No .

_____

SUPREME COURT OF THE UNITED STATES

Irena Shie,
Petitioner
vs.
COMMONWEALTH OF PENNSYLVANIA,
Respondent

On Petition for a Writ of Certiorari to the Supreme Court of Pennsylvania

Middle District 610 MAL 2023

PETITION FOR A WRIT OF CERTIORARI

Irena Shie
Pro Se
409 Elton Farm Cir,
Glen Mills,
PA 19342
Phone: 6106180686
Email: irena.dean@gmail.com
 I. QUESTION PRESENTED
1. In light of the Fourteenth Amendment to the U.S. Constitution and the
Americans with Disabilities Act (ADA), 42 U.S.C. § 12101 et seq., which mandate
equal protection under the law and reasonable accommodations for disabilities,
did the courts in Pennsylvania violate these principles by failing to provide
necessary accommodations during judicial procedures for a petitioner with a
disclosed and documented communication disability, thereby impeding her ability
to participate meaningfully in the justice system?

2. Considering the First Amendment of the U.S. Constitution, which

safeguards the right to freedom of speech and petition the government for a
redress of grievances, and Title 42, U.S.C. § 1983, which addresses the deprivation
of constitutional rights under color of state law, did the Pennsylvania courts’
treatment of the petitioner’s efforts to seek protection from harassment by the
accuser Ms. Jones as harassment against the accuser constitute a violation of the
petitioner’s rights to free speech and petition?

Page 2 of 24
 II. LIST OF PARTIES AND RELATED CASES

A. Parties to the Proceeding

Irena Shie, Petitioner, Pro Se - The petitioner in this case, who seeks a writ of
certiorari from this Court following adverse decisions by the lower courts in
Pennsylvania. Ms. Shie is an individual with a communication disability seeking
redress for violations of her constitutional rights under the First and Fourteenth
Amendments and the Americans with Disabilities Act.
Commonwealth of Pennsylvania, Respondent - The respondent in this case,
represented by the Pennsylvania Attorney General’s Office. The Commonwealth
of Pennsylvania is involved through its courts' decisions and actions that are at
issue in this petition.
Caitlin Jones, Accuser – At this point Ms. Jones is employed by Garnet Valley
School District in Pennsylvania as an elementary school principal.

B. Related Cases

This petition for a writ of certiorari follows the final judgment issued by the
Supreme Court of Pennsylvania. The relevant lower court cases include:

Trial Court Decision - Issued by the Court of Common Pleas of Delaware County
Criminal Division, Case No. CP-23-SA-0000409-2022. This court found Ms. Shie
guilty of a summary offense of harassment.

Appellate Court Decision - Reviewed and affirmed by the Pennsylvania Superior

Court, Case No. 2971 EDA 2022. This court denied the direct appeal filed by Ms.
Shie.

State Supreme Court Denial - The Pennsylvania Supreme Court denied a hearing
on the petitioner’s appeal, Case No. 610 MAL 2023. This denial order was issued
without an opinion, effectively upholding the lower courts’ rulings.

This petition asserts that the decisions from the aforementioned cases have
collectively resulted in violations of constitutional and statutory rights warranting
review by this Court. Each of these cases is directly related to the instant petition
as they constitute the entire history of the legal proceedings relevant to this
request for certiorari.

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 III. TABLE OF CONTENTS

I. QUESTION PRESENTED .............................. Error! Bookmark not defined.

II. LIST OF PARTIES AND RELATED CASES……...…………………….…….. 3
III. TABLE OF CONTENTS…………………………………..……………………..…4
IV. INDEX OF APPENDICES…………………………………..……………………..4
V. TABLE OF AUTHORITIES…...…………………………………….…………….5
VI. OPINIONS BELOW………………………………………………………………..7
VII. JURISDICTION…………………………………………………………………….8
VII. CONSTITUTIONAL PROVISIONS INVOLVED……………………………...9
IX. STATEMENT OF THE CASE ...................................................................... 10
X. REASONS FOR GRANTING THE PETITION…..………………………...…20
XI. CONCLUSION .............................................................................................. 23

IV.INDEX OF APPENDICES

Appendix A Order of State Supreme Court Denying Review

Appendix B Decision of State Trial Court
Appendix C Psychological Report
Appendix D Article and Social Media Posts

Page 4 of 24
 V. TABLE OF AUTHORITIES

CASES

• Board of Trustees of Univ. of Alabama v. Garrett, 531 U.S. 356 (2001)

..................................................................................................................10
• Barden v. City of Sacramento, 292 F.3d 1073 (9th Cir. 2002)
...................................................................................................................19
• Olmstead v. L.C., 527 U.S. 581 (1999)
........................................................................................................13,28,31
• Pennsylvania Department of Corrections v. Yeskey, 524 U.S. 206
(1998).........................................................................................................14
• Tennessee v. Lane, 541 U.S. 509 (2004)
..........................................................................................................10,19,22
• League of Women Voters of Pennsylvania v. Commonwealth, 178 A.3d 737
(Pa. 2018) ………………………………………….………………..………….10

STATUTES

• Americans with Disabilities Act of 1990 (ADA), 42 U.S.C. §§ 12101 et

seq. ................................................................................7,9, 11,12,13,14,15,16
• Rehabilitation Act of 1973, Section 504, 29 U.S.C. § 794 ........6, 10,11,13,14
• Title 42, U.S.C. § 1983 – Civil action for deprivation of
rights...............................................................................................................2
• 28 U.S.C. § 1257(a) – Jurisdiction of the Supreme Court .......................8,11

CONSTITUTIONAL PROVISIONS

• U.S. Constitution, Amend. I ...............................................6.9.17.18.19.21,22

• U.S. Constitution, Amend. XIV, § 1 ......................................6.10.17.18.19.20

REGULATIONS

• 42 U.S.C. § 12132 – ADA Title II Provisions ......................................9,14,21

• 29 U.S.C. § 794 – Requirements under Section 504 of the Rehabilitation
Act ...............................................................................................6,10,11,14,21

OTHER AUTHORITIES

• Federal Rules of Appellate Procedure, Rule 32.1 – Citation of Judicial

Decisions, etc. ...............................................................................................11

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 No . _____

SUPREME COURT OF THE UNITED STATES

Irena Shie,
Petitioner
vs.
COMMONWEALTH OF PENNSYLVANIA,
Respondent

On Petition for a Writ of Certiorari to the Supreme Court Of Pennsylvania

Middle District 610 MAL 2023

PETITION FOR A WRIT OF CERTIORARI

Under the Americans with Disabilities Act (ADA), 42 U.S.C. § 12101 et seq., and
the Rehabilitation Act of 1973, 29 U.S.C. § 794 (Section 504), individuals with
disabilities are guaranteed the right to reasonable accommodations to ensure their
full and equal participation in public life, including judicial proceedings. Despite
this, the Supreme Court of Pennsylvania has consistently failed to provide
reasonable accommodation based on ADA for the Petitioner, Irena Shie, an
individual with an officially diagnosed autism spectrum disorder, hearing
impairment, and auditory processing disorders which significantly restrict her
ability to communicate effectively, thereby denying her the ability to participate
meaningfully in her legal defense.

Furthermore, the Petitioner's First Amendment rights have been compromised by

the Pennsylvania courts’ interpretation of her advocacy and efforts to protect her
daughter from harassment and bullying by the Ms. Jones as forms of harassment.
This interpretation not only silenced her protests against cruel treatment by Ms.
Jones, but also suppressed her efforts to obtain help and secure safety for her and
her children, who also have disabilities, and punished her for exercising her rights
to free speech and rights to live free from fears and intimidation, and rights to
petition the government for a redress of grievances as guaranteed under the U.S.
Constitution, Amendment I.

The decisions of the lower courts which overlook these critical issues of disability
discrimination and suppression of free speech raise significant constitutional
questions. These include violations of the Fourteenth Amendment’s guarantee of
equal protection under the law and the right to due process, especially given the

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non-provision of necessary reasonable accommodations based on ADA which are
mandated by federal law for individuals with disabilities.

In addition, the Petitioner contends that the mischaracterization of her actions as

harassment rather than desperate efforts and advocacy to protect her children
from abuse by Ms. Jones reflects a misunderstanding and misapplication of the
principles of justice and disability rights. This mischaracterization has resulted in
a profound injustice, not only penalizing the Petitioner for her disability but also
persecuting her for standing up against harassment by Ms. Jones and punishing
her or trying to protect her and her daughter’s rights to feel safe and live free from
fears.

