; Acts 1:1; Rev. 1:7).
7 4. A person is cleansed from sin only through genuine repentance and
faith in the precious blood of Jesus Christ (Rom. 10:9-10; Acts 3:19).
8 5. The Holy Spirit dwells within the Christian, giving him/her sanctifying
9 power to live a life glorifying to God (Gal. 5:16; Rom. 8:1-17).
6. Water baptism symbolizes to the world our identification with Christ
10 (Rom. 6:3-4).
11
12 35. River View Christian Academy is Christian but not affiliated with a
15 36. All River View Christian Academy staff are required to be Christians.
17 37. Evangelical church services are provided on Sundays. Bible studies are
20 38. Daily religious devotions appear from 8 to 8:30 each morning on the
23 39. River View Christian Academy does not employ mental health
27 students is not dealt with through therapy administered by mental health workers.
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Verified Amended Complaint
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1 41. River View Christian Academy is not a boot camp or wilderness camp.
2 Staff do not employ corporal punishment to change behaviors. They do not seek to
3 modify behaviors through withholding food or denying medical treatment to the
4 sick or injured. They do not place students in solitary confinement.
5 42. Instead, River View Christian Academy provides a combination of a
6 structured environment and spiritual guidance.
7 43. Concerning a structured environment, the school has schedule and rules
8 of conduct for students that are similar to any public or private school. Disciplinary
9 actions for violation of rules include removal of privileges, writing sentences,
10 separation from other students when appropriate, (e.g., in cases such as threats of
11 violence or fighting), detention, suspension, and expulsion. School discipline falls
12 within the ordinary scope of what is administered in public and private secondary
13 schools throughout California.
14 44. As to the spiritual guidance, such is provided through opportunities to
15 study the Bible, attending a church service at River View Christian Academy,
16 prayer, pastoral counseling, or spiritual discussions with older mature Christians.
17 45. Plaintiffs are informed and believe and thereon allege that the Attorney
18 General and Director, through their agents, view the structured environment and
19 spiritual guidance of River View Christian Academy as a “behavioral based
20 service” as per Cal. Health & Safety Code § 1502(a)(19). Behavioral based service
21 is not defined in the Health and Safety Code, but Plaintiffs are informed and
22 believe and thereon allege that the term means behavior modification.
23 Students
24 46. River View Christian Academy’s website has a tab which reads: “Does
25 Your Teen Need Help?” The
26 text under the tab states:
27
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Verified Amended Complaint
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1 Academy. The Community Care Facilities Act gives students the right “[t]o be free
2 from acts that seek to change his or her sexual orientation, including efforts to
3 change his or her gender expressions, or to eliminate or reduce sexual or romantic
4 attractions or feelings toward individuals of the same sex.” Cal. Health & Safety
5 Code § 1502.2(d)(1)(P). River View Christian Academy holds the religious
6 convictions that sexual activities are proper only between a man and a woman who
7 are married to each other. Moreover, River View Christian Academy does not
8 allow any sexual or romantic encounters or entanglements between students of any
9 kind. That stands as a universal rule and applies between boys and girls, boys and
10 boys, and girls and girls. In addition to the religious basis for the rule, River View
11 Christian Academy has this rule in order to prevent distractions to academic
12 endeavors by the students.
13 67. In view of the rights of students to sexual autonomy related to sexual
14 orientation under the Community Care Facilities Act, a private alternative boarding
15 school must “submit a staff training plan to the department [of Social Services] as
16 part of its plan of operation” to include the rights of youth in the area of “[c]ultural
17 competency and sensitivity in issues relating to the lesbian, gay, bisexual, and
18 transgender communities.” Cal. Health & Safety Code § 1502.2(c)(4). In that
19 River View Christian Academy holds a theologically conservative position on
20 sexual ethics described above, Teen Rescue is informed and believes and thereon
21 alleges that it is impossible for it to propose a plan consistent with its religious
22 beliefs and practices that the State of California will approve.
23 68. Because of this, neither the Attorney General nor the Director can bring
24 River View Christian Academy under the Community Care Facilities Act as written
25 and remain consistent with the religion clause of the First Amendment.
26 69. The enforcement of the Community Care Facilities Act by the
27 Defendants against the school ministry of Teen Rescue is done under color of law.
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Verified Amended Complaint
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1 the website which states that the school program is designed for “struggling
2 teenagers in need of full-time supervision and redirection” indicates that the “web
3 site does not clearly meet the intention of the regulations.” The findings were
4 noted as “inconclusive.”
