The following is from the introduction to our Court Complaint.  It explains all that Charlie went through that Sophomore year at Landon and how Landon failed to protect him and warn us as his parents of the danger he was in:

On March 27, 2022, Charlie Schnell., a 16-year-old high school Sophomore who had just 13 days earlier been forced to withdraw from The Landon School, took down his Landon banner from above his bed, made it into a noose and hanged himself. Charlie’s suicide was the tragically foreseeable consequence of Landon’s mounting and egregious failures to protect him from harm, as Charlie. had exhibited, experienced and endured a series of significant traumatic events, mental health warning signs and risk factors for suicide during the first eight months of his Sophomore year.
First, there was the trauma in August 2021 that Charlie suffered when the father of a Landon classmate and close friend hanged himself. As the school was aware, Charlie knew the gruesome details of the hanging and was personally struggling in its aftermath. As a school that touted its expertise in boys, Landon knew or should have known that it needed to promptly engage in postvention efforts to address this prominent suicide within its community and to mitigate the risk of suicide contagion. Tragically, eyewitness testimony has confirmed that one night before his own suicide, Charlie discussed the suicide of this friend’s father in detail.

Then, in September 2021 a fellow Landon Sophomore made an on-campus statement that was perceived as a threat to shoot up the school – a threat, even if later determined by the School to have been made in jest, that traumatized Charlie and his classmates in this era of horrific mass shootings. Charlie. himself described his anguish over the perceived school shooting in a classroom journal that was reviewed by his English teacher, Defendant Stephanie Wooten, thus placing Landon directly on notice of his significant mental and emotional distress:

I’m tired and worried. It’s hard to catch back up in some classes but I’m managing to get through it. I’m on so many pills for my tonsils that I’m always tired and have a lack of motivation which is really aggravating ... They also cause me insane pain....

I’m worried about the school shooting threats. I’ve run the scenario through my head and talked to my dad and advisor. They can’t even imagine because of the infrequency of school shootings at their age. If there was a shooting I wouldn’t want to run and leave all my friends but I also wouldn’t want to get shot so it’s very contradicting....

So right now I would sum everything up to being tired, in pain, hopeful and worried.

Unfathomably, Landon failed to inform Charlie’s parents of this journal entry – they only came to learn of it as they paged through his notebooks after his death.

As reflected in the entry, Charlie’s angst and ruminations over the perceived school shooting threat coincided with significant physical health issues he was experiencing. Throughout that Fall and Winter of his Sophomore year, Charlie’s endured a long bout of mononucleosis, a 12- pound weight loss and a worsening tonsillitis condition that led to a December surgery. Charlie’s mother, Dawn Schnell, informed the school repeatedly that Charlie was feeling overwhelmed by the debilitating stress and related academic struggles caused by these ongoing physical issues. She also repeatedly urged the school to develop an affirmative plan of academic support for Charlie to address these concerns, to no avail.

Then, on January 26, 2022, Charlie suffered a serious concussion during a school wrestling practice, missing about five days of school. Landon, which touts its top notch athletic programs and school training staff, knew or should have known that a concussion, a form of traumatic brain injury, would place Charlie at an even increased risk of impulsivity, depression and suicide, especially given his already vulnerable mental health state. But, as Charlie struggled for days with post-concussive symptoms, the school failed to follow the standard of care for concussion protocol before having Charlie return to school and sports and failed to adequately assess or address this heightened risk to Charlie’s fragile mental health.

Charlie continued to suffer post-concussion symptoms into February and on February 23, 2022 tested positive (for the second time) for COVID, missing yet another week of school. Charlie finally returned to school on March 1, 2022, about three weeks before his death.

On March 4, 2022, Charlie was at lacrosse practice and made a mistake during a practice drill. After being sent to sit on the bench, he muttered the word “pussy” in frustration in reference to his coach. While Charlie’s documented trauma and physical and mental health struggles were mitigating factors that called for some degree of empathy in assessing his impulsive use of such language, the school subjected him to a formal disciplinary process.

The hearing appeared to have gone favorably for Charlie, but the process was then contaminated by an extraneous, last-minute allegation that Charlie, who was White, had shown a racist drawing to a close friend, a Black classmate. No Landon administrator ever saw the drawing or ever spoke to Charlie. about the last minute allegation against him. Nonetheless, Landon officials relied on the inflammatory allegation in the ongoing disciplinary proceeding and subsequent appeal process. Charlie’s parents were then pressured by Defendants Federowicz and Neill to withdraw Charlie from Landon under threat of expulsion, in exchange for a feigned promise of “confidentiality” regarding the reason for his withdrawal.

