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UNITED STATES DISTRICT COURT 

FOR THE SOUTHERN DISTRICT OF FLORIDA 

BRETT STUDLEY, 

Plaintiff 

v. 

AMERICAN LEARNING SYSTEMS, INC., 

DOUGLAS LAURIE, and 

LANEY STEARNS, 

Defendants 

DOCKET NO: 

 COMPLAINT 

AND JURY DEMAND 

INTRODUCTION 

This case arises out of the unlawful termination of Plaintiff Brett Studley, a teacher and 

girls basketball coach, because of his support for his student-athletes’ decisions to wear “Black 

Lives Matter” t-shirts to their pre-game warmups in protest against racism at their school and in 

their community. Even though Brett Studley did precisely what the mission statement of Defendant 

American Learning Systems, Inc. d/b/a American Heritage School of Boca Delray encourages – 

showing “strong moral principles in every aspect of campus life” – the school fired him for it. 

PARTIES 

1. Plaintiff Brett Studley (“Studley”) is an individual who resides in Boca Raton, 

Florida. 

2. Defendant American Learning Systems, Inc. (“American Heritage”) is a for-profit 

corporation organized under the laws of Florida with a principal place of business at 12200 W. 

Broward Boulevard, Plantation, Florida. 

JURISDICTION AND VENUE 

3. The Court has subject matter jurisdiction over this action under 28 U.S.C. § 1331, 

as the case arises under the Constitution, laws, or treaties of the United States. 

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4. The Court has in personam jurisdiction over American Heritage because American 

Heritage’s principal place of business is in Florida and the individual defendants reside in Florida. 

5. On August 27, 2021, Studley filed a complaint of discrimination regarding this 

matter with the Florida Commission on Human Relations pursuant to Fla. Stat. § 760.11. 

6. On March 4, 2022, the office of the Florida Commission on Human Relations 

issued a Notice of Rights letter to Studley which permits him to bring this action. See Exhibit 1, 

March 4, 2022, Notice of Rights Letter from the Florida Commission on Human Relations to 

Studley. 

7. Venue is proper in the Southern District of Florida under 28 U.S.C. § 1391(b)(1) 

and (2) as American Heritage’s principal place of business is in the judicial district and a 

substantial part of the events giving rise to Plaintiff’s claims occurred in the judicial district. 

FACTS 

American Heritage 

8. American Heritage is a private, for-profit pre-kindergarten-to-grade-12 school 

system with campuses in Broward and Palm Beach counties. American Heritage touts itself as the 

“#1 Private School In The Nation.” 

9. Most of the faculty and student body at American Heritage is white. 

10. American Heritage employs a work-service program allowing parents of students 

who could not otherwise afford to attend the school to work part-time on-campus jobs to help 

defray the cost of tuition. 

11. During his employment, Studley was surprised to see that white parents who 

utilized the program were much more likely to be given positions that interfaced with the public, 

whereas non-white parents were more likely to be given janitorial duties. 

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Coach Studley 

12. On August 10, 2017, Studley began working at American Heritage as a teacher and 

head coach of the girls’ basketball team (the “Lady Stallions”) at American Heritage’s Palm Beach 

campus. By then, Studley had already been a licensed professional Florida educator for six years 

and had coached basketball at the scholastic and collegiate levels for twelve years. 

13. In his first years as head basketball coach, Studley headed a rapid turn-around. 

After a less-than-stellar 3-18 first season, Studley led the Lady Stallions to a 20-9 record in his 

second season and the team qualified for the regional semifinals of the Florida High School 

Athletic Association (“FHSAA”) Class 4A State Championships. By the 2020-21 school year, 

Studley and the Lady Stallions were poised to contend for the FHSAA Class 4A State 

Championship. 

The Racially Discriminatory Classroom Incident and American Heritage’s Lack of Response 

14. On March 1, 2020, in response to the COVID-19 pandemic, American Heritage 

turned to remote learning to allow its students to continue attending classes. However, American 

Heritage cancelled school sports for the remainder of the school year. Sports were to resume in the 

fall of 2020, and all participating student-athletes would continue to attend school remotely. 

