SPRINGFIELD — The parties in a federal discrimination lawsuit involving the city’s three public day schools for children with mental health disabilities have filed hundreds of pages of emails, affidavits and other documents this summer as the two sides argue whether the case should be certified as a class-action lawsuit.

The two sides in the case have also filed testimony from special education experts in recent weeks, in which those experts offer contrasting views on the formation of the proposed class.

The plaintiffs, which include a teenage student, his mother and an advocacy organization, have supplied a number of internal emails sent by staff earlier this year in support of their argument in favor of class-action status.

One email thread includes messages in which a staff member calls one student and his mother “crazy.” Other documents include statements signed by parents seeking to join the lawsuit against the school district who say their children suffered from a lack of opportunities at the schools.

But in support of its opposition to class action certification, attorneys for the city on Aug. 16 filed documents that include affidavits from parents who say their children saw improvements in their school work and behavior after transferring to the Springfield Public Day Schools.

In one affidavit, a mother says her son “is enthusiastic and supportive of his classmates” and “has also improved academically, and has achieved higher grades at Public Day Middle School.”

The recent flurry of document filings will culminate this fall with a hearing in which the court will hear the evidence and ultimately decide whether to allow the case to proceed as a class action lawsuit.

Case background

The suit was filed in June 2014 by a then-15-year-old day school student identified as “S.S.” and his mother, identified as “S.Y.”

It alleges that the more than 200 mentally disabled students attending the public day schools are discriminated against because they do not receive the same opportunities as students attending the city’s neighborhood schools. Students at the day schools don’t have the same opportunities to participate in sports or extracurricular activities as other students, and don’t receive the same level of support in terms of college and military recruiting, the complaint states.

Moreover, the lawsuit alleges that providing an education is not the real goal at the day schools, which cover the elementary, middle and high school grades.

“Instead of fostering learning, the focus of the Public Day School is on behavior control using drastic methods including dangerous physical restraints, inappropriate forced isolation in padded rooms, and repeated arrests and suspensions for minor offenses,” the complaint states.

The Parent / Professional Advocacy League, which advocates for better access to mental health services, is also a plaintiff in the lawsuit. The city and its school department are named as defendants.

When the lawsuit was filed two years ago, Springfield Superintendent of Schools Daniel Warwick called the claims “outrageous” and said the suit was an action by “outsiders” that threatened to distract the district from its mission of providing quality education and services.

“These are merit-less allegations that are jam-packed with falsehoods,” he said. “I cannot wait for the opportunities to not only defend our public day programming but also to highlight the significant gains which have been realized by the students enrolled in these programs.”

According to an affidavit from Springfield Alternative Schools Principal Rhonda Jacobs, a total of 246 students were enrolled in the three day schools for the 2015 to 2016 school year. The district’s total enrollment was 25,642. The schools have an average class size of seven to 12 students.

Plaintiffs present internal emails

Documents filed by the plaintiffs with the court on July 15 include affidavits from parents expressing disappointment with the day schools, as well as internal emails in which staff describe deteriorating building conditions. In another email thread, staff members make derogatory statements about colleagues, students and parents.

An affidavit from one father states that his son, who has a mental health disability and was suspended repeatedly while a student at Chestnut Accelerated Middle School, was transferred to the Public Day Middle School over the family’s objections.

“The PDS middle school campus looks like a jail,” the father wrote. “My first experience with PDS staff was with someone who told me that she used to be a correctional officer and that she ‘knows how to call DCF,’ the state child protection agency. [Springfield Public Schools] is aware of my child’s very difficult history in DCF custody and of his fear of the agency.”

The father’s affidavit bemoans what he called a complete lack of afterschool programs and other opportunities. Moreover, the father said his son found the day school environment frightening. “It seems to me that J.R. is almost too afraid to apply himself to math, a subject he likes,” the father wrote. “I believe that J.R. is stuck academically and not able to do what he is capable of at PDS.”

One email thread describes the circumstances surrounding a parent whose child was being transferred to a day school, and shows staff in sharp disagreement about how to handle the student.

School officials had determined the child had attention deficit disorder. The boy’s mother had allegedly told a behavior specialist he was also schizophrenic.

“I asked him if he hears voices and he says he always hears them for a lot of years. I have never heard this ever before about him,” Lynda Austin, the behavior specialist, wrote in a Jan. 4, 2016 email to Melissa “Mimi” O’Neill, the school district’s Supervisor of Clinical and Behavioral Services.

The specialist’s email refers to Springfield Public Day Middle School Assistant Principal Linda Singer’s efforts with the boy — who, according to Austin, told him “how much he is going to learn and how much work he is going to do,” Austin’s email states.

“Um hello [the boy] has about a 67 IQ and has done absolutely nothing all year bc he is too busy fighting and freaking out every second,” Austin wrote to O’Neill. “I don’t get her angle. I felt like I was seriously on a prank show or something. It was so crazy,” the specialist wrote.

The boy’s “mom of course is just as crazy as he is and drops f bombs as frequently as he does and they argue like crazy,” Austin wrote.

O’Neill responded later that morning to Austin: “Mom makes crap up a lot his diagnoses — we had some service providers last year at a meeting and they had never heard those diagnoses either — she threw out bipolar then too.”

The message continued with a swipe at Singer, the assistant principal: “Linda is a piece of work and i totally agree — she has no business there. How did Rhonda come up with that one.”

Also included in the plaintiff’s filings in support of the class designation is an email thread that speaks to claims that maintenance at the day schools lags behind other facilities.

