Full opinion text
MEMORANDUM AND ORDER SHAW, District Judge. This matter is before the Court on two motions for summary judgment filed by the defendants. Plaintiffs oppose the motions. For the following reasons, the Court will grant in part and deny in part defendants’ motion for summary judgment as to plaintiffs Jamie Kaufmann Woods, Shari Lueken, Erika Teasley, Tracey Brazil Ozuna and Jessica Deboi (collectively referred to as the “Student plaintiffs”). The Court will grant defendants’ motion for summary judgment as to plaintiffs Ralph Lueken, Marilyn Lueken, Paul Douglas Hoover, Jr., and Katrina Hoover (collectively referred to as the “Parent plaintiffs”). Background. The plaintiffs in this action assert various federal and state law claims against the defendants arising from the Student plaintiffs’ enrollment at the Mountain Park Baptist Boarding Academy (“Mountain Park”), a boarding school operated by the defendants. The plaintiffs are Jamie Kaufmann Woods, Shari Lueken (a minor), Ralph Lueken and Marilyn Lueken (Shari’s parents), Erika Teasley (a minor), Katrina L. Hoover (Erika Teasley’s mother) and Paul Douglas Hoover, Jr. (Katrina Hoover’s husband), Tracey Brazil Ozuna, and Jessica Deboi. Plaintiffs’ twenty-count complaint asserts federal claims for violations of the Americans with Disabilities Act and the Fair Labor Standards Act, and state law claims of assault, battery, false imprisonment, negligence, negligence in providing medical treatment, intentional infliction of emotional distress, conversion, and fraud. The defendants are Bob Wills, Betty Sue Wills, Sam Ger-hardt, Deborah Gerhardt, Julie Gerhardt, Sharon Goodman and Andrea Hill, all alleged to be doing business as Mountain Park Boarding Academy. The defendants filed a counterclaim against the Hoovers and the Lueken parents for indemnification. The counterclaim is not at issue on the summary judgment motions. One of the primary assertions made by the plaintiffs is that the defendants surreptitiously administered to the Student plaintiffs antipsychotic, psychotropic or behavior modification drugs while they were at Mountain Park. Plaintiffs assert that they were administered the prescription medications chlorpromazine (trade name Thorazine), carbamazepine (trade name Tegretol), and/or thioridazine (trade name Mellaril). Legal Standard. The standards applicable to summary judgment motions are well settled. Pursuant to Federal Rule of Civil Procedure 56(c), a court may grant a motion for summary judgment if all of the information before the court shows “there is no genuine issue of material fact and the moving party is entitled to judgment as a matter of law.” See Celotex Corp. v. Ca-trett, 477 U.S. 317, 322, 106 S.Ct. 2548, 91 L.Ed.2d 265 (1986). The initial burden is placed on the moving party. City of Mt. Pleasant, Iowa v. Associated Elec. Co-op., Inc., 838 F.2d 268, 273 (8th Cir.1988) (the moving party has the burden of clearly establishing the nonexistence of any genuine issue of fact that is material to a judgment in its favor). Once this burden is discharged, if the record shows that no genuine dispute exists, the burden then shifts to the non-moving party who must set forth affirmative evidence and specific facts showing there is a genuine dispute on a material factual issue. Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 249, 106 S.Ct. 2505, 91 L.Ed.2d 202 (1986). Once the burden shifts, the non-moving party may not rest on the allegations in its pleadings, but by affidavit and other evidence must set forth specific facts showing that a genuine issue of material fact exists. Fed.R.Civ.P. 56(e); Herring v. Canada Life Assur. Co., 207 F.3d 1026, 1029 (8th Cir.2000); Allen v. Entergy Corp., 181 F.3d 902, 904 (8th Cir.), cert. denied, 528 U.S. 1063, 120 S.Ct. 618, 145 L.Ed.2d 512 (1999). The non-moving party “must do more than simply show that there is some metaphysical doubt as to the material facts.” Matsushita Elec. Indus. Co., Ltd. v. Zenith Radio Corp., 475 U.S. 574, 586, 106 S.Ct. 1348, 89 L.Ed.2d 538 (1986). A dispute about a material fact is “genuine” only “if the evidence is such that a reasonable jury could return a verdict for the nonmoving party.” Herring, 201 F.3d at 1029 (quoting Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248, 106 S.Ct. 2505, 91 L.Ed.2d 202 (1986)). A party resisting summary judgment has the burden to designate the specific facts that create a triable question of fact. See Crossley v. Georgia-Pacific Corp., 355 F.3d 1112, 1114 (8th Cir.2004). The Court is “ ‘not required to speculate on which portion of the record the nonmoving party relies, nor is it obligated to wade through and search the entire record for some specific facts that might support the non-moving party’s claim.’ ” Barge v. Anheuser-Busch, Inc., 87 F.3d 256, 260 (8th Cir.1996) (quoting White v. McDonnell Douglas Corp., 904 F.2d 456, 458 (8th Cir.1990)). “Self-serving, conclusory statements without support are not sufficient to defeat summary judgment.” Armour and Co., Inc. v. Inver Grove Heights, 2 F.3d 276, 279 (8th Cir.1993). With this standard in mind, the Court accepts the following facts as true for purposes of resolving the instant motions for summary judgment. Facts. As a threshold matter, the Court must address plaintiffs’ failure to comply fully with Local Rule 4.01(E), and the effect of that failure. Local Rule 4.01(E) provides with respect to summary judgment motions: A memorandum in support of a motion for summary judgment shall have attached a statement of uncontroverted material facts, set forth in a separately numbered paragraph for each fact, indicating whether each fact is established by the record, and, if so, the appropriate citations. Every memorandum in opposition shall include a statement of material facts as to which the party contends a genuine dispute exists. Those matters in dispute shall be set forth with specific references to portions of the record, where available, upon which the opposing party relies. The opposing party also shall note for all disputed facts the paragraph number from movant’s listing of facts. All matters set forth in the statement of the movant shall be deemed admitted for purposes of summary judgment unless specifically controverted by the opposing party. E.D. Mo. L.R. 4.01(E). Plaintiffs responded to defendants’ statements of uncontroverted material facts by filing a document containing numbered paragraphs in which plaintiffs admitted or denied each statement of material fact, often providing affirmative statements in support of the denials. Plaintiffs did not, however, include in their responses “specific references to portions of the record, where available, upon which the opposing party relies.” E.D. Mo. L.R. 4.01(E). Instead, plaintiffs submitted their own statement of additional material facts which incorporated by reference certain documents and declarations executed by seven of the plaintiffs. As a result, plaintiffs have deemed admitted defendants’ statements of material fact except to the extent that their affidavits serve to raise a genuine issue of material fact. The Court will therefore repeat defendants’ statements of material fact largely verbatim, and will note whenever plaintiffs properly dispute a fact and the ground for their dispute. Cf. Northwest Bank & Trust Co. v. First Ill. Nat’l Bank, 354 F.3d 721, 725 (8th Cir.2003) (holding district court did not abuse its discretion by applying local rules that excluded some of the material facts offered in opposition to a motion for summary judgment); Huckins v. Hollingsworth, 138 Fed.Appx. 860, 862 (8th Cir.2005) (unpublished per curiam) (where plaintiffs responded to the defendants’ statements of material facts by paragraph number as required by local rule but did not fully comply with that rule by submitting their own concise statement of material facts as to which they contended there exists a genuine issue to be tried, and instead provided the district court with affidavits, the district court did not abuse its discretion when it recounted the defendants’ statements of facts verbatim but noted whenever the plaintiffs properly disputed a fact and the ground for their dispute). Facts Relating to Student Plaintiffs’ Claims. 1. Mountain Park Baptist Church (“Mountain Park”) is an independent Baptist church established by defendants Pastor Bob Wills and his wife, Betty Sue Wills, in 1987. 2. The sole ministry of Mountain Park was to serve teens through the operation of a boarding academy that provided a secure, structured Christian environment. 3. The twin missions of Mountain Park, through the defendants, including Bob Bills, Betty Wills, Sam Gerhardt, Debbie Gerhardt, Julie Gerhardt, Sharon Goodman and Andrea Hill, were to (a) provide a secure environment to nurture Christian values of respect for authority, Biblical self-image, and self-discipline, and (b) foster academic development. 4. Defendants’ religious beliefs and practices were incorporated into the educational curriculum, policies and practices at Mountain Park. In addition, defendants regularly conducted group Bible study services and had church services several days per week. 5. To develop the social skills and self-discipline of each student, Mountain Park and its employees established and maintained tiers of student status and achievement. 6. The orientation program fosters self-discipline and responsibility, as well as leadership skills that were critical to Mountain Park’s missions. 7. New students were placed on orientation upon enrollment. The student on orientation has a guide or mentor who helps the student become acclimated to Mountain Park. 8. Both students on orientation and their guides engaged in the same activities, including going to school, performing chores including dorm cleaning, prayer, Bible study and other activities. 