Trustee Dee Perry files federal §1983 civil-rights complaint against Viloria and four fellow trustees
On December 10, 2019, sitting LBUSD Trustee Dee Perry filed a federal civil-rights complaint in the U.S. District Court for the Central District of California (Southern Division, Santa Ana) as Case No. 8:19-cv-02381-DOC-JDE, captioned "Dee Perry v. Jason Viloria, Jan Vickers, Peggy Wolff, Carol Normandin, James Kelly, Members of Laguna Beach Unified School District Board, in their official capacities; and DOES 1 to 50." All five individual defendants were named in their official capacities only. The case was assigned to District Judge David O. Carter and Magistrate Judge John D. Early. Perry was represented by Michael J. Aguirre and Maria C. Severson of Aguirre & Severson LLP, San Diego. The complaint pleaded four claims: (1) Violation of First Amendment under 42 U.S.C. §1983, (2) Retaliation under 42 U.S.C. §1983, (3) Injunctive Relief for Violation of the United States Constitution, and (4) Declaratory Relief. The Prayer for Relief sought a permanent injunction restraining defendants from prohibiting Perry from speaking to constituents, participating in board meetings (open and closed), participating in district and school events, and obtaining information needed to do her job; plus a declaration of constitutional violation; plus attorney fees and costs under 42 U.S.C. §1988. Notably, the filed complaint did **not** plead monetary damages (contemporaneous Laguna Beach Independent reporting referencing "$25,000 in emotional distress" reflected the June 26, 2019 notice-of-intent letter, not the operative complaint). Jurisdiction was pleaded under 28 U.S.C. §§1331 and 1343(3)–(4); venue under §1391(b). The complaint's substantive allegations are asymmetric across the five defendants. Viloria is named in multiple individual-conduct paragraphs (¶44, ¶50, ¶52–54, ¶58, ¶69), including the alleged January 15, 2019 "You have no right to talk to staff" statement and the alleged pattern of "raising his voice at her in an aggressive manner, and then petulantly refusing to meet with her on issues of governance." Wolff is named in the individually-attributed December 21, 2018 email episode (¶55–58) and ¶59 ("Defendant Wolff's attempts to restrain speech and right to associate are in gross violation of the United States Constitution"). Vickers, Normandin, and Kelly appear only in the identification paragraphs (¶7, ¶9, ¶10) and the collective "Board majority" / "block- voted" framing; the complaint does not plead any specific individual act by any of those three beyond their votes with the majority. The court's eventual dismissal rationale ("the Board operates as an entity, and no board member has individual authority") tracks that pleading asymmetry. Perry alleged she had been on the LBUSD Board since November 2014 and was re-elected in November 2018; this is the same Dee Perry who currently sits as Board Clerk (December 2025–) and served as Board President during 2025. Named co-defendant James Kelly is a sitting trustee on the current board, though the complaint pleads no individual conduct by Kelly beyond his vote with the board majority; named Superintendent-defendant Jason Viloria is the same superintendent the post-2024 board would later terminate without cause (November 21, 2024).
People referenced
Citations (3)
- Laguna Beach Independent · 2019-12-19
Laguna Beach Independent's contemporaneous reporting on the December 2019 filing, including the June 26, 2019 notice-of-intent date and the relief sought ($25,000 in emotional-distress damages plus a restraining order).
- BoardDocs Agenda — Special Board Meeting (Closed Session), August 31, 2020 primary Laguna Beach Unified School DistrictLaguna Beach Unified School District · 2020-08-31
Confirms the federal-court case number and the four trustee co-defendants from a primary-source public agenda. The closed-session item caption verbatim: "Conference with Legal Counsel Existing Litigation (§ 54956.9) Case No. 8:19-cv-02381-DOC-(JDEx) Dee Perry v Jason Viloria, Jan Vickers, Pegg[y Wolff], et al."
- Perry v. Viloria — Complaint (Document 1, filed December 10, 2019) primary U.S. District Court, Central District of California (via CourtListener / RECAP)U.S. District Court, Central District of California (via CourtListener / RECAP) · Michael J. Aguirre, Maria C. Severson · 2019-12-10
With pronounced intolerance for any substantive merit-based dissent arbitrarily deemed to be at odds with Board demands for "unity," "fidelity" and "allegiance" to the Board, through actions of the Board majority taken with conspicuous discriminatory intent, the Superintendent and four other Board members have retaliated and discriminated against Plaintiff, and in complicity with such aforesaid discriminatory purpose, conspired against her in violation of her First Amendment rights, including freedom of speech and association, Fifth Amendment right to due process, and Fourteenth Amendment right to equal protection of law, under the United States Constitution.
Operative introductory allegation (¶3) of the Perry v. Viloria complaint as filed December 10, 2019. The complaint as a primary-source document is the canonical record of what Perry actually pleaded.