5 72. Since the Community Care Facilities Act was amended in 2016, the
6 California Department of Social Services asserts that River View Christian
7 Academy falls within the definition of private alternative boarding school and thus
8 is subject to the Community Care Facilities Act, the jurisdiction of the California
9 Department of Social Services, and is enforced by the California Attorney General.
10 This allegation rests upon a warrant, dated January 8, served at the campus of River
11 View Christian Academy. (Exhibit 4). The warrant was by application of the
12 Community Care Licensing Division of the California Department of Social
13 Services in which the Attorney General and his deputies provided legal
14 representation before the Superior Court of California, in and for the County of
15 Shasta.
16 73. The warrant provided for the physical inspection of the grounds,
17 interviews of staff, leadership, volunteers, clients/children/ residents and “any other
18 potential witness” along with the collection, inspection and review of documents
19 related to matters enumerated in the Community Care Facilities Act. This includes,
20 records related to the following:
21
22 a. staff meetings on behavioral interventions;
b. records or evidence that shows that…RVCA operates as a
23 community care facility;
24 c. monitoring of food intake;
d. behavioral based services;
25 e. rehabilitative or treatment services;
26 f. conversion or other therapy for social, emotional, or behavioral
issues;
27 g. the acceptance of children with developmental disabilities, mental
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Verified Amended Complaint
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1 86. The notice was dated March 28, 2019, and gives Teen Rescue until
2 April 13, 2019, to file an application for a license or face a fine of $200 per day. If
3 Teen Rescue continues to operate River View Christian Academy it will be subject
4 to criminal prosecution with incarceration up to 180 days in jail.
5 87. Between April 2-3 counsel for Plaintiffs left numerous voicemails to
6 opposing counsel (Ismael Castro, Laurie Adamson and Judy Wong) to speak with
7 them about this urgent development. After eight voicemails, Judy Wong responded
8 by e-mail writing, “We presently only represent CDSS with respect to the federal
9 lawsuit. We do not represent CDSS with respect to issuance of this notice. It
10 appears that CDSS’ notice follows the inspection of the River View facility and is
11 consistent with its licensing enforcement duties.”
12 88. The representation of opposing counsel stands as inconsistent with the
13 filings made in the California Superior Court in Shasta County. There all three
14 attorneys represented the California Department of Social Services in the papers
15 filed with that Court to obtain the warrant related to CDSS’ enforcement duties.
16 See Exhibit 4 at p. 1.
17 89. In addition to fines and prosecution, Plaintiffs, and each of them, have a
18 reasonable fear that Defendants will attempt to close down the school. This could
19 occur even before the Defendants file a responsive pleading based on the extended
20 timeframe stipulated to by the parties to May 7, 2019.
21 90. Immediate relief is required to maintain the status quo while this Court
22 has an opportunity to rule on the constitutionality of the Community Care Facilities
23 Act. Absent immediate relief from this Court, the River View Christian Academy
24 and the Parent Class will be irreparably harmed. Moreover, the pupils will be
25 removed from school during the middle of a school term. As described above,
26 many of these students have experienced difficulties and an unscheduled move
27 would cause hardship on them educationally, and emotionally spiritually.
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Verified Amended Complaint
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4 91. River View Christian Academy and the Class Representative, Mr.
5 Williams, hereby incorporate the foregoing paragraphs as though fully set forth
6 herein.
7 92. The Community Care Facility Act and its supporting regulations
8 impose requirements on River View Christian Academy regarding student
9 autonomy in religion and sexual identity. In view of the latter, the law requires
10 River View Christian Academy to submit a plan for training in cultural competency
11 and sensitivity in issues relating to the lesbian, gay, bisexual, and transgender
12 communities. The law further imposes restrictions on the use of “behavioral-based
13 services to youth with social, emotional, or behavioral issues.”
14 93. Compliance with the Community Care Facility Act will violate the
15 sincerely held religious convictions and practices of this Christian ministry. The
16 Community Care Facility Act has no religious exemption.
17 94. Requiring River View Christian Academy to comply with the scope of
18 Community Care Facility Act and thus fall under the enforcement jurisdiction of the
19 Attorney General and the Director of the State Department of Social Services will
20 violate this religious educational institution’s rights to the free exercise of religion as
21 protected by the First Amendment.
22 95. Enforcement of the Community Care Facility Act is done under color
23 of state law and exposes Teen Rescue and its employees to criminal liability for
24 exercising their religion.
25
26
27
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Verified Amended Complaint
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1 after leaving foster care. The Parent Class stands appalled by the prospect of putting
2 their children under the jurisdiction of this state entity in charge of the licensing,
3 regulation, and monitoring of this failed and disreputable system.
4 102. What is more, the Parent Class does not wish to have California
5 countermand parents on what religious exercise and beliefs they want for their
6 children by requiring, under threat of criminal sanctions, that River View Christian
7 Academy defer to the wishes of individual students on religious practices on the
8 campus.
9 103. Bringing this religious school under the jurisdiction of the Department
10 of Social Services in order to enforce the religious and sexual orientation
11 requirements of the Community Care Facility Act violates the parental rights of the
12 Parent Class.
13
14
15 PRAYER FOR RELIEF
16 WHEREFORE, the Plaintiffs respectfully pray that the Court grant:
17 1. An order temporarily restraining Defendants, and their agents,
18 from enforcing the Community Care Facilities Act against Teen Rescue’s
19 school ministry operated through the River View Christian Academy
20 2. An order declaring that the Community Care Facilities Act is
21 unconstitutional under the religion clause of the First Amendment on its
22 face and as applied to River View Christian Academy;
23 3. An order declaring that application of the Community Care
24 Facilities Act to River View Christian Academy unconstitutionally
25 interferes with the free exercise of religion rights and the parental rights of
26 the Parent Class;
27
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28
Verified Amended Complaint
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1 VERIFICATION
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