Meanwhile, as Landon was well aware, the allegation against Charlie related to the rumored drawing already had quickly embroiled the campus, leading to explosive animus against Charlie and placing him in a demonstrable, heightened zone of danger of risk of harm from others and of self-harm/suicide. Notably, Defendant Wooten personally took it upon herself to play a public and adversarial role against Charlie in regards to the drawing allegation, described by an eyewitness as marching on campus with students who were expressing anger and making audible threats against Charlie But Landon did not investigate, intervene or otherwise take effective action to quell this mounting anger towards Charlie. Nor did Landon advise Charlie’s parents that students were openly expressing animus towards Charlie and that he was in a zone of danger.

Instead, the school made matters worse by having its administrators engage in improper, extensive discussions with other students, parents and faculty that essentially corroborated Charlie’s rumored role regarding the drawing, further inflaming the animus against him. Such discussions included a large, lengthy meeting on Monday, March 14, 2022 with students in the Sophomore class – while Charlie was still enrolled as a student – where the drawing was discussed and where the palpable, roiling anger towards Charlie was evident. After Charlie’s withdrawal from Landon, Defendant Federowicz met with the entire Sophomore class on March 15, 2022, confirmed Charlie was no longer at Landon and told them that Charlie had done “bad things.” But, again, Charlie’s parents were not informed of any of these discussions or of the demonstrable anger and animus being expressed against Charlie.

After his withdrawal from Landon, Charlie continued to be in a zone of danger from the continued and concerted animus and anger against him. Charlie was socially excluded, shunned, bullied, labeled a racist and threatened by his Landon peers during this period. Based on investigation to date, Landon was aware that Charlie was being persecuted and ostracized by Landon students. For example, on information and belief, Defendant Federowicz called a Landon parent and told her that her son should not be excluding or cancelling Charlie, a clear indication that Landon was on notice of what was happening to Charlie yet neither Defendant Federowicz, Defendant Neill, as Head of School, nor Defendant Curtis, as School Counselor, ever informed Charlie’s own parents about the ongoing bullying/social exclusion. Landon’s failure to protect Charlie both before and after his forced withdrawal or to tell his parents what was happening was particularly egregious as Landon knew that this particular Sophomore class had a history of serious bullying and cyber-bullying.

Nor did Landon have appropriate professionals, policies and protocols in place to effectively address the mental health issues and bullying within its community, which were occurring within a well-documented, nationwide epidemic of plummeting teen mental health and escalating rates of cyber-bullying and teen suicide. For example, Landon did not have a specific anti-bullying policy, much less one with the types of notification to parents and reporting requirements embodied in the governing standard of care. And while Landon conveyed to the Schnells and the rest of its parent community via its 2021-2022 policy handbook that it had “licensed and trained” counselors on its staff to care for its adolescent boys, based on investigation to date, Landon’s Upper School counselor, Defendant Curtis, was not certified as a counselor by the State of Maryland Department of Education or licensed by the National Board of Certified Counselors. Notably, in its most recent 2023-2024 policy handbook, Landon has removed the words “licensed and trained” from its description of Defendant Curtis’ qualifications.

In the end, even though Landon was aware of the traumatic events, injuries, struggles and stressors that Charlie exhibited, experienced, and endured during his Sophomore year; was aware of the impending difficulty he faced with a forced mid-semester transition to another school; was aware of the palpable anger and animus being expressed toward him by students in its community; and had knowledge of the propensity of its Sophomore class to engage in bullying and cyber-bullying, the school failed to investigate or supervise the actions by its own students; to assess or address Charlie’s unique vulnerability to mental health concerns self-harm or suicide; to refer him for any such assessment; to advise his parents to do the same; or to even warn his parents that he was in this zone of danger.

The consequences of Landon’s actions and inactions were unfathomably tragic for Charlie and his family. If left unaddressed, the school’s systemic failures, as alleged herein, may continue to place current and future students at the school at risk. The Schnells thus bring this action to hold Defendants accountable for Charlie’s death and to protect current and future Landon students from harm.