Jennifer Styczinski and Thomas Styczinski v. City of Eden Prairie

Background

Jennifer and Thomas Styczinski, on behalf of their minor son A.S., brought this action under 42 U.S.C. § 1983—the federal statute that allows individuals to sue state or local government actors for violations of their constitutional rights—against the City of Eden Prairie, Valerie Verley (the Community Center Manager), and Amy Markle (the Parks and Recreation Director). The Styczinskis alleged that the revocation of their family's access to the Eden Prairie Community Center's (EPCC) Aquatic Center violated their First Amendment right to free speech and their Fourteenth Amendment right to due process. They sought declaratory relief (a court declaration that defendants acted unlawfully), injunctive relief (a court order requiring reinstatement of access), damages, and attorney's fees.

Factual Record

The Styczinskis became EPCC members in 2015 and agreed to abide by the EPCC's 'Behavioral Guidelines: Verbal Abuse' policy (the Policy). The Policy applies when 'a participant demonstrates threatening or personalized abusive behavior toward staff members and/or other patrons' and defines verbal abuse as 'speaking with the intent to demean, humiliate, blame or threaten,' including name-calling, personal attacks, condescension, degradation, threats, and ignoring or refusing to comply with staff enforcing building rules.

Two incidents formed the factual basis of this lawsuit:

Fitness Center Incident (April 5, 2022) A.S. wore wet outdoor shoes into the Fitness Center, violating facility rules. When Fitness Instructor Kelly Henderson instructed him to dry his shoes, A.S. ignored her and began using a treadmill. Fitness Lead Jill Bickler then addressed A.S., who dismissed her and said Henderson was harassing him. Thomas requested to speak to a manager, and the Manager on Duty spoke with him. Two days later, Verley emailed Jennifer, reminding the family of EPCC behavior guidelines and warning that continued issues would jeopardize their membership. Jennifer did not respond and did not share the email with Thomas until after the second incident.

Aquatic Center Incident (July 15, 2022) A.S. broke diving board rules, causing lifeguards to close the board; he then climbed on the ladder and railing despite the closure. Separately, Jennifer intervened in a lifeguard's conversation with a group of misbehaving teenagers, became visibly angry, and gestured emphatically. The head lifeguard, Mayia Melchert, asked Jennifer to write down her contact information per her training. After Jennifer left, Thomas arrived, asked that the diving area be reopened (which it was), and A.S. and his friend repeatedly violated the diving rules. Thomas then confronted Melchert in the pool, gesturing with his hands, pointing, and shaking his finger and fist at her while she was crouched on the pool deck. He later followed two minor female lifeguards out the door and called out that he would be complaining about one of them. Melchert reported that Thomas was 'screaming,' 'very animated, very loud,' and in her 'personal space,' causing her to feel physically threatened. Five lifeguards completed incident report forms that evening, and two lifeguards told Verley the following week they were afraid to return to work if the Styczinski family came back.

Post-Incident Process On July 20, 2022, after reviewing lifeguard reports and speaking with staff, Verley revoked the family's Aquatic Center access and emailed the Styczinskis, attaching the Policy and warning that their broader membership was in jeopardy. Thomas then requested and received a meeting with the City's Parks and Recreation Director on August 12, 2022. The Director subsequently declined to reverse the decision, noting that over ten individuals had reported the family's behavior as threatening. Thomas asked how to appeal; the Director offered to escalate to the City Manager, but Thomas did not pursue this. Nearly a year later, on August 1, 2023, Thomas wrote to the City Manager asking that Verley and the Director be disciplined. The City Manager declined to discipline them but offered to restore the family's full EPCC membership, including Aquatic Center access.

Legal Analysis

Standard of Review Summary judgment—a ruling in favor of one party without a trial—is appropriate when there is no genuine dispute of material fact and the moving party is entitled to win as a matter of law. The court noted that where the record clearly contradicts one party's account, the court need not accept that party's version of events.

Count I: First Amendment Free-Speech Claims

As-Applied Challenge An as-applied challenge argues that a law or policy, even if valid on its face, was unconstitutionally applied to the specific plaintiff. The court rejected the Styczinskis' as-applied claim on two independent grounds.

First, the court held that the EPCC is a non-public forum—government property that has not traditionally or by designation been opened for general public discourse. In a non-public forum, the government may impose content-based restrictions on speech so long as the restrictions are viewpoint-neutral and reasonable in light of the forum's purpose. The court found the Policy satisfied both requirements, particularly noting the significant safety interest in maintaining order at a pool where disruptions could distract lifeguards.

Second, the court held that the revocation was based on the Styczinskis' conduct, not their speech. The First Amendment does not bar restricting conduct that incidentally involves speech. The court identified three specific conduct violations: (1) A.S. wore outside shoes into the Fitness Center and ignored staff directions; (2) Thomas behaved in a threatening and harassing manner toward Melchert and followed minor lifeguards around the deck; and (3) Jennifer interfered with lifeguards' attempts to enforce pool rules with other patrons.

Facial Challenge A facial challenge argues that a law or policy is unconstitutional in all or most of its applications, not just as applied to the plaintiff. To succeed, plaintiffs must show that 'a substantial number of the law's applications are unconstitutional, judged in relation to the statute's plainly legitimate sweep,' applying the framework from Moody v. NetChoice, LLC, 603 U.S. 707 (2024).

The Styczinskis argued the Policy was not viewpoint-neutral because it restricted criticism of staff but was silent about compliments. The court rejected this characterization, finding the Policy does not prohibit patrons from expressing negative viewpoints; it only restricts the manner of expression—specifically, threatening or demeaning conduct. A patron could criticize staff through many channels (speaking to a manager, using a comment box, speaking to any employee) so long as the patron did not behave in a threatening or demeaning manner. Because the Policy restricted abusive conduct regardless of viewpoint, the court found it viewpoint-neutral and granted summary judgment to defendants on the facial First Amendment claim.

Count II: Fourteenth Amendment Due Process Claims

The court rejected the Styczinskis' due process claims on multiple grounds.

First, there is no constitutionally protected property interest in unrestricted access to a public building. A protected property interest—a requirement for a due process claim—arises only where a statute or policy contains specific substantive standards that meaningfully limit official discretion. The Styczinskis could not establish such an interest in EPCC access.

Second, even assuming a protected interest existed, the court found the family received constitutionally adequate process: they had prior notice of the Policy (including the warning email after the Fitness Center incident), received a written explanation for the revocation, met with the Parks and Recreation Director, and were ultimately offered restoration of full membership, including Aquatic Center access.

Because the as-applied due process claim failed, the facial due process claim also failed—consistent with the general principle that a party who cannot show a constitutional violation as applied to themselves cannot succeed on a facial challenge. The court also noted that because there was no constitutional violation, it did not need to address Verley's immunity argument (qualified immunity, which would have protected her from personal liability even if a violation occurred).

Disposition

The court denied the Styczinskis' motion for partial summary judgment (Doc. No. 29), granted defendants' motion for summary judgment (Doc. No. 33), and dismissed all of plaintiffs' claims with prejudice—meaning the claims are permanently closed and cannot be refiled.