Given the broad implications of this case on the rights of individuals with
disabilities in the judicial system and the precedent it sets for the interpretation
of constitutional rights, it is imperative that the Supreme Court review this
matter. The issues at hand not only affect the Petitioner but also have wider
ramifications for the rights of disabled individuals across the country to access
justice and receive fair treatment under the law. Individuals with disabilities are
prone to abuse, but the majority of them are unable to defend themselves. Abusers
like Ms. Jones take advantages of the disabled victims’ defenseless and powerless
nature and often time the abusers could walk away without consequences, like in
this instant case.

The need for a correction on this Court’s oversight is critical to uphold the
fundamental rights afforded under the United States Constitution and various
federal statutes designed to protect individuals with disabilities. This Court’s
intervention is urgently required to correct the failures of the Pennsylvania courts
and to ensure that similar violations are not perpetuated in other jurisdictions.

Therefore, the Petitioner respectfully requests that this Honorable Court grant a
writ of certiorari to review the judgment of the Pennsylvania Supreme Court in
this matter.

VI. OPINIONS BELOW

The opinions rendered by the courts below in this matter are critical to
understanding the trajectory and the judicial reasoning that led to this petition
for a writ of certiorari.

The initial appeal was made to the Pennsylvania Court of Appeals, where the
Petitioner sought direct review of the lower court's decision. The appeal was
primarily centered around the Pennsylvania courts’ failures to provide reasonable
accommodations during the legal proceedings, as required under the Americans
with Disabilities Act (ADA) and Section 504 of the Rehabilitation Act, as well as
claims of First Amendment violations. The Court of Appeals denied this appeal,
maintaining that the issues presented did not warrant a reversal or remand of the
lower court's decisions. This decision by the Pennsylvania Court of Appeals is
officially reported as Case No. 2971 EDA 2022, with an opinion issued under
Judicial Slip Opinion No. J-S36003-23. The date of this decision is not specified in
the provided details but is included in the official reports.

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Following the unfavorable outcome at the appellate level, the Petitioner advanced
her case to the Pennsylvania Supreme Court, seeking a further review and hoping
for a different interpretation or a more favorable understanding of her claims
concerning disability rights and free speech infringements. However, the
Pennsylvania Supreme Court declined to hear the Petitioner's case, effectively
upholding the appellate court's decision without additional commentary or
justification. The order denying the petition for hearing was issued on March 26,
2024. This order did not provide an opinion but merely stated the denial, which is
a common practice when the court decides not to take up a case for a detailed
review.

This final denial by the Pennsylvania Supreme Court marked the conclusion of
the Petitioner's options within the state judicial system, prompting the current
petition for a writ of certiorari to the United States Supreme Court. The details
and specifics of these lower court decisions, including the appellate court's opinion
and the supreme court's order, are crucial for the United States Supreme Court's
review. They highlight the legal and procedural context in which violations of
federal rights occurred, and they frame the issues for which the Petitioner seeks
redress.

These opinions and orders are attached in the appendix of this petition for ease of
reference and review by the Honorable Supreme Court.

VII. JURISDICTION

The jurisdiction of this Honorable Court to review the petition for a writ of
certiorari in this case is established under the provisions of 28 U.S.C. § 1257(a).
This statutory provision grants the Supreme Court of the United States authority
to review on certiorari final judgments or decrees rendered by the highest court of
a state in which a decision could be had. This review can occur where the validity
of a treaty or statute of the United States is drawn into question or where any
title, right, privilege, or immunity is claimed under the federal law.

The decision rendered by the Supreme Court of Pennsylvania is a final judgment

in this matter. There are no further avenues for review within the Commonwealth
of Pennsylvania, as the state's highest court has conclusively denied the
Petitioner’s appeal. This denial effectively terminates all state judicial proceedings
and solidifies the decision as final and binding within the state judicial hierarchy.

The Petitioner has invoked this Court's jurisdiction timely, adhering strictly to the
procedural requisites for such a petition. The petition for writ of certiorari was
filed within 90 days following the issuance of the final judgment by the
Pennsylvania Supreme Court, dated March 26, 2024. This filing respects the
stipulated period allowed under federal law, which underscores the urgency and
the procedural propriety with which this matter has been brought before this
Court.

Page 8 of 24
By these merits, this Court is called upon to exercise its jurisdiction to address
significant questions of federal law presented in the petition, specifically issues
arising under the Americans with Disabilities Act, the Rehabilitation Act, and
crucial aspects of the First and Fourteenth Amendment to the United States
Constitution, as interpreted and applied by the courts of Pennsylvania. The
resolution of these federal questions not only impacts the Petitioner directly but
also bears significant implications for the interpretation and enforcement of
federal rights more broadly. Therefore, the exercise of this Court's jurisdiction is
both appropriate and necessary to ensure that federal laws are uniformly and
correctly applied across the states, safeguarding the constitutional rights of
individuals, especially those pertaining to protected classes under disability rights
statutes.

VIII. CONSTITUTIONAL AND STATUTORY PROVISIONS INVOLVED

This petition involves significant constitutional and statutory provisions that are
essential for determining the legal issues presented. The relevant provisions
include:

1. United States Constitution, Amendment I: Congress shall make no law

respecting an establishment of religion, or prohibiting the free exercise thereof; or
abridging the freedom of speech, or of the press; or the right of the people peaceably
to assemble, and to petition the Government for a redress of grievances."

2. United States Constitution, Amendment XIV, Section 1: All persons born or

naturalized in the United States, and subject to the jurisdiction thereof, are
citizens of the United States and of the State wherein they reside. No State shall
make or enforce any law which shall abridge the privileges or immunities of
citizens of the United States; nor shall any State deprive any person of life, liberty,
or property, without due process of law; nor deny to any person within its
jurisdiction the equal protection of the laws.

3. Americans with Disabilities Act of 1990 (ADA), 42 U.S.C. §§ 12101 et seq.:

Particularly relevant are provisions concerning reasonable accommodations for
individuals with disabilities to ensure their full and equal enjoyment of all public
facilities and services (42 U.S.C. § 12132).

4. Rehabilitation Act of 1973, Section 504, 29 U.S.C. § 794(a): No otherwise

qualified individual with a disability in the United States... shall, solely by reason
of her or his disability, be excluded from the participation in, be denied the benefits

Page 9 of 24
of, or be subjected to discrimination under any program or activity receiving
Federal financial assistance.

5. In Tennessee v. Lane, 541 U.S. 509 (2004) the Supreme Court held that
Title II of the ADA applied to the administration of justice and required that
individuals with disabilities have equal access to judicial services.

6. In Olmstead v. L.C., 527 U.S. 581 (1999), The Court ruled that unnecessary
segregation of persons with disabilities constitutes discrimination in violation of
Title II of the ADA.

7. In Board of Trustees of Univ. of Alabama v. Garrett, 531 U.S. 356 (2001)

court held that while limiting some applications of the ADA, the Supreme Court
affirmed that the statute was appropriately used to prevent discrimination against
disabled persons in public services.

These constitutional and statutory provisions form the bedrock of the arguments
presented in this petition, centering on violations of the Petitioner’s rights to due
process and equal protection under the law as guaranteed by the Fourteenth
Amendment, and the right to participate in judicial proceedings without
discrimination as required by federal disability statutes. The case implicates
fundamental principles of justice and accessibility, questioning whether the state
court's actions—or lack thereof—contravened these established legal protections
by failing to provide reasonable accommodations and by misinterpreting actions
taken by a person with disabilities under distressing circumstances as constitutive
of harassment.

IX. STATEMENT OF THE CASE

I. Overview of the Case

Irena Shie, herein referred to as the 'Petitioner,' is before this Honorable Court to
challenge the judgments rendered by the state courts of Pennsylvania, which
upheld her conviction of a summary offense of harassment. This appeal stems from
a conviction entered by the Court of Common Pleas of Delaware County Criminal
Division, under case number CP-23-SA-0000409-2022, and subsequently affirmed
by the Supreme Court of Pennsylvania on October 18, 2023.