9. The orientation program was a fundamental part of defendants’ mission because it was the primary mechanism for directing the positive peer pressure that was critical to Mountain Park’s mission. 10. More senior or experienced students who demonstrated their faith in God and responsibility served as orientation guides. 11. More senior and responsible students performed “safety patrol,” where a student would observe a part of the dormitory to help maintain the safe and secure environment that was a part of Mountain Park’s mission, for approximately one hour during a night. 12. The orientation program and safety patrol were never offered to the public. They were merely part of Mountain Park’s mission and Mountain Park never derived a substantial economic benefit from the program. 13. Students are enrolled in Mountain Park by their parents. 14. Typically, when each student was enrolled at Mountain Park, defendant Sam Gerhardt would meet personally with one or both parents to discuss the policies and procedures at Mountain Park as well as go through several forms that are filled out by the parents. 15. Occasionally, initial discussions with parents would be undertaken by telephone. 16. Sam Gerhardt always told the truth about the policies and practices at Mountain Park when he met with parents. 17. Defendant Julie Gerhardt was employed by Mountain Park as a staff member from June 1997 until April 2004. 18. Defendant Sharon Goodman was employed by Mountain Park as a staff member from August 2000 until May 2004. 19. Defendant Andrea Hill was employed by Mountain Park as a staff member from June 1997 until May 2004. A. Tracey Ozuna. 20. Plaintiff Tracey Ozuna was enrolled by her parents at Mountain Park as a student on two occasions. The first occasion was between December 1995 and April 1996 and the second time was from February 1997 through December 1997. She was under the age of eighteen both times. 21. Ms. Ozuna’s parents executed a power of attorney to Mountain Park when she was enrolled there. 22. While she was a student at Mountain Park, Ms. Ozuna engaged in activities of daily student life, including having breakfast, Bible memory, school, lunch, exercise, chores and dinner. 23. Ms. Ozuna has no facts demonstrating that defendants actually administered chlorpromazine to her. Her only claimed facts to support the assertion that defendants gave her chlorpromazine are that she purportedly experienced some symptoms which are possible side effects from taking chlorpromazine, that she looked up on an Internet website. 24. While at Mountain Park, Ms. Ozu-na was not aware that she was being administered any chlorpromazine or any other antipsychotic medication. 25. Ms. Ozuna acknowledges that the only named defendant she alleges touched her was Betty Wills. 26. Ms. Ozuna was hit with a paddle eight times by Laura Matthews during her first enrollment at Mountain Park. Debbie Gerhardt ordered the paddling in front of Ms. Ozuna. 27. Ms. Ozuna was never given a copy of the rules or the Parent-Student Handbook while at Mountain Park. 28. During both of her enrollments at Mountain Park, Ms. Ozuna had memory loss, disorientation, difficulty differentiating different individuals, increased passivity, inability to think clearly, weight gain, and yellowish skin color. 29. After she left Mountain Park, Ms. Ozuna lost the extra weight she had gained without dieting or other weight loss efforts. 30. During both enrollments, Ms. Ozu-na had difficulty urinating and defecating. 31. During her second enrollment at Mountain Park, Ms. Ozuna did not have her menstrual period for eight months. She had only one or two menstrual periods at the end of her second enrollment. 32. Ms. Ozuna spent over a year in other boarding schools and never missed a menstrual period while at the other schools. 33. Ms. Ozuna has memory gaps that make it hard for remember what happened at Mountain Park. She has no other memory gaps, although she attended other boarding schools. 34. Ms. Ozuna thought about running away from Mountain Park but “could not act upon the thought.” 35. All food, drink, medication and other items for ingestion into the body were strictly controlled by the defendants. Ms. Ozuna was not allowed to take any drugs unless defendants authorized their administration. 36. Ms. Ozuna was required to drink a specified amount of milk or juice, neither more nor less, and could not share or get refills. B. Jessica Deboi. 37. Plaintiff Jessica Deboi was enrolled by her parents at Mountain Park between April 1997 and December 1997. She was under the age of eighteen at the time. 38. When her parents enrolled Ms. De-boi at Mountain Park, they executed a power of attorney form to Mountain Park. 39. While she was a student at Mountain Park, Ms. Deboi engaged in activities of daily student life, including having breakfast, Bible memory, school, lunch, exercise, chores and dinner. 