Case 1:16-cv-00540-AJT-MSN Document 37 Filed 07/28/17 Page 6 of 20 PageID# 3262 September 29, 2015 stating that Davison was barred from entry onto any school board property for the remainder of the 2015-16 school year upon threat of arrest for criminal trespass. Id. ¶ 30z. Two subsequent letters correcting the first one were issued to Davison, and each of the three was issued without a prior hearing. The letters required Davison to request permission form Principal Stephens two days in advance of any desire to attend any matter related to his children at Seldens Elementary School. Davison alleges that he was prevented from attending his children’s school performances, taking his children to the park located on LCPS grounds over the weekend, meeting with his children’s teachers, dropping his children off at or picking them up from school, and bringing his children forgotten items to them during the school day, among many other inconveniences. Within days of receiving the first “No Trespass” letter, Plaintiff appealed directly to Principal Stephens to lift the ban, and she denied that appeal in the final revised version of the letter dated October 14, 2015 (the “No Trespass Letter”). Id. ¶ 32a-b. The No Trespass Letter also provided instructions for initiating an “Appeal of Administrative Decisions” under paragraph B of LCSB Policy 2-20. After Plaintiff initiated that process, the Loudoun County School Board held a hearing on November 23, 2015, where committee members did not allow Davison to present his case or witnesses he had brought in his support and voted to uphold the No Trespass Letter. Id. ¶ 38. Plaintiff appealed that decision to the Loudoun County Circuit Court on a Petition for Judicial Review pursuant to Virginia Code § 22.1-87 on December 22, 2015. See Defendants’ Memorandum of Law in Support of Their Motion (“Defs.’ Mem. Supp.”), Ex. 50 (the “Petition”). In the Petition, Davison claimed that the No Trespass Letter violated his First and Fourteenth Amendment rights. 6

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