The core of the Petitioner's case revolves around her testimony of systematic
harassment against her by Ms. Jones, following the Petitioner's attempts to secure
a safe educational environment for her daughter who has multiple disabilities and

Page 10 of 24
is a crime victim. The legal proceedings leading to the Petitioner’s conviction are
contested on the grounds of significant procedural and constitutional violations,
notably the failure to accommodate the Petitioner’s disabilities during the judicial
process.

The Petitioner, diagnosed with multiple disabilities including autism spectrum

disorder, hearing impairment, and auditory processing disorders, asserts that
these conditions critically impair her ability to communicate effectively. This
appeal raises substantial questions regarding the adherence of state courts to
federal mandates under the Americans with Disabilities Act (ADA), 42 U.S.C. §
12101 et seq., and the Rehabilitation Act of 1973, 29 U.S.C. § 794, which require
reasonable accommodations to be made for individuals with disabilities.

Furthermore, this case also touches upon the First Amendment rights of the
Petitioner, arguing that her conviction was retaliatory, tied to her efforts to
advocate for her daughter’s safety in her educational environment in Garnet
Valley school district. The treatment faced by the Petitioner in the lower courts
not only raises concerns under the aforementioned disability statutes but also
implicates her constitutional rights to free speech and to petition the government
for redress of grievances. Ms. Shie is persecuted by the Pennsylvania courts for
her courage to speak up against Ms. Jones’ misconduct and cruel treatment of her
daughter.

This petition seeks to invoke the jurisdiction of this Court under 28 U.S.C. §
1257(a) to review and rectify the state courts' decisions which represent a final
judgment on matters involving significant federal questions that the state courts
have adjudicated in a manner arguably contrary to the rights and protections
afforded under federal law. The outcome of this appeal could significantly impact
the application of disability rights within the judicial system, ensuring that
individuals with disabilities are granted their rightful accommodations and
protections under the law.

II. Background of the Petitioner

Irena Shie, the Petitioner, is a resident of Glen Mills, Pennsylvania, engaged in
advocating for the educational and safety needs of her daughter within the Garnet
Valley School District. The Petitioner is a person with disabilities, diagnosed with
autism spectrum disorder, auditory processing disorders, attention-
deficit/hyperactivity disorder (ADHD), post-traumatic stress disorder (PTSD),
major depression, and anxiety disorders. These conditions significantly impact her
communication abilities and interaction with her surroundings, particularly in
high-stress environments such as legal proceedings.

The Petitioner's involvement in the instant case began as a direct result of her
efforts to ensure a safe educational environment for her daughter, and other
students with disabilities and students who are victims of crimes. Her advocacy
efforts were met with hostility and escalated into accusations of harassment by
Ms. Caitlin Jones, the principal of Garnet Valley Elementary School. These false
accusations ultimately led to the legal charges against the Petitioner.

Page 11 of 24
Throughout her legal ordeal, the Petitioner faced numerous challenges that were
compounded by her disabilities. Notably, her condition necessitates specific
reasonable communication accommodations based on ADA, such as additional
time to process verbal information and the need for written communication, which
were not consistently provided throughout the court proceedings. This lack of
accommodation led to significant misunderstandings and misrepresentations of
her actions and statements, which were critical factors leading to her conviction.

The Petitioner’s case is emblematic of the broader struggles faced by individuals

with disabilities within the legal system, where the lack of proper reasonable
accommodation results in unjust outcomes. Her appeal to this Court not only seeks
justice in her case but also aims to affirm the legal protections and
accommodations required by federal law for individuals with disabilities, ensuring
that they can participate fully and fairly in judicial processes.

In addition to her legal battle, the Petitioner has been a proactive member of her
community, advocating for disability rights, better educational practices, and safer
educational environments. Her experiences have driven her to become a vocal
supporter of reforming how schools and legal systems interact with individuals
with disabilities, particularly in contexts involving legal or disciplinary issues.

This background sets the stage for the significant legal questions presented in this
petition, revolving around the intersection of disability rights and the justice
system, and highlights the broader implications of this case for similar individuals
nationwide.

III. Factual Background and Initiation of Legal Dispute

The factual background of this case begins with the Petitioner, Irena Shie,
addressing the needs of her daughter, H.S., within the Garnet Valley School
District. H.S., a minor with diagnosed autism spectrum disorder, is a victim of a
sexual assault perpetrated by another student in the district, B.H., who was
subsequently convicted at Pennsylvania juvenile court in 2018 but continued to
attend the school in Garnet Valley school district.

In response to this situation, in 2018 the Petitioner approached school

administrators to seek measures to ensure H.S.'s and other female students’ safety
at school because sexual offense tend to be repeat the offense. The response from
the administration, particularly from Ms. Jones, the principal, was not only
dismissive but also hostile. Ms. Jones poked fun of sexual assault, and put the
blame on the victim, gaslighted the victim by suggesting that the assault never
happened, and refused to separate the offender from the victim at school despite
separation between victim and offender is required by Pennsylvania law. Ms.
Jones and the district superintendent Mr. Marc Bertrando have been overly
protective of B.H. for private reasons because they are inappropriately friendly
with B.H.’s parents. The administrators’ refusal to take safety measures again
B.H. has resulted in further sexual assaults by B.H. against at least five other
female students between 2018 and 2023, and some assaults occurred at school
setting. However, to this day, B.H. continues to enjoy his privileges in Garnet

Page 12 of 24
Valley School District guaranteed by Mr. Bertrando and Ms. Jones who abuse
their power on regular basis and run the school as if it is their own private business
using tax payers money and blatantly ignore the pain and suffering of B.H’s
victims who have to live in fears in the school district every single day. The victims’
trauma and humiliation from the sexual assaults are lifelong, and at least two of
the victims have attempted suicide due to the trauma from the sexual assaults by
B.H. These young girls’ lives will never be the same. The sexual assaults that occur
in Garnet Valley School District are preventable if only the district administrators
do not favor a sexual offender over students’ safety and maliciously paint advocacy
as harassment. The administrators play around with the law and rules for their
own personal gain. Ms. Jones and the administrators of Garnet Valley School
District have a long history of abusing the systems. For example, they regularly
call the Child Protective Service on parents who file lawsuits against them, and
all the time, the parents are innocent, and no child abuse is found as described in
Appendix D. In this instant case, Ms. Jones abused the justice system to satisfy
her ego and for personal financial benefits. It is about time to finally hold Ms.
Jones and the administrators of the school district accountable for their long
history of power abuse, child abuse and child endangerment.

Petitioner’s advocacy for protection of female students in Garnet Valley School

District so far only ignited harassment against Petitioner by district
administrators, particularly Ms. Jones. Per court order, B.H. is not allowed to
attend any school events when one or more of the Petitioner’s family members are
present in the events. To diminish B.H.’s disadvantages and allow B.H. to attend
school events freely, Ms. Jones issued a counter rule to prohibit the Petitioner from
getting into the school grounds.

Ms. Jones’ hostility escalated when the Petitioner requested reasonable

accommodations for her daughter’s disabilities during physical education classes,
as well as for herself as parent to communicate with the school, given her own
disabilities which severely affect communication. These accommodations were
necessary to ensure compliance with the Americans with Disabilities Act (ADA)
and the Rehabilitation Act of 1973. Despite disclosing her conditions and
requesting reasonable accommodations, the Petitioner was met with resistance,
non-compliance and demeaning attitudes by Ms. Jones. Petitioner requested
communication in writing via emails exchanges due to hearing impairment, and
if the school cannot agree to communication in writing, Petitioner requested to
have a discussion with the school to determine an alternative communication
method to enable Petitioner to participate in her daughter’s education. The school
never refused to communicate in writing, however, Ms. Jones falsely claims that
Petitioner was harassing her by communicating in writing through emails, despite
none of the emails were addressed to Ms. Jones privately and the contents of the
emails were mostly desperate screams for help in Petitioner’s attempts to find
someone who is able to see through Ms. Jones’ manipulation and deception, and
have integrity and courage to stop Ms. Jones from harassing and bullying
Petitioner and her daughter. Ms. Jones’ unceasing and escalating harassment
gradually become more and more dangerous and could result in fatality in which
Petitioner’s daughter might eventually commit suicide. Petitioner and family only
wanted to live our own lives and find care to help with our disabilities, however,
Ms. Jones would not leave us alone. Tragically, the one and only reason Ms. Jones