15. On November 24, 2020, a black student-athlete and member of the Lady Stallions 

(“Student-Athlete 1”) was attending a virtual American Heritage class taught by David Hession 

(“Hession”) when a student joined a class activity with “blacks smell” displayed as their screen 

name. This was not the first time a participant in an American Heritage virtual classroom displayed 

racially inflammatory imagery onscreen. Hession captured screenshots of this incident. 

16. As one of only two black students in the class, Student-Athlete 1 felt personally 

attacked and burst into tears. She relayed her experience to her teammates. 

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17. Studley learned about the incident from Hession soon after it occurred. Troubled, 

Studley urged Hession to report the incident to Principal Lisa LeFevre (“LeFevre”). 

18. Moments after his conversation with Hession, Studley approached American 

Heritage Dean Muhammad Abdullah (“Abdullah”) and showed him the screenshots. Abdullah 

told Studley that he was going to open an investigation into the incident. 

19. Later that day, another Lady Stallion (“Student-Athlete 2”) reported the incident to 

LeFevre, describing it as just another example of discrimination at American Heritage against 

students of color and informing LeFevre of how disturbed she was by the situation. 

20. Student-Athlete 2’s parents contacted American Heritage to complain about the 

incident. 

21. By November 30, 2020, despite multiple requests for information about the 

investigation, Studley had received no updates from the administration and American Heritage had 

issued no statements regarding the incident. 

22. Around November 30, 2020, Studley asked his supervisor, Palm Beach campus 

Athletic Director Laney Stearns (“Stearns”), for the school to send out an email stating simply that 

American Heritage would not tolerate acts of racial discrimination in any form. Stearns refused. 

Student-Athletes Take a Stand Against Racism 

23. On December 1, 2020, the Lady Stallions were scheduled to play an away game. 

The school had yet to address the racial slur incident, so Student-Athlete 1 asked Studley if she 

could wear a “Black Lives Matter” t-shirt during warm-ups. 

24. Because his students clearly felt abandoned by American Heritage, as it had not 

responded to the racial slur incident and had not taken any action or made any statement about it, 

Studley worried that rejecting Student-Athlete 1’s request would tacitly ratify both the use of a 

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racial slur in the classroom and American Heritage’s failure to respond to it. Based on these 

considerations, Studley felt he had a moral and professional duty to grant Student-Athlete 1’s 

request, which he did. At the December 1, 2020, game, Student-Athlete 1 warmed up in a t-shirt 

that contained the words “Black Lives Matter.” 

25. On December 3, 2020, the day before the Lady Stallions’ next scheduled home 

game, Student-Athlete 1 again asked to wear the “Black Lives Matter” t-shirt for warm-ups. 

Studley told her that he would support her decision. When she heard about Student-Athlete 1’s 

idea, Student-Athlete 2 also decided to wear a “Black Lives Matter” t-shirt during warm-ups. 

Studley told Student-Athlete 2 that he also supported her decision, for the same reasons. 

26. An American Heritage student took a photograph of the student-athletes wearing 

“Black Lives Matter” t-shirts and later posted it to their personal Twitter page, as did American 

Heritage Football Coach Christopher Rutledge ("Rutledge"). 

American Heritage Attempts to Quash Student-Athlete Advocacy 

27. On December 5, 2020, Stearns, after having seen Rutledge’s Twitter post, called 

Studley and scolded him, reiterating that they had already discussed the school’s refusal to make 

a statement about racism. Studley noted that they had discussed the lack of a response by the school 

to the racial slur incident and had not discussed the student-athletes’ decision to wear “Black Lives 

Matter” t-shirts in response. 

28. During the call, Stearns rejected the idea that black lives matter and stated, “All 

lives mattered.” 

29. Stearns also asked Studley why those who used “Black Lives Matter” loot 

communities and referenced black-on-black crime in support of his position. 