“Public Day Middle – Broken Windows in several classrooms,” the city’s Principal of Alternative Day Schools Rhonda Y. Jacobs wrote in a December 2015 email to Robert Mulcahey, the facilities operations administrator for Springfield Public Schools.

Jacobs wrote Mulcahey again in February about conditions at Springfield Public Day Middle School, located at 118 Alden St.

“Our requests are still pending,” the principal told Mulcahey. “Please, please, please support putting closure on some of the items on our initial lists such as: Windows at Alden Street….”

The email continues: “Our parents in the alternative school already feel as though we are the last to receive. Delay further validates their impressions. I know and believe different as I am aware of the ‘Big Picture’. But I need your help.”

In another February 2016 email, the Public Day Middle School’s adjustment counselor reports to the principal that a closet “previously identified with asbestos” is “where staff store the student’s belongings, such as coats, phones, etc.”

The counselor asked: “The students’ belongings are stored here all day long every day on top of these asbestos tiles. Is this considered hazardous?”

Parents show support for schools

Among the dozens of pages of expert testimony, statements by school officials and other documents supplied by the district in opposition to the proposed class certification are affidavits from parents who say the day schools have been a boon to their children’s education.

In one affidavit, the father of an eighth grade student at the Public Day Middle School described his son as suffering from both post-traumatic stress disorder and attention deficit disorder. The boy was a “repeat kindergartener” who was often overwhelmed in large groups and had struggled academically.

Since transferring to the Public Day Middle School in 2014, the boy has “improved his interactions with staff and other students and has substantially improved in self-regulation and using coping strategies, communicating with others effectively and maintaining safe behaviors,” the father wrote, in addition to showing academic improvements and greater confidence in some subjects.

“I am supportive of the Springfield Public Day School,” the affidavit continued. “The staff at the Public Day Middle School are creative and innovative in their approaches to help my son both academically, and improve and stabilize his aggressive behavior.”

The mother of a current seventh-grade student at the Public Day Middle School described her son showing “noticeable social and emotional improvements” after the boy was transferred from the  Glickman Elementary School to the elementary day school.

Her son — who suffers from attention deficit disorder and Asperger’s syndrome, according to the affidavit — eventually won a reputation as a “team leader” in math and art classes — despite the fact that, at the Glickman school, he struggled to work with classmates during group activities and was often disruptive.

The woman said the family’s home life had improved, too, thanks to coping strategies and other techniques her son learned from day school staff that she implemented outside of school.

“I have also implemented similar strategies at home with J.M., allowing him space at home in which to take a break when he is emotionally overwhelmed,” she wrote. “The strategies introduced to me by Public Day staff have worked at home.”

In another affidavit, the mother of a former day school student said the school district preferred to keep her child in  M. Marcus Kiley Middle School — but she insisted on a day school placement.

At the Public Day Middle School, her son — who suffered from PTSD, attention deficit disorder, anxiety and depression among other diagnoses — showed marked improvements in both his behavior and academic achievement, she wrote.

The boy was eventually able to transfer back to Van Sickle Academy, and this year won a spot in his high school of choice: Putnam Vocational Technical Academy.

“The Springfield Public Day School was the best thing that ever happened for my son,” the mother’s affidavit states.

Experts disagree on class status

The parties have also introduced testimony from experts in the field of special education, offering contrasting views of whether the day school students meet the criteria for a class-action lawsuit.

The plaintiffs in the case offered testimony from Peter E. Leone, a professor of special education in the College of Education at the University of Maryland.

From January through May 2016, Leone assessed a “statistically valid random sample” of over two dozen day school students, interviewing students or their parents, reviewing student records and interviewing mental health providers and advocates assigned to work with day school students.

In summarizing his findings, Leone wrote that the potential class members have been placed in the day schools because they showed behavioral difficulties in their neighborhood schools. In order to thrive at those neighborhood schools, the day school students would need what Leone referred to as a “common set” of “school based behavior services.”

But, Leone argued, the neighborhood schools do not offer the services “that would allow class members to avoid placement in the segregated SPS Public Day School.”

Leone said he was “confident” that the proposed class members could find academic success in the neighborhood schools if those schools offered “appropriate” services.

The district, Leone wrote, “has a common practice of failing to provide SBBS [school based behavioral services] to S.S. and members of the class in the neighborhood schools, thereby denying these children equal educational opportunity.”

But in response to Leone’s testimony, a document filed by the school district this summer offered testimony from Nicole LaChapelle, an attorney who currently serves as director of special education for Holyoke Public Schools.

According to LaChapelle’s argument, the varied nature of the day school students’ experiences — each of whose schooling is guided by a unique individual education plan — means the students together fail to form a cohesive class.

“Plaintiff’s expert has not provided credible evidence that the proposed class is comprised of members who share the same motivation in bringing this action with common remedy, for their individual educational plans are tailored for the individual student,” her testimony states.

Moreover, she said, the Parent / Professional Advocacy League and the students themselves are motivated by different claims. The advocacy group, she explained, represents “many children with diverse mental health needs” — some of whom are not students in the Springfield district. The Springfield students, meanwhile, “seek to access FAPE [free and appropriate education] for themselves individually.”

Because of the specific circumstances surrounding each student under their individual education plans, LaChapelle wrote, “there is not a group resolution that answers the majority of possible contentions if the action goes forward as a class action.”

Both experts received compensation for their testimony, according to disclosure statements included in court filings.

The hearing on the evidence that will ultimately lead to the court’s decision on the class certification question is scheduled for Oct. 16, according to court records.