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refuses to leave Petitioner’s family alone is nothing other than Ms. Jones’ ego and
delusions. Ms. Jones delusionally thought that Petitioner wanted to sue the school
and harm her, and created a delusional story about Petitioner being dissatisfied
toward her because her inflated ego does not allow her to admit that parents are
annoyed by her misconducts as described in Appendix D. Ms. Jones lied to law
enforcement on multiple occasions. Being a pathological liar who lies every time
she opens her mouth, Ms. Jones has been able to deceive and manipulate various
people from the school board to Pennsylvania state courts, and even the
Pennsylvania State Police are powerless against her abuse, manipulation and
deception.
• Under the ADA, individuals with disabilities are entitled to reasonable
accommodations that allow them to participate fully and equally in public
life. Failure to provide such accommodations can be seen as discrimination
(42 U.S.C. § 12132).
• Section 504 of the Rehabilitation Act of 1973 prohibits discrimination based
on disability in any program or activity receiving Federal financial
assistance (29 U.S.C. § 794(a)).
• In cases such as Pennsylvania Department of Corrections v. Yeskey (524
U.S. 206), the Supreme Court has interpreted ADA provisions broadly,
affirming that they apply to all areas of public life, reinforcing that the lack
of accommodations in judicial and educational settings can constitute
discrimination.

The legal dispute began when the Petitioner, after repeated failed attempts to
secure a safe environment for her daughter at the school and cease the ongoing
harassment from Ms. Jones, resorted to formal complaints by Petitioner against
Ms. Jones with the school district in March 2021, and later with the Pennsylvania
Department of Education in June 2021. However, these complaints only escalated
the harassment by Ms. Jones against the Petitioner and her daughter, H.S who
started struggling during physical education (PE) classes at that time because she
is unable to perform certain tasks that normal children could do easily due to her
disability such as throwing and catching a ball. Multiple medical and mental
health professionals urged Ms. Jones to provide accommodation or excuse H.S.
from PE class, which was all blatantly ignored by Ms. Jones. Instead, Ms. Jones
put H.S. on the stage during PE classes to humiliate H.S. and for all her
classmates to see that H.S. is not able to perform simple tasks. This bullying by
Ms. Jones eventually pushed H.S. to severe emotional distress and H.S. started
cutting herself. When the Petitioner asked Ms. Jones to have a discussion on H.S.
struggles, Ms. Jones became angry. Because Ms. Jones had said that H.S.’ issue
was merely anxiety, Ms. Jones was offended when mental health professionals
pointed out that it was much more serious than anxiety. It was autism spectrum
disorders and physical deformity that made H.S. struggle in PE classes. Therefore,
no matter how cruelly H.S. was bullied by Ms. Jones, H.S. and Petitioner were
unable to change the situation. Ms. Jones increasingly became more and more
angry because her fragile vulnerable ego and her false sense of grandiosity were
severely hurt when H.S. continued to have disabilities and was unable to attend
PE classes due to severe emotional distresses. Ms. Jones only saw this as rebellion
and offense against her, and started to fabricate the stories about she was being
harassed by Petitioner because Petitioner was dissatisfied with her “decision” that
in reality she had never made. This is one of her enormous amounts of twisted and

Page 14 of 24
distorted reality created by Ms. Jones. A child cannot stop having a disability just
because Ms. Jones says there is no disability. H.S. went through assessments and
the professionals officially diagnosed her with autism spectrum disorders and
physical deformity. However, Ms. Jones’ inflated ego and her craving for
admiration do not allow her to admit that she was completely wrong, therefore she
only sees H.S.’ diagnosis as a dissatisfaction toward her. She went extra length to
alter diagnosis by reaching out to mental health professionals to slander Petitioner
and tell them that Petitioner fabricated H.S. symptoms in order to maliciously sue
the school for financial gain. Ms. Jones could not care at all that by preventing
disabled student from receiving care and treatment, she put the student in danger.

Subsequently the Petitioner filed a complaint with the Office of Dispute

Resolution, which oversees special education matters in Pennsylvania to seek
help, but this again resulted in Ms. Jones’ outburst of rage. Ms. Jones began
stalking the Petitioner and reached out to Petitioner private medical and mental
health professionals to prevent the professionals from providing correct diagnosis
and treatment. This is the actual core issue of this instant case. It is not about the
Petitioner’s dissatisfaction toward Ms. Jones. This case is about Petitioner’s efforts
to stop Ms. Jones’ harmful and dangerous behaviors against children with
disability.

It is not exaggerated to say that Ms. Jones attempted to murder H.S. who was
suicidal at that time when Ms. Jones reached out to Delaware County Crisis
Connection Service to tell them that Petitioner fabricated H.S. suicidal ideation
and mental health issues in order to sue the school, and Ms. Jones successfully
blocked the desperately needed help and support from various institutions just
because it hurt Ms. Jones’ ego that H.S, was suicidal due to bullying by Ms. Jones
in PE classes. Ms .Jones also does not want to get sued by parents based on her
misconducts ( See first screenshot on Exhibit D) , but at the same time she refuses
to follow the education law and to do her works correctly. Ms. Jones has no
understanding that mental health care is important, and she would choose at any
time to see students committing suicide rather than admitting her selfish actions
and gross negligence where she deliberately blocked private mental health
services paid by parents outside the school from students. In total, Ms. Jones and
her flying monkeys which include the troopers from Pennsylvania State Police
were able to compromise about twenty Petitioner’s private medical and mental
health professionals with her delusional fabricated stories that Petitioner seeks
medical and mental health care because Petitioner was angry at Ms. Jones and
want to sue the school. This false accusation is not only completely baseless, but
also harmful and dangerous. Furthermore, Ms. Jones fabricated stories about
suicidal students based on her delusions. In her false claim, the parents of the
suicidal students fabricate suicidality to threaten Ms. Jones in order to get
services. This claim shows Ms. Jones’ false sense of grandiosity. She even twisted
serious issues such as suicide to shift attention from the students who desperately
need help to herself because she craves admiration and attention. It is an act of
true evil that Ms. Jones prevents suicidal students who have disabilities and
mental health issues from receiving correct diagnosis and care. Additionally, it is
an act of true cowardice that Ms. Jones denies what she definitely did, then smears
and persecutes the parents for exposing her behavior. It is hard to believe a
principal of a school would do such horrible conducts because these conducts are

Page 15 of 24
far from a normal behavior of a principal of a school, but Ms. Jones truly did all
those things described in the above lines and paragraphs. The psychology report
attached on Appendix C explains why Ms. Jones’ behaviors are so unbelievable.
Additionally, Ms. Jones manipulates the justice system to avoid prosecution and
to persecute parents who stand up against her. "Flying monkeys" is used in
psychology to describe people who enable or perform tasks for an abusive person.
A number of parents sued Garnet Valley School district and Ms. Jones due to their
misconduct as educators, however, Ms. Jones has been able to twist the truth and
paint people who sued her as malicious and hungry for financial gain, which is
untrue. It hurts Ms. Jones’ inflated ego when parents complain about her
misconduct and lack of knowledge in special education matters. Ms. Jones would
go to extra length to punish anyone who dares to speak up or correct her.

The situation deteriorated when Ms. Jones falsely accused the Petitioner of
harassment — a claim stemming from the Petitioner’s desperate advocacy for her
daughter's rights and safety.

These false accusations led to legal charges against the Petitioner, maliciously
framed by Ms. Jones’s portrayal of the Petitioner's advocacy as harassment. The
subsequent trial, where the Petitioner was convicted of harassment, did not
adequately accommodate the Petitioner's communication disabilities, leading to
significant procedural and substantive issues. This conviction is what the
Petitioner now seeks to overturn, arguing that her actions were mischaracterized
due to a lack of appropriate accommodations and a fundamental
misunderstanding of her disability-related communication methods.