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30. At the end of the conversation, Stearns suggested that American Heritage President 

Douglas Laurie (“Laurie”) would take action against Studley when he saw the Twitter posts. 

31. At the time, Stearns had a history of violating ethics laws to advance his own 

interests. On January 30, 2019, the State of Florida’s Commission on Ethics announced that 

Stearns, while acting as Plantation city fire chief, violated the state’s anti-nepotism law by hiring 

or promoting his own son. In addition, Karen Stearns – Stearns’s wife – serves as athletic director 

for American Heritage’s Broward campus. 

32. On December 5, 2020, Studley also learned from American Heritage’s contact 

tracing team that he had been in close contact with an American Heritage employee who had been 

exposed to COVID-19 and was asked to self-quarantine. No member of the girls’ basketball team 

was asked to self-quarantine, so the team continued to practice at the campus gym while Studley 

attended practices via Zoom. 

33. On December 8, 2020, Stearns called Studley to inform him of the protocols for his 

return to campus and explicitly told Studley that members of the girls’ basketball team were 

forbidden from wearing “Black Lives Matter” t-shirts during pre-game warm-ups. Studley 

reluctantly relayed Stearns’s – and therefore the school’s – directive to the Lady Stallions. 

34. Although American Heritage forbade black students from wearing “Black Lives 

Matter” t-shirts during pre-game warm-ups, it had previously allowed white American Heritage 

students to display “Trump” flags, “Trump 2024” banners, and “Blue Lives Matter” flags during 

virtual classes without consequence. In light of the racial slur incident, Studley felt that American 

Heritage’s newly selective enforcement of its policies was racially discriminatory. 

35. Prior to the Lady Stallions’ next game, scheduled for December 10, 2020, Studley 

received calls from several of his student-athletes’ parents asking what would happen if their 

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children warmed up in “Black Lives Matter” t-shirts. Studley told them truthfully that he did not 

know. 

36. On or about December 9, 2020, Stearns, an athletic director taking an unusually 

active role in the enforcement of a dress code policy, called Studley and ordered him to bench any 

student-athlete who attempted to warm up in a “Black Lives Matter” t-shirt and warned that any 

student-athlete who warmed up in a “Black Lives Matter” t-shirt would be immediately suspended. 

Studley told Stearns that he would refuse to force his assistant coaches to enforce the directive, 

which Studley viewed as racially discriminatory. 

37. During the December 9, 2020, call, Studley noted that Student-Athlete 2 had over 

60,000 followers on Instagram and was considering posting about the controversy. Stearns 

responded, “Dwyane Wade couldn’t take us down. Do you think the administration is afraid of a 

high school girl?”, touching on American Heritage’s recent history of receiving backlash for its 

attitude toward racism and discrimination. Regarding the reference to Dwayne Wade, in 2018, 

NBA star Dwyane Wade and actress Gabrielle Union publicly supported an investigation into the 

alleged race-based expulsion of Cyrus Nance, a black American Heritage student-athlete. 

American Heritage also faced a groundswell of criticism in the summer of 2020 for a statement 

about diversity on its campus, widely seen as vapid and passive, in the wake of national protests 

advocating for racial justice and police reform. 

38. On another call on December 9, 2020, Stearns threatened Studley’s employment, 

saying “What’s going to stop [Laurie] from cancelling games and then blaming it on COVID?” 

39. On the evening of December 9, 2020, team parents posted on Twitter about their 

unhappiness with American Heritage’s handling of the “Black Lives Matter” t-shirts situation. The 

local high school sports community quickly took notice of the posts. 

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40. American Heritage’s own policies support Studley’s refusal to participate in 

Stearns’ racially motivated scheme. The American Heritage Employee Handbook requires that 

faculty members: 

Shall not harass or discriminate against any student on the basis of 

race, color, religion, sex, age, national or ethnic origin, political 

beliefs, marital status, handicapping condition, sexual orientation, 

or social and family background and shall make reasonable effort to 

assure that each student is protected from harassment or 

discrimination. 