40. No physician has ever told Ms. De-boi that the symptoms she allegedly suffered while at Mountain Park came from being given chlorpromazine. 41. Ms. Deboi cannot state that she suffered a battery by any of the defendants. 42. Ms. Deboi was never given a copy of the rules or the Parent-Student Handbook while at Mountain Park. 43. Two days after leaving Mountain Park, Ms. Deboi was on a cruise ship and took the medication Sudafed for a sinus problem. She was not allowed to have Sudafed while at Mountain Park. After taking the Sudafed, Ms. Deboi vomited, was in great pain, and lost consciousness. She was taken by lifeboat to a hospital, where tests showed her blood sugar was extremely low and she was dehydrated. She spent several days in the hospital recuperating. 44. Ms. Deboi was severely constipated at Mountain Park, and gained almost thirty pounds while there. After she left Mountain Park, she lost about ten pounds quickly without dieting or other weight loss efforts. 45. While at Mountain Park, Ms. Deboi had memory gaps, constant fatigue, difficulty concentrating, increased passivity, and an inability to resist aggression in others. She felt like a zombie. 46. Ms. Deboi did not have a menstrual period for approximately six months while at Mountain Park. After six months, she had regular but lighter than normal periods. After she left Mountain Park, her periods became regular within a couple of months. She has never had irregular menstrual periods either before or after her time at Mountain Park. 47. While at Mountain Park, she thought about running away “but could not act upon the thought.” 48. Approximately two to four weeks after she left Mountain Park, Ms. Deboi’s senses and faculties began to be normal. She did not really feel like herself until two months later. 49. While at Mountain Park, Ms. Deboi was required to drink a specified amount of milk or juice, neither more nor less, and could not share or get refills. 50. All food, drink, medication and other items for ingestion into the body were strictly controlled by the defendants. Ms. Deboi was not allowed to take any drugs unless the defendants authorized their administration. C. Jamie Kaufmann Woods. 51. Ms. Woods’ mother and father enrolled her at Mountain Park. 52. Ms. Woods was at Mountain Park from September 9, 1999 until May 2001. 53. Ms. Woods’ date of birth is July 22, 1983, and she was under the age of eighteen while at Mountain Park. 54. Ms. Woods graduated from Mountain Park. 55. At the time of Ms. Woods’ enrollment, her natural mother, Christine M. Donley, executed a power of attorney to Mountain Park. 56. Ms. Woods has no facts to support the allegations that she was given chlor-promazine while she was at Mountain Park. 57. Ms. Woods alleges that she was battered by defendants Betty Wills and Andrea Hill. 58. No outside individuals were allowed in Mountain Park’s church, except for one of Mountain Park’s attorneys, David C. Gibbs. 59. An orientation guide, Meaghan Richter, pulled Ms. Woods’ hair and pushed her to get her attention, because Ms. Woods could not hear her due to hearing loss. 60. Ms. Woods complained to defendant Hill about the hair pulling but Hill did not do anything about it. 61. When Ms. Woods arrived at Mountain Park, she was tackled to the ground by a number of girls, and defendant Hill was shouting instructions to the girls to hold her down. Ms. Woods was falsely accused of trying to run away. 62. Ms. Woods did try to run away a couple of days after she arrived at Mountain Park, and she was tackled to the ground by other students, who had standing orders to catch and secure runaways, and was taken back to her bed. 63. Ms. Woods was never given a copy of the rules or the Parenb-Student Handbook while at Mountain Park. 64. While at Mountain Park, Ms. Woods had memory loss, dark urine, constant fatigue, disorientation, increased passivity, inability to resist aggression in others, inability to think clearly, and a weight gain of about thirty pounds. Ms. Woods felt sluggish and had memory gaps that make it very hard to remember what happened at Mountain Park. 65. A couple of the students Ms. Woods was assigned to guard had purple urine. 66. After she left Mountain Park, Ms. Woods lost the extra weight without dieting or other weight loss efforts. 