Additionally, the Pennsylvania trial court and appeal courts based their
judgement solely on lies, false and delusional testimony by Ms. Jones. As described
in the forensic psychology evaluation report attached, Ms. Jones is diagnosed with
narcissistic personality disorders and psychotic delusional disorders. On one
occasion, Ms. Jones panicked about a personal alarm that she thought was a
weapon to murder people. Personal alarm is a mini-sized device that makes a loud
noise if the carrier pushes its button in case of emergency. A personal alarm is not
a weapon and does not have the capacity to murder anyone. On other occasions,
Ms. Jones made a false report that she saw Petitioner lingering at school and
staring at her. Ms. Jones does not know that the Petitioner suffers from face
blindness and to this day Petitioner does not know how Ms. Jones’ face looks like
therefore it is obviously a lie that she saw Petitioner lingering at school and staring
at her. On another occasion, Ms. Jones made delusional claims that Petitioner
wanted to attack the school when Petitioner asked Ms. Jones to stop blocking
diagnosis and mental health care for suicidal students because her behavior could
eventually result in children committing suicide. However, despite her claims
about Petitioner are all false and delusional, Ms. Jones has been able to deceive
and manipulate various systems, from the members of Garnet Valley school
district school board, Pennsylvania State Police to Pennsylvania state courts
through her countless of lies, delusions and hallucinations. Needless to say, it is
possible that Ms. Jones believes her own lies due to her delusional disorders as
described in Appendix C.

Page 16 of 24
Ms. Jones has been able to take advantage of Petitioner’s severe communication
disability to twist Petitioner’s emails and efforts to secure safety for the students
as merely dissatisfaction toward her. This claim shows Ms. Jones’ inflated ago,
delusions, and distorted reality. Petitioner and a number of other parents are
annoyed and alerted by Ms. Jones’ constant lies, misconducts, inappropriate and
sometimes dangerous behaviors as a principal. As described above, Ms. Jones and
the administrators of Garnet Valley School District are experts in power abuse
ignoring and sacrificing the safety of their students for their own private reasons
and personal gain. They deceive and manipulate others without pain or shame. It
is not exaggerated to say that Ms. Jones would murder students if it meant she
would secure her salary and position, therefore Ms. Jones needs to be monitored
and restrained such as in restraining order in order to protect students from her
malicious and harmful behaviors.

Unable to get help from the police and other organizations, Petitioner made
desperate posts on social media to seek help and alert others of what is actually
going on in Garnet Valley School District. There have been too many victims of the
selfish, reckless and irresponsible behaviors by Ms. Jones and the administrators
of Garnet Valley School District. This has to stop. Someone has to take action to
stop this, but the Pennsylvania State Police and the Pennsylvania state courts are
compromised either willingly or unaware that they are being maliciously
manipulated by the Ms. Jones and the administrators of the school district.

This case highlights the critical intersection of disability rights and legal
processes, illustrating how misunderstandings and prejudices about disabilities
can lead to wrongful convictions. It raises significant questions about the justice
system’s capacity to adapt to and accommodate individuals with unique
communication and processing methods, as mandated by law. The failure to
provide such accommodations not only affects the fairness of the trial but also
undermines the integrity of the judicial process, potentially violating
constitutional rights under the Fourteenth Amendment to due process and equal
protection.

IV. Legal Challenges and Disability Discrimination

The core legal challenges in this case revolve around systemic failures to
accommodate disabilities, both in educational and judicial contexts, resulting in
discrimination, a denial of due process and equal protection under the law and a
false conviction. These challenges are not isolated incidents but reflect a broader
pattern of disregard for the statutory and constitutional rights of individuals with
disabilities.
Specific Legal Challenges

• Violation of the Americans with Disabilities Act (ADA) and Section 504 of
the Rehabilitation Act: The GVSD and its administrators, including Ms.
Jones, failed to provide reasonable accommodations to both H.S. and the
Petitioner. This failure extends to the refusal to modify communication
methods and provide a safe educational environment free from fears,
bullying, harassment and intimidation, directly impeding the Petitioner's

Page 17 of 24
 ability to advocate for her daughter and participate in her education
effectively.
• Discriminatory Retaliation: The Petitioner faced retaliation in response to
her advocacy for disability accommodations for her daughter, which is
prohibited under the ADA (42 U.S.C. § 12203). The actions taken by the
school administrators culminated in criminal charges against the
Petitioner, fundamentally based on her disability-related advocacy.
• Denial of Due Process: During the legal proceedings that followed the
school's accusations, the Petitioner's disability was not accommodated,
violating her right to a fair trial as guaranteed by the Fourteenth
Amendment. The lack of reasonable accommodation impeded her ability to
communicate effectively and defend herself, raising substantial concerns
about the validity of the legal process and outcome.
• False Testimony: This instant case is based solely on Ms. Jones’ false and
twisted testimonies. Ms. Jones is delusional and a pathological liar. Ms.
Jones even lied under oath at the trial court with her delusional and false
testimonies such as Petitioner’s lingering at school, sending her twenty
emails in a short time, calling her names. She deliberately misled the court
such as Petitioner is dissatisfied with her decision even though Ms. Jones
knows exactly that the truth is Petitioner was annoyed by her constant
harassment, discrimination, disregard for student safety and unwanted
interferences in family private medical and mental health care despite
multiple cease and decease letters issued against Ms. Jones to stop her
reckless and harmful behaviors. Ms. Jones’ selfish actions create fears for
the safety of Petitioner’s family and make it impossible for disabled
children, H.S. and her brother to get mental and medical help and support.
Ms. Jones and Mr. Bertrando abuse their power as school officials to prevent
adults and children with disabilities receiving correct diagnosis, care and
treatment in order to avoid penalty for their violation of Individual with
Disability Education Acts that oblige the school to discover and provide
services and accommodations to students with disability. Just like they
sacrifice the safety of female students in Garnet Valley School District to
favor a sexual offender B.H., they also sacrifice students with disability to
favor high salary for themselves, unnecessary sports and theater events at
the school district to boost their reputation.
• Malicious Prosecution: Malicious prosecution is a particularly egregious
legal wrong, one that occurs when one party initiates a baseless legal action
against another with the intent of using the legal system to oppress or
harass. In this case, the accuser, Ms. Jones, has employed such tactics,
fabricated stories and manipulating the judicial process to retaliate against
the Petitioner for lawfully advocating for her daughter's rights and safety.
This misuse of the judicial system not only undermines the integrity of the
legal process but also highlights a severe abuse of judicial resources to
persecute the Petitioner unjustly. This action is particularly reprehensible
as it targets the Petitioner’s disabilities, exacerbating the challenges she
faces and impeding her ability to defend herself effectively. Such conduct
not only violates the principles of justice and equity enshrined in the
Fourteenth Amendment and the Americans with Disabilities Act but also
exposes the systemic failures in protecting the rights of individuals with
disabilities within the legal system.

Page 18 of 24
 • Lack of Legal Representation : Due to communication difficulties,
oftentimes even their own defense attorneys think autistic defendants are
guilty even though they are innocent. Petitioner had to fire several
attorneys ,including attorney Vincent Caputo, throughout this process due
to communication issues and their unwillingness to fight against a school
district. Petitioner is hearing impaired and has hard time communicating
orally especially over the phone. Attorney Caputo lied to harm this case
when he mentioned that Petitioner continued calling him after he
withdrew. Without assistance from an appropriate adult, it is nearly
impossible for autistic individuals to access justice due to their severe
difficulties in communicating which is the hallmark of autism spectrum
disorders.
• Tennessee v. Lane (541 U.S. 509 (2004)): The U.S. Supreme Court
recognized that individuals with disabilities must have access to public
facilities and services, including courts, on an equal basis with others,
emphasizing that states must comply with the ADA to ensure public
services are accessible.
• Barden v. City of Sacramento (292 F.3d 1073 (9th Cir. 2002)): This case
affirmed that public entities must take necessary steps to ensure that
individuals with disabilities are not excluded, denied services, or otherwise
treated differently than other individuals because of the absence of
auxiliary aids and services.

The legal challenges presented by this case highlight critical issues in the
enforcement of disability rights laws. They underscore the need for:

• Enhanced awareness and training regarding disability rights within Garnet

Valley school district.
• Judicial acknowledgment and correction of the systemic biases and
procedural barriers that prevent fair treatment in the legal system for
individuals with disabilities.
• A reevaluation of policies and practices that currently allow for
discriminatory practices and retaliatory actions against individuals
advocating for rights under the ADA and Section 504.

IV. Appeal and Need for Certiorari

A. Grounds for Appeal: The appeal to the United States Supreme Court is
predicated on significant questions regarding the interpretation and
application of federal laws concerning disability rights and the procedural due
process guarantees provided under the Fourteenth Amendment. The
Petitioner contends that the decisions made by lower courts, and the actions
of the educational institution involved, have resulted in grave miscarriages of
justice that necessitate review and rectification by this Court.