41. The American Heritage policy cited above, as well as the Florida Department of 

Education’s Rule 6A-10.081, which contains language substantially similar to the American 

Heritage policy, states further that: “Violation of any of these principles shall subject the individual 

to revocation or suspension of the individual educator’s certificate, or the other penalties as 

provided by law.” At all relevant times, Studley has held a valid Florida educator’s certificate. 

American Heritage Retaliates by Cancelling Lady Stallions Basketball Games and Events 

42. On the morning of December 10, 2020, Stearns informed Studley that American 

Heritage’s Broward campus basketball team had cancelled that night’s game against the Lady 

Stallions. Stearns told Studley that he didn’t know why the game was cancelled but mentioned the 

parents’ Twitter posts. 

43. After the call with Stearns, Studley called the coach of the Broward campus 

basketball team about the cancellation. The Broward campus coach was surprised and did not 

know that the game was cancelled. The coach promised to speak to his campus’s athletic director 

Karen Stearns – Stearns’s wife – about it. 

44. Shortly thereafter, Studley received another call from Stearns informing him that a 

basketball tournament fundraiser scheduled for the upcoming weekend, which Studley had helped 

organize, was also cancelled. 

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45. When Studley asked why, Stearns said all events were being cancelled to “disinfect 

the gym due to the member of the boys basketball team who had tested positive for COVID-19”, 

or words to that effect, despite the school having already completed contact tracing five days prior 

and after the school learned of the positive test even earlier than that. 

46. When students or employees at American Heritage had tested positive for COVID19 in the past, no room or building on the American Heritage Palm Beach campus had been closed 

for several days for “disinfecting.” 

47. Upon learning the purported reason for the cancellation, some parents posted their 

discontent on Twitter, believing that American Heritage had cancelled their children’s basketball 

game in retaliation for student-athletes wearing “Black Lives Matter” t-shirts. 

48. On December 12, 2020, Studley received a call from Robert Stone (“Stone”), 

headmaster of American Heritage’s Palm Beach campus. Stone asked Studley for all 

communications between Studley, the athletic department, Lady Stallions players, and their 

families. Studley shared that information with Stone the same day. 

49. Later that day, American Heritage’s administration sent an email to faculty, staff, 

parents, and students stating that they had finally investigated the November 24, 2020, incident. 

The e-mail did not denounce the use of the racial slurs and did not offer any resources for students 

affected by the incident. 

50. Following the December 12, 2020, email, American Heritage made no further 

investigation and took no further action regarding the November 24, 2020, incident. 

Coach Studley Reacts to American Heritage’s Inaction Against Racism 

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51. On Sunday, December 13, 2020, concerned that if he remained silent any longer he 

would be complicit in the school’s refusal to condemn racism, Studley made the following three 

posts on Twitter: 

52. As of December 13, 2020, the Lady Stallions basketball team had had no cases of 

players with COVID-19 during the 2020-2021 season. 

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53. On December 14, 2020, at team practice, Studley reiterated the school’s position 

about the “Black Lives Matter” t-shirts, but left the decision about wearing them up to each 

student-athlete and told them he would support them no matter their choice. 

54. On December 15, 2020, prior to the Lady Stallions’ game, seven of the ten team 

members wore “Black Lives Matter” t-shirts during warm-ups. The other three team members 

expressed support for their teammates’ position in other ways. 

55. In the weeks following Studley’s Twitter posts, several media outlets contacted 

Studley for comment about American Heritage and its history of racial controversy. In response, 

Studley acknowledged only his support of the student-athletes’ decisions to wear “Black Lives 

Matter” t-shirts, but did not comment on American Heritage’s response. 

56. Members of the Lady Stallions continued to wear “Black Lives Matter” t-shirts 

during warm-ups until their final game on February 25, 2021. 

57. That season, the Lady Stallions advanced to the 2021 FHSAA Class 4A state 

semifinals – the furthest the team had ever advanced in school history. 