67. The symptoms she experienced at Mountain Park have not happened to her at any other time except at Mountain Park. 68. For approximately seven to nine months while she was at Mountain Park, Ms. Woods did not have menstrual periods. After that time, she had irregular periods. Within a couple of months after she left Mountain Park, her periods became regular. Ms. Woods has never had irregular periods either before or after Mountain Park, except for two or three months after the birth of her son. 69. Ms. Woods thought about running away from Mountain Park “but could not act upon the thought after the first few days.” Later, she could not even think about running away although she was miserable all the time. Ms. Woods began to think about drinking chemicals or committing other self-harm behavior. She swallowed a safety pin during this time. 70. Ms. Woods was required to drink a specified amount of milk or juice, neither more nor less, and could not share or get refills. 71. All food, drink, medication, and other items for ingestion into the body were strictly controlled by the defendants. Ms. Woods was not allowed to take any drugs unless the defendants authorized their administration. 72. About a month after leaving Mountain Park, Ms. Woods’ senses and faculties began to be normal. This was the first time after going to Mountain Park that she felt capable of asserting herself or thinking independently. D. Shari Lueken. 73. Ms. Lueken was enrolled at Mountain Park by her parents from June 23, 2000 until June 20, 2002. 74. Ms. Lueken was under the age of eighteen while she was a student at Mountain Park. 75. At the time she was enrolled in Mountain Park, Ms. Lueken’s parents executed a power of attorney to Mountain Park. 76. Ms. Lueken testified that she has no facts showing that any pills she was given while at Mountain Park were chlor-promazine. 77. Ms. Lueken contends, however, that she was given chlorpromazine without her knowledge. 78. Ms. Lueken cannot identify any instances when one of the defendants pushed or shoved her. 79. In her Declaration, Ms. Lueken states that different staff members, including defendants Goodman and Julie Ger-hardt, gave her pills and checked to make sure she swallowed them. 80. Ms. Lueken felt she was drugged because she “felt like a zombie,” she had below normal energy levels, her menstrual periods stopped for a nine-month period, her breasts became enlarged, her hair started falling out, and she experienced increased passivity. After nine months, she began having erratic menstrual periods. 81. Ms. Lueken experienced these symptoms only while at Mountain Park. 82. After leaving Mountain Park, Ms. Lueken’s breasts returned to normal size, her hair stopped falling out, her menstrual periods resumed normalcy, and she “began to function normally.” 83. All food, drink, medication and other items for ingestion into the body were strictly controlled by the defendants. Ms. Lueken was not allowed to take any drugs unless the defendants authorized their administration. 84. Ms. Lueken was dragged by her arms or other body parts around an exercise track by Amanda File, Natalie Fah-nestock, Amanda Krassin, Jamie Kaufman and other girls, many times. Erin Shanahan, a staff member, dragged Ms. Lueken around the track by the hair. Ms. Lueken was told by other students that Ms. Gerhardt directed them to pull her around the track. 85. Marilyn and Ralph Lueken, Ms. Lueken’s parents, observed three musical instruments packed into a package, which was shipped to Ms. Lueken at Mountain Park. When she opened the package, one of the instruments, a piccolo, was not inside. Ms. Lueken has no facts showing that one or more of the defendants actually took possession of the piccolo. E. Erika Teasley. 86. Erika Teasley was enrolled by her mother and her mother’s husband at Mountain Park from January 18, 2003 until May 2003. 87. Ms. Teasley was under the age of eighteen while at Mountain Park. 88. Ms. Teasley’s mother, plaintiff Katrina Hoover, executed a power of attorney to Mountain Park. 89. Ms. Teasley admits that none of the defendants ever hit her. 90. Ms. Teasley was never on safety patrol and was never an orientation guide. 91. Ms. Teasley has no facts to support her assertion that any of the defendants ever administered thioridazine to any students. 92. Ms. Teasley did not think she had been given behavior modification drugs by the defendants until she went to see her doctor, Dr. Beste, after she left Mountain Park. 93. Ms. Teasley engaged in activities of student life, including going to school, Bible memorization, eating meals and chores. 94. According to Ms. Teasley’s Declaration, defendants Goodman, Julie Ger-hardt and Hill gave her pills and always checked her mouth to make sure she swallowed them. They stopped giving her the pills several days before she left Mountain Park but continued to give pills to the other girls. 95. The pills were given in the cafeteria in the mornings and in the hallways at night. 96. While at Mountain Park, Ms. Teas-ley’s eyesight deteriorated badly, she lost strength, felt drowsy, was quiet and cooperative even in situations where she would normally resist, and was not herself. She had difficulty thinking and reasoning and “felt like walking zombie.” 