. B. Legal Basis for Certiorari

• The case presents substantial questions regarding the application of the

Americans with Disabilities Act (ADA) and Section 504 of the
Rehabilitation Act, particularly in the context of educational and judicial
accommodations for individuals with disabilities.

Page 19 of 24
 • Lower court decisions conflict with Supreme Court precedents such as
Olmstead v. L.C. (527 U.S. 581), which emphasized the right of individuals
with disabilities to live in the community and receive services in the most
integrated setting appropriate to their needs, and Tennessee v. Lane, which
highlighted the necessity of access to judicial processes for disabled
individuals.
• There is a pressing need for uniform national standards in how educational
institutions and courts accommodate individuals with disabilities,
especially in legal settings. The inconsistency in handling these
accommodations poses a significant risk of unequal treatment across
jurisdictions.

C. Need for Review by the Supreme Court

1. This case represents a critical test of the judiciary's commitment to

protecting the rights of the most vulnerable members of society, ensuring
that individuals with disabilities receive equal protection under the law as
guaranteed by the Fourteenth Amendment.
2. Effective enforcement of the ADA and Section 504 is crucial for upholding
the rights of individuals with disabilities. This case provides the Court an
opportunity to reinforce the standards for compliance with these important
legal protections.
3. The Supreme Court's intervention is necessary to clarify the obligations of
public entities under the ADA and Section 504, particularly regarding what
constitutes "reasonable accommodations" in both educational and judicial
contexts.

D. Implications of Denial of Certiorari

Denial of certiorari would not only leave in place the lower court's rulings that
misapply federal disability rights laws but also perpetuate the existing disparities
in how these laws are enforced across the country. Such an outcome could
undermine public confidence in the legal system's ability to equitably protect the
rights of disabled individuals and could lead to a broader erosion of these rights.

The issues raised in this petition are of profound importance not only to the
Petitioner but to the millions of Americans living with disabilities. The principles
at stake—access to education, fair treatment in judicial proceedings, and the
fundamental rights to due process and equal protection—are cornerstone
guarantees of American law. As such, this Court's review is essential to ensure
these principles are upheld and that the protections intended by the ADA and
Section 504 are fully realized. The Petitioner respectfully urges the Court to grant
certiorari to address these urgent and significant legal questions.

X. REASONS FOR GRANTING THE PETITION

A. Ensuring Compliance with the ADA and Section 504

The petitioner's experiences underscore a troubling disregard for the rights

guaranteed under the Americans with Disabilities Act (ADA) and Section 504 of
the Rehabilitation Act. These laws are pivotal in ensuring that individuals with

Page 20 of 24
disabilities receive reasonable accommodation necessary to fully participate in all
aspects of society, including the judicial process. The lower courts' failure to
properly apply these protections has broader implications, suggesting a potential
systemic issue in the enforcement of disability rights within judicial and
educational institutions.

Legal Precedents and Provisions:

• ADA Title II mandates that "no qualified individual with a disability shall,
by reason of such disability, be excluded from participation in or be denied
the benefits of services, programs, or activities of a public entity, or be
subjected to discrimination by any such entity" (42 U.S.C. § 12132).
• Section 504 states that any program receiving federal assistance must
ensure that the needs of persons with disabilities are met as adequately as
the needs of the non-disabled (29 U.S.C. § 794).
• In Olmstead v. L.C., the Supreme Court held that unjustified segregation
of persons with disabilities constitutes discrimination in violation of Title II
of the ADA.

The petitioner’s case presents a clear scenario where these legal standards were
not met, warranting a review to reinforce and clarify the application of these
crucial laws.

B. Protection of Constitutional Rights

This case also presents significant constitutional questions under the Fourteenth
Amendment, which guarantees due process and equal protection under the law.
The petitioner’s inability to participate meaningfully in her defense due to
inadequate accommodation directly challenges her rights to a fair trial and to
access the court on equal terms with other citizens.

Constitutional Framework:

• The suppression of the Petitioner's First Amendment rights forms a critical

basis for granting this petition. The accuser's mischaracterization of the
Petitioner's lawful advocacy and reporting of misconduct as harassment
egregiously infringes upon her freedom of speech. The Petitioner utilized
social media platforms to seek community support and legal aid, a modern
means of petitioning for redress of grievances, which is a fundamental right
protected by the First Amendment. However, these efforts were also
maliciously twisted as acts of harassment by Ms. Jones, further
demonstrating a calculated attempt to silence, punish and maliciously
prosecute the Petitioner for utilizing her constitutional rights. This twisting
of legitimate exercises of free speech into allegations of harassment not only
undermines the democratic values of freedom of expression and advocacy
but also highlights the urgent need for this Court's intervention to reaffirm
and protect these fundamental rights, particularly for individuals in
vulnerable positions.
The safety of the children in Garnet Valley School District is at stake, but
the Pennsylvania State Police and state courts are impotent toward this

Page 21 of 24
 school district. There is an urgent need for the federal government to
intervene to ensure students’ safety in this district.
• The Fourteenth Amendment is critical in safeguarding the rights of all
citizens, especially those belonging to vulnerable populations, against
unfair or discriminatory treatment by state entities.
• Supreme Court precedent in Tennessee v. Lane recognized the importance
of ensuring access to court services for individuals with disabilities, aligning
with the fundamental principles of due process and equal protection.

C. Promoting Uniformity in the Law

The discrepancies in how lower courts handle ADA and Section 504 requirements
suggest a lack of uniformity that can lead to unequal treatment of disabled
individuals across different jurisdictions. The Supreme Court’s intervention is
necessary to establish clear, consistent guidelines for what constitutes reasonable
accommodations, particularly in educational settings and judicial proceedings.

Need for Supreme Court Guidance:

• Uniform standards are essential to prevent a postcode lottery where the

rights and accommodations an individual receives depend heavily on
geographical location or the specific court in which a case is heard.
• Clear guidance from the Supreme Court would help lower courts more
effectively implement ADA and Section 504 provisions, ensuring fair and
equal treatment across the board.

D. Addressing a Matter of Broad Public Importance

The issues at stake in this petition transcend the immediate interests of the
parties involved and touch upon the fundamental rights of an entire class of
citizens. Ensuring that individuals with disabilities can access public services and
legal protections without discrimination is a matter of broad public importance.

Broader Implications:

• This case serves as a vital benchmark for the rights of disabled individuals
in the U.S., potentially impacting millions of people.
• It offers the Supreme Court an opportunity to make a profound and positive
impact on the lives of those living with disabilities by affirming their rights
and the government’s obligations under the ADA and Section 504.

Given the significant legal questions raised, the potential for broad impact on
national disability rights law, and the need to ensure that constitutional
guarantees are upheld, this petition for a writ of certiorari should be granted. The
Supreme Court has both an opportunity and an obligation to rectify the issues
presented, ensuring justice not only for the petitioner but for all individuals with
disabilities facing similar challenges.

Page 22 of 24
 XI. CONCLUSION

This petition for a writ of certiorari comes before this Honorable Court not merely
as a redress for an individual grievance but as a pivotal opportunity to reaffirm
and enforce the fundamental rights and protections afforded under the United
States Constitution and statutory law to individuals with disabilities. The
experiences of the Petitioner, Irena Shie, expose a critical gap in the enforcement
and application of the Americans with Disabilities Act (ADA) and Section 504 of
the Rehabilitation Act, underscoring a systemic issue that affects the broader
disabled community’s access to justice and education.

The failure of the Pennsylvania courts to provide necessary accommodations—

despite clear, repeated requests and an undeniable need—represents a breach of
both statutory mandates and constitutional guarantees. This failure has not only
undermined the Petitioner’s ability to participate fully in her defense but also
signals a disturbing disregard for the rights of individuals with disabilities, setting
a precedent that could lead to further inequities.

The broader implications of this case cannot be overstated. Each day that these
issues remain unaddressed is a day that justice is denied not only to the Petitioner
but to all similar individuals who might feel the chilling effect of a system that
does not adapt to accommodate their needs. The Supreme Court’s guidance is
urgently needed to ensure consistent and fair application of the ADA and Section
504 across all jurisdictions, thus preventing a patchwork of rights and
accommodations that varies from one state to another.