58. On May 4, 2021, Studley received an email from American Heritage’s Strategic 

Operations Director Natalie Laurie asking if Studley was interested in joining a recently created 

Diversity, Equity, and Inclusion (“DEI”) Task Force Committee. 

59. On May 5, 2021, in response Studley wrote, in part: 

I thought this task force was put in place to address the systemic 

issues here at American Heritage, however it seems like it is just for 

optics.... A player of mine was racially attacked in her class and the 

school refused to make a statement condemning that 

behavior. Instead the school cared more to protect the student who 

caused the situation and not the student who was attacked. I believe 

if the Task Force was here for real change, consulting with them 

would have been a wise choice. Our standing as a school has taken 

a deep hit in communities of color and we continue to do nothing to 

repair it. I hope that this Task Force does the job it was intended to 

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do, but my feelings are that this is just another way to put lipstick on 

a pig. 

American Heritage Fires Studley for Standing with His Students Against Racism 

60. On May 17, 2021, Studley met with LeFevre and CFO June Walker (“Walker”) to 

discuss his May 5, 2021, email. LeFevre and Walker told Studley they viewed his statements as 

false and that the administration’s response to the racial slur incident and the subsequent reaction 

from the girls’ basketball team was adequate. Studley disagreed. 

61. At this meeting, Studley reported other instances of racial discrimination he has 

witnessed at American Heritage, including heightened scrutiny in admissions toward students of 

color, incidents where he was asked “what color” prospective girls’ basketball players were, and 

racially disparate student discipline. 

62. On June 10, 2021, Laurie told Studley that his contract would not be renewed for 

the 2021-2022 school year, effectively terminating his employment. 

63. Laurie said the administration had lost faith in Studley “for making false 

statements” in his May 5, 2021, email and the May 17, 2021, meeting, and for “lying to the media.” 

Studley denies these allegations. 

64. During the meeting, Studley told Laurie he believed the December 10, 2020, game 

was cancelled because black student-athletes planned to wear “Black Lives Matter” t-shirts at the 

game. Studley stated that the school’s given reasons for the cancellation were pretextual. 

65. Before this meeting, Studley was not warned that American Heritage was 

considering taking any adverse action against him. 

66. After Studley’s termination, at least three student-athletes who played for Studley 

transferred from American Heritage to other schools. 

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67. American Heritage terminated Studley because of his association with and support 

for black student-athletes on the girls’ basketball team, because of his opposition to and refusal to 

participate in American Heritage’s racial discrimination, and because of his complaints about 

racial discrimination to American Heritage. 

CAUSES OF ACTION 

COUNT I 

Violation of 42 U.S.C. § 2000e 

(Against American Heritage) 

68. Plaintiff incorporates and realleges the preceding paragraphs as if fully restated 

herein. 

69. At all relevant times, Plaintiff was qualified by his education, training, experience, 

and/or licensure for the position for which he was employed by American Heritage. 

70. American Heritage’s termination of Plaintiff’s employment constituted an adverse 

employment action. 

71. At the time of Plaintiff’s termination, American Heritage knew that Plaintiff had an 

association with students at the school who were members of a protected class based on their race. 

72. Plaintiff’s association with students at American Heritage who were members of a 

protected class based on their race was a determining factor in American Heritage’s decision to 

terminate him. 

73. As a direct and proximate result of American Heritage’s conduct, Plaintiff has 

suffered damages including lost wages, other lost employment benefits, reputational harm, 

emotional distress, attorney’s fees, legal costs and fees, and other direct and consequential 

damages, in an amount to be determined at trial. 

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COUNT II 

Violations of 42 U.S.C. § 1981 

(Against American Heritage) 

74. Plaintiff incorporates and realleges the preceding paragraphs as if fully restated 

herein. 

75. As described herein, American Heritage has violated 42 U.S.C. § 2000e. 

76. At all relevant times, Plaintiff was qualified by his education, training, experience, 

and/or licensure for the position for which he was employed by American Heritage. 

77. American Heritage’s termination of Plaintiff’s employment constituted an adverse 

employment action. 

