Thus any federal constitutional claims predicated on § 1983 should have been dismissed. See King v. Pioneer Regional Educational Svc. Agency, 301 Ga.App. 547, 552(1), 688 S.E.2d 7 (2009) (although “municipalities and other local governmental entities are included among those persons to whom § 1983 applies,” such entities “may not be held liable on a respondeat superior theory,” but may be held liable only when “execution of a government's policy or custom inflicts the injury” suffered), citing Monell v. Dept. of Social Svcs., 436 U.S. 658, 690(II), 98 S.Ct. 2018, 56 L.Ed.2d 611 (1978). As this Court has noted, “a primary purpose of the doctrine of sovereign immunity is the protection of the public purse.”

But Mecca fails to establish how, on the facts of this case, its due process rights were violated. See King v. State, 272 Ga. 788, 792(1), 535 S.E.2d 492 (2000) (procedural due process means notice and an opportunity to be heard); King v. Pioneer Regional Educational Service Agency, 301 Ga.App. 547, 553(1)(a), 688 S.E.2d 7 (2009) (“The substantive component of the Due Process Clause protects individual liberty against certain government actions regardless of the fairness of the procedures used to implement them.”) (citations and punctuation omitted).Prior to the trial court's determination of when an answer was due, Maestro had filed a pleading opposing Mecca's request for an extension; Maestro attached as exhibits to the pleading copies of the notices it had sent to Mecca.

See Davis v. Wallace, 310 Ga.App. 340, 347(4), 713 S.E.2d 446 (2011) (“An action for false imprisonment will lie where a person is unlawfully detained under a void process, or under no process at all ...” (punctuation omitted)); OCGA § 51–7–20.See King v. Pioneer RESA, 301 Ga.App. 547, 552(1), 688 S.E.2d 7 (2009) (In order to state a claim under 42 USC § 1983, “a plaintiff must show a deprivation of a federal right by a person acting under color of state law.” (punctuation omitted)).

To illustrate the dangers of restraint and seclusion in the school environment, Plaintiff references the 1994 suicide of a Georgia special education student who hung himself with his shoelaces in a time-out room. (Pl.'s Mem. in Opp. to Summ. J. at 8.) See also Nancy Badertscher, "State May Ban Seclusion Rooms," Atlanta Journal-Constitution (May 13, 2010); King v. Pioneer Regional Educational Service Agency, 301 Ga.App. 547, 688 S.E.2d 7 (Ga. App. Ct. 2009). Leaving a child captive and unattended in a small, windowless room may well be the type of "objectively unreasonable" seizure that would defeat qualified immunity. Plaintiff alleges that is what happened here — that he was locked in a 55-square-foot room and had to bang and kick at the door until a maintenance worker freed him ten minutes later.