By granting this writ of certiorari, this Court has the opportunity to make a
substantial and positive impact on the lives of millions of Americans with
disabilities, reaffirming their rights and the nation’s commitment to ensuring
equal access to justice for all its citizens, regardless of their physical or mental
challenges. Therefore, we respectfully urge the Court to grant this petition,
thereby reinforcing the importance of accessibility, equality, and justice in every
aspect of American life.

Respectfully Submitted:

Irena Shie
June 1, 2024

Page 23 of 24
PROOF OF SERVICE
I, Irena Shie, hereby certify that I am over the age of eighteen years and not a
party to the within action; my address is 409 Elton Farm Cir, Glen Mills, PA
19342. On June 5, 2024, I served the foregoing document described as PETITION
FOR A WRIT OF CERTIORARI on the interested parties in this action by placing
a true copy thereof, enclosed in a sealed envelope addressed as follows:

List of Recipients:

1. Clerk of the Court Supreme Court of the United States 1 First Street, NE
Washington, D.C. 20543
2. Attorney General of Pennsylvania Office of the Attorney General,
Pennsylvania Office of Attorney General Strawberry Square, Harrisburg,
PA 17120

Method of Service:

• I caused such envelope with postage thereon fully prepaid to be placed in

the United States mail at Glen Mills USPS, 142 Glen Mills Rd, Glen Mills,
PA 19342. Each envelope was mailed with postage thereon fully prepaid
online on USPS website on July 4th, 2024.

I declare under penalty of perjury under the laws of the United States that the
above is true and correct and that this declaration was executed on June 5, 2024.

Respectfully submitted:

Irena Shie,

Page 24 of 24
 APPENDIX C
Psychological Report
 Psychological Assessment Report

CASE: False Accusations of Harassment by Caitlin Jones against

Irena Shie

To Whom It May Concern

I, Manzer Imam, a licensed forensic psychologist, have conducted an in-depth comprehensive

psychological assessment of Catlin Jones," in relation to the case involving allegations of harassment
and false accusations made by her. The purpose of this report is to provide an objective evaluation of
the mental state of Caitlin Jones and to present evidence indicating potential mental health issues,
specifically narcissistic personality disorders with psychopathic features and psychotic disorder.

I. Introduction
Irena Shie has sought my expertise in evaluating the behavior and mental state of Caitlin Jones, who
has been accused of creating false narratives of harassment against Irena Shie. This report presents the
findings of my assessment based on the information provided and my clinical expertise.
II. Diagnosis:
1. Narcissistic Personality Disorder(NPD) with psychopathic features
2. Psychotic (Delusional) Disorder
Narcissistic Personality Disorder (NPD) with psychopathic features Overview: Narcissistic
Personality Disorder is a mental health condition characterized by a persistent pattern of exaggerated
feelings of self-importance, an excessive need for admiration, socially irresponsible, exploitative, and
guiltless behavior. Individuals with NPD often engage in manipulative behaviors, including chronic
lying, denial of own actions, projection, and gaslighting, exploiting, or violating the rights of others
without any remorse. This behavior causes harm to others and is often criminal.
Psychotic (Delusional) Disorder Overview: Delusional (psychotic) disorder involves having one or
more false beliefs, or delusions, for at least one month. Delusions are based on an incorrect
interpretation of reality and are unshakable, even when presented with evidence to the contrary.

III. Evidence of NPD and Psychotic Disorder in Caitlin Jones

Pathologically Lying and Denial of Own Actions: Caitlin Jones consistently fabricates stories and
denies her own actions, even when presented with concrete evidence contradicting her claims.
Projection and Gaslighting: Caitlin projects her own unacceptable and criminal behaviors onto the
victim Irena Shie, such as harassing and threatening others; and engages in gaslighting tactics to
create confusion and doubt.
Delusional Grandiosity: Despite lacking authority, Caitlin delusionally believes in her power to
control situations and accuses others of being angry or unhappy due to her decisions.
Violating and harming others without remorse: Caitlin repeatedly reached out to mental health
professionals and medical doctors in order to prevent disabled students from receiving correct diagnosis
and mental health care.
Aggressions: Even though Caitlin was told multiple times that preventing suicidal individuals from
receiving help is a murder, she would not her dangerous and abusive behaviors. It is appropriate to say that
Caitlin needs to be monitored and restrained to stop her efforts to murder people.
Delusional Persecutory: People with this type of delusional disorder believe someone or something is
mistreating, spying on or attempting to harm them (or someone close to them). People with this type of
delusion may make repeated complaints to legal authorities. Caitlin Jones believes that she was treated
unfairly when Irena filed complaints about her behavior, and she even believes that Irena Shie was
threatening her even though Irena only told her to stop her dangerous, harmful and abusive behaviors.
Hallucinations: Caitlin Jones reported that she saw Irena Shie lingering in the school’s parking lot for
an extended period of time even though this never happened. Caitlin also reported that Irena was staring
at her even though this is not possible because Irena suffers from face blindness.

The Needs to be Right all the Time: Caitlin could not accept that she was wrong about a student's
disabilities and mental health issues therefore she reached out to this student's private mental health
providers to alter diagnosis and mental health treatment in order to prove she was right. This student
is Irena Shie's daughter.

Anger Issues:
Caitlin’s ego was bruised when Irena filed a complaint with the Pennsylvania Department of Education.
Caitlin vengefully lashed out with rage by smearing Irena with multiple false narratives, smear
campaigns and accusations to humiliate Irena.

Manipulative and deceitful: Caitlin has been able to manipulate and deceive the Pennsylvania State
Police, the Delaware County Court of Common Pleas, Pennsylvania Superior and Supreme Court with
false accusations against Irena Shie based solely on her psychotic delusions and hallucinations.

IV. Legal Implications

Impact on Children and Potential Child Abuse: Caitlin's abusive behavior has negatively affected
children's mental health care, potentially constituting child abuse due to her inability to empathize and
provide appropriate care.
Violations of the Law: Caitlin Jones's actions may have violated laws related to providing services to
eligible children, warranting legal consequences.
Potential for Legal Action: Given the substantial evidence of misconduct, legal action against
Caitlin Jones is justifiable and necessary.

V. Concerns regarding Caitlin Jones's Mental State

Delusions and Potential for Endangering Others: Caitlin Jones's delusional thoughts, including
fantasies of mass murder, are deeply concerning and pose a risk of dangers to others. These delusions
must be addressed promptly.
Risk of Harming Others: Her false accusations and delusional thinking raise concerns about
the potential that Caitlin will eventually harm others physically on top of psychologically,
especially considering her projections of violence onto others.

VI. Conclusion
In conclusion, based on the evidence presented and my professional evaluation, it is my expert opinion
that it is accurate that Caitlin Jones exhibits traits consistent with narcissistic personality disorder
(NPD) comorbid with psychotic disorders. Her behaviors, including pathological lying, aggressions
without remorse, denial of her own actions, projection, anger issues, gaslighting, delusional grandiosity
and delusional persecutory are indicative of this disorder.
Furthermore, her delusions, including thoughts of mass murder, necessitate immediate attention and
intervention from mental health professionals and appropriate authorities.
It is my professional recommendation that Caitlin Jones undergo a thorough psychiatric evaluation
to determine the extent of her mental health condition. Additionally, given the potential risks
associated with her delusional thinking, appropriate legal measures and safeguards should be put in
place to protect the safety and well-being of others.

Please feel free to contact me if you have any questions or require additional information.

May 26, 2024

Sincerely,

MANZAR IMAM
(Forensic Psychologist)
manzarimam1300@gmail.com
 APPENDIX D
Article and Social Media Posts
 Rated by SuperLawyers™ 2014 - 2023 ×

GVSD Found to Have Violated Cheerleader's

Civil Rights and FAPE Standards Due to
Mismanagement of Her Health Needs

ANOTHER LEG AL DEFEAT FOR G ARNET VALLEY SCHOOL DISTRICT - FOUND TO HAVE
VIOLATED CHEERLEADER'S CIVIL RIGHTS AND FAPE STANDARDS DUE TO

M I S M A N A G E M E N T O F H E R H E A LT H N E E D S

FOR IMMEDIATE RELEASE

Glen Mills, PA – November 12, 2023

The Garnet Valley School District has been found in

violation of the rights of a student, Kyndal, who
suffers from juvenile idiopathic arthritis (JIA) and
related disabilities.