78. At the time of Plaintiff’s termination, American Heritage knew that Plaintiff had an 

association with students at American Heritage who members of a protected class based on their 

race. 

79. Plaintiff’s association with students at American Heritage who were members of a 

protected class based on their race was a determining factor in American Heritage’s decision to 

terminate him. 

80. As a direct and proximate result of American Heritage’s conduct, Plaintiff has 

suffered damages including lost wages, other lost employment benefits, reputational harm, 

emotional distress, attorney’s fees, legal costs and fees, and other direct and consequential 

damages, in an amount to be determined at trial. 

COUNT III: 

Violation of Fla. Stat. Ann. § 760.10 

(Against American Heritage) 

81. Plaintiff incorporates and realleges the preceding paragraphs as if fully restated 

herein. 

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82. At all relevant times, Plaintiff had an association with students at American 

Heritage who were members of a protected class based on their race. 

83. As a direct and proximate result of Plaintiff’s protected association with members 

of a protected class, Plaintiff suffered the adverse employment action of the termination of his 

employment. 

84. As a direct and proximate result of American Heritage’s conduct, Plaintiff has 

suffered damages including lost wages, other lost employment benefits, reputational harm, 

emotional distress, attorney’s fees, legal costs and fees, and other direct and consequential 

damages, in an amount to be determined at trial. 

COUNT IV: 

Wrongful Termination in Violation of Public Policy 

(Against American Heritage) 

85. Plaintiff incorporates and realleges the preceding paragraphs as if fully restated 

herein. 

86. Plaintiff’s termination violated public policy and was therefore wrongful. 

87. Plaintiff was terminated in retaliation for his refusal to participate in or condone 

American Heritage’s racial discrimination as described herein. 

88. Plaintiff was terminated for refusing to violate the terms and conditions of his 

educator’s license, as described in Florida Department of Education Rule 6A-10.081. 

89. As a direct and proximate result of American Heritage’s conduct, Plaintiff has 

suffered damages including lost wages, other lost employment benefits, reputational harm, 

emotional distress, attorney’s fees, legal costs and fees, and other direct and consequential 

damages, in an amount to be determined at trial. 

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COUNT V: 

Tortious Interference with Contractual Relationship 

(Against Laurie and Stearns) 

90. Plaintiff incorporates and realleges the preceding paragraphs as if fully restated 

herein. 

91. At all relevant times, Plaintiff maintained a contractual relationship with American 

Heritage. 

92. Laurie and Stearns intentionally, wrongfully, and by improper means and with 

improper motive interfered with Plaintiff’s contractual relationship. 

93. Laurie and Stearns acted with a spiteful, malicious, malignant purpose unrelated to 

any legitimate business purpose. 

94. As a direct and proximate result of Laurie’s and Stearns’s conduct, Plaintiff has 

suffered damages including lost wages, other lost employment benefits, reputational harm, 

emotional distress, attorney’s fees, legal costs and fees, and other direct and consequential 

damages, in an amount to be determined at trial. 

PRAYER FOR RELIEF 

WHEREFORE, Plaintiff Brett Studley prays for the following relief: 

A. that the Court enter judgment in favor of Plaintiff on all Causes of Action; 

B. that the Court, as to all Causes of Action, award the Plaintiff damages in an amount 

to be determined at trial, including compensatory damages, liquidated damages, and punitive 

damages as allowed by law, interest, costs, and reasonable attorneys’ fee as allowed by law; 

C. that the Court order such other, further, and different non-monetary relief as the 

nature of this action may require and that the Court deems just and proper. 

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Respectfully submitted, 

By the Plaintiff, 

 BRETT STUDLEY, 

 by his attorney, 

Dated: August 25, 2022 /s/ Charles F. Rodman

Charles F. Rodman 

Florida State Bar No.: 0147737 

 chuck.rodman@rodmanemploymentlaw.com 

RODMAN EMPLOYMENT LAW 

 181 Wells Ave., Suite 101 

 Newton, MA 02459 

 Tel: (617) 820-5250

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