A recent decision by Special Education Hearing

Officer Joy Waters Fleming, Esq., established that
the district failed to provide necessary
accommodations for Kyndal's medical needs,
particularly during school-sponsored activities. This
ruling marks a significant setback for the district in
their obligation to uphold FAPE (Free Appropriate
Public Education) as mandated by Section 504 of
the Rehabilitation Act of 1973.

In a detailed 41-page Final Decision and Order, it was

revealed that the Garnet Valley School District
denied Kyndal appropriate accommodations, including essential access to a nurse on District-sponsored away
trips.

"Kyndal has had her educational rights trampled by the very institution meant to protect those rights," Joseph
Montgomery, Esq., representing Kyndal's family, highlighted the District's failure to provide necessary medical
accommodations, notably during off-campus activities.

As a dedicated athlete and committed student coping with chronic conditions,

Kyndal requires a strict medication regimen. Despite her parents’ proactive
engagement and the clear doctor’s orders submitted to the school, Kyndal's
needs were met with procedural delays and, in some cases, outright denial.

The District’s legal representation contended that the District’s efforts were
appropriate for the student. However, the detailed findings by Hearing Officer
Kyndal and her mother,
Joy Waters Fleming, Esq., told a different story. Elaina Adams, pictured in
front of GVHS

Hearing Officer Fleming noted specific instances where the District did not meet
its obligations. “The District failed to provide the Student with a 504 plan that described how the District
would address this Student's medication administration needs during the out-of-state, school-sponsored trip.
Based on the totality of the evidence, the District denied the Student a FAPE by failing to reasonably
accommodate the Student's medical needs, ensuring meaningful access to an educational benefit," the
Hearing Officer stated, underscoring the severity of the oversight (Page 35 of the decision which can be read
here).

The case unfolded around the District’s decision-making process regarding Kyndal’s participation in a February
2023 cheerleading trip. Despite clear recommendations from Kyndal’s physicians, the District denied Kyndal a
FAPE by failing to reasonably accommodate her medical needs, ensuring meaningful access to an educational
benefit.

As a result of these findings, Hearing Officer Fleming ordered Garnet Valley to provide compensatory
education for Kyndal and to convene a meeting to review and revise the Kyndal’s 504 plan to address
medication administration during school-sponsored activities and trips.

In the hearing officer’s own words, "[T]he District had in its possession July 2022 and January 2023 letters
from the Student's treating physicians. Both letters requested that a nurse administer the Student's
medications and monitor for adverse reactions. Medication administration through nursing support was a
reasonable accommodation in order for this Student to have meaningful access to the Florida school trip.
Although the parent attended the Florida trip, she had to stay in a hotel, away from the Student, and a
medication dosage was missed.” Despite these clear directives from healthcare professionals, the school failed
to take the necessary actions, resulting in a denial of FAPE.

A key finding by the hearing officer was that “[t[his disabled Student's access to an educational program or
activity must not depend on parental participation,” a significant finding for all parents who have been
demanded by schools to supplement services that a district refuses to provide.

Montgomery, founder of Montgomery Law and EducationLawyers.com, a firm dedicated to student advocacy,
remarked on his client's resilience:

"Kyndal is a fighter. It’s a shame her energy has to be spent fighting for the supports and services she is
legally entitled to, instead of being able to focus fully on her health, academics, and athletics. This process
 has been draining for her; the school has been relentless in their efforts to put obstacles in her way. But at
the end of the day, when a district fails to provide a student with a disability what they are legally entitled
to, the district should be called to account. The Garnet Valley School District has been called out on their
errors. It's why we say our business is in ‘Teaching Schools a Lesson,’ when appropriate.”

Speaking on the matter, Kyndal's mother, Elaina Adams, who is a nurse by profession, shared her perspective:

“Providing access to safe and appropriate care for our children shouldn’t turn into a legal battle when
sending our children off to school. This includes care needed for after-school activities and clubs. All we
asked for was for a nurse to be provided so our daughter could receive her prescribed medications and so
the effects of the medications could be monitored as ordered by her doctors. She loved her team and
being a part of the team. Her medications are used to treat her pain, decrease her stiff, aching joints, and
numbness, all associated with her arthritis. All of which, when left untreated or when there is a delay in
receiving her medication, brings her pain to intolerable levels.

“Over time, that pain and stiffness causes bone damage and deterioration. When we started this process,
we were hopeful that if found in the wrong, Garnet Valley would make it right by providing my daughter
the care she needs. The amount of money spent by the district in legal fees and resources to prevent her
from getting care could have been used towards resources for not only my child but so many other
children in our district. It just doesn’t make sense to us. We had hoped that with the hearing officer's
decision in our favor, the district and its coaching staff would have just complied with the ruling and given
the care that they should have all along.

“Unfortunately, that has not been our experience. We know we are not alone in being mistreated by the
district and its employees. We know we are not alone in their attempts to gaslight us and make false
accusations. We are taking a stand for our child. We hope all students can benefit from our efforts.
Allowing administrators and coaches to belittle and bully our students is not okay with us. This isn’t about
a parent being unrealistic about their child’s abilities. Kyndal, even despite her diagnosis, has never missed
a competition. She has never been unable to perform her routine as given to her. If she couldn’t, we would
understand why she was removed from her varsity competition team.”

Kyndal has opened up about the matter since the hearing officer’s decision was announced, breaking her
silence and sharing:

"Despite winning the legal battle, my struggle is far from over. I am currently facing what I feel is such
severe discrimination from the school's faculty that I was forced off the varsity cheerleading team, leading
to my reluctant decision to quit. This process, meant to aid me, has only been met with indifference and
obstruction from the school.

“After a recent incident, in which the coaches initially refused to allow my nurse on the bus, compelled me
to publicly disclose my medications, and finally refused the nurse full access to me at a competition, was
brought to the school's attention, the response was not supportive. Instead, the coach removed me from
the Varsity competition team, saying it was because 'they couldn’t trust I would be at 100%, and if I got
hurt, it would be their fault.' I reminded the coaches that my condition and the effects of my condition are
 nothing new. Their decision made no sense because I was told that I would still be allowed to compete
with the Game Day team. This team has a longer routine and requires me to stunt, jump, base, and tumble,
but it is not the varsity competition team; it is very different. Why can I do those things with one team and
not the other? No explanation was offered.

“They have allowed me to compete the prior two seasons on the JV team during full-blown flares, and I
never missed a beat. I never let my coaches or teammates down. Now though, after securing my right to
access a nurse through the legal system, I was told that perhaps cheer isn’t my sport, and I should find
something else to do. I am allowed to compete per my rheumatologist’s advice. Moving and staying active
is exactly what the physician has ordered. Physically, the more active I stay, the better I feel, and my joints
don’t hurt as much. Mentally, having a schedule and routine helps me focus on that and not my arthritis.
It’s a win-win. Stress is a known cause of flares in my type of arthritis.

"Being removed from the varsity competition team was a punch to the gut. I have worked so hard to
achieve that goal. I was told it was for this weekend only and that they would re-evaluate my status the
following Monday. I was told that I would still compete with Game Day and that I should just enjoy that. My
mother and I both explained that this doesn't make sense. If I say I can do it, I will do it, but our feelings,
opinions, and proof through prior performance fell upon deaf ears. They had clearly made up their mind,
and in their opinion, my disability meant I just didn’t meet their standards. During practice on the previous
Thursday evening [November 9, 2023] my teammates were told I would not be competing with them at all
this weekend, and the coaches then rearranged the routine, removing me from not only one routine but
now two.

“I have been punished and pulled from something I loved so much, in retaliation for, among other things,
the perceived inconvenience caused by having my nurse present and by the coaches' behavior being
reported to the district. My overall physical, mental, and emotional well-being must now take priority; I
can’t endure further abuse from the school. Reluctantly, I told my mother to inform the coaching staff
that I would no longer be a member of the team and the sport I have spent the last 11 years falling in love
with. This is not what I wanted; this is not what I want."

The decision reinforces the necessity for school districts to adhere strictly to legal guidelines regarding the
accommodations of students with disabilities and the importance of taking prompt and appropriate action
when a student’s health and education are at stake.

EducationLawyers.com
For more information on this case or to arrange interviews, please contact:

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