97. Ms. Teasley was struck by a Kenda Landsverk for the alleged offense of looking at a new student. Landsverk also hit Ms. Teasley another time, also for a reason related to a new student. 98. Ms. Teasley describes Landsverk was an “enforcer” of Mountain Park policy. Landsverk would be summoned by Mountain Park staff to assault or restrain students. Facts Relating to Student Plaintiffs Generally. 99. Kennett Asher, D.O., performed a medical examination on each of the plaintiffs and concluded that none of them had any medically significant conditions which can be attributed to their enrollments at Mountain Park. 100. Plaintiffs made Rule 26(a)(2) disclosures in December 2004. 101. A psychologist, Jeffrey Kline, Ph. D., was retained to perform evaluations on plaintiffs Ms. Lueken and Ms. Teasley. 102. Dr. Kline is not licensed to practice medicine and is not a medical doctor. 103. Dr. Kline was not retained to perform evaluations on or offer opinions about plaintiffs Ms. Woods, Ms. Ozuna or Ms. Deboi. 104. Benjamin Corpus was retained by plaintiffs to test hair samples for the presence of certain drugs, including chlorpro-mazine, thioridazine and carbamazepine. 105. Mr. Corpus only performed testing on hair samples provided to him that were alleged to be from Ms. Lueken and Ms. Teasley. Mr. Corpus did no analysis and offered no opinions about Ms. Woods, Ms. Ozuna or Ms. Deboi. 106. Mr. Corpus offered no opinion about any emotional distress or a medically diagnosable injury. 107. By Memorandum and Order dated October 27, 2005, the Court granted defendants’ Daubert motion and excluded the testimony of Mr. Corpus in its entirety. Facts Relating to the Parent Plaintiffs’ Claims. A. The Hoovers. 108. Katrina Hoover (mother of Ms. Teasley) and Paul Hoover, Jr. executed a Hold Harmless Agreement to defendants, as well as an Enrollment Orientation Agreement, Finances Form and Notice of Parental Responsibility. 109. Katrina Hoover paid $500 per month for Ms. Teasley’s tuition, which was Mountain Park’s cost for room and board. 110. Plaintiffs made Rule 26(a)(2) disclosures in December 2004. The disclosures do not identify any experts offering an opinion about Katrina Hoover or Paul Hoover, Jr. 111. Katrina Hoover cannot state that she ever spoke with defendants Bob Wills, Betty Wills, Deborah Gerhardt, Julie Ger-hardt, Sharon Goodman or Andrea Hill in relation to enrolling Ms. Teasley in Mountain Park. 112. The only person Katrina Hoover spoke with about enrolling Ms. Teasley at Mountain Park was Sam Gerhardt. 113. Katrina Hoover cannot specify any misrepresentations that Sam Gerhardt allegedly made. 114. Katrina Hoover did not consult with a State Fire Marshal, County Health Department, or any other person or entity to determine if the dormitory or facilities at Mountain Park were safe. 115. Paul “Doug” Hoover, Jr. is not Ms. Teasley’s legal guardian, and has not adopted Ms. Teasley. 116. Sam Gerhardt told Doug Hoover that Mountain Park would not administer psychotropic or behavior modification drugs to Erika Teasley. 117. Doug Hoover relied upon this representation in enrolling Erika Teasley at Mountain Park. 118. The Hoovers removed Erika Teas-ley from Mountain Park due to “persistent and credible” rumors of physical abuse. Hoover Deck, ¶ 8. When they removed Erika from Mountain Park, she “acted like a zombie” and had what appeared to be burn marks on her arm. Id. “Due to the physical symptoms and rumors of drugging, we chose to have Erika Teasley tested for drugs.” Id. 119. Mr. Hoover contributed funds toward the $500 monthly payment to Mountain Park. 120. Mr. Hoover received a copy of the Mountain Park parent-student handbook, which assured him that he would be kept informed concerning any of Erika Teas-Iey’s medical or dental needs, and that her needs would receive prompt attention. 121. Mr. Hoover would not have sent Erika Teasley to Mountain Park if he had known she would be forced to wait two and a half months to get dental care for a chipped tooth. 122. Mr. Hoover would not have permitted Erika Teasley to go to Mountain Park had he known how she would be treated, or about the drugging of students, the physical abuse of students, and deprivations of medical care and other essentials of life. B. The Luekens. 123. Ralph and Marilyn Lueken each executed a Hold Harmless Agreement to defendants and an Enrollment Orientation Agreement. 124. Ralph Lueken was assured by Mountain Park’s documentation, and by oral representations by Sam Gerhardt and others, that his daughter Shari Lueken would be treated humanely and would receive necessary medical care. 125. Sam Gerhardt told Ralph Lueken that Mountain Park was a drug-free facility- 126. Ralph Lueken relied on these representations in deciding to enroll Shari Lueken at Mountain Park. 127. Ralph Lueken received a copy of the Mountain Park parent-student handbook, which assured him that he would be kept informed of any medical or dental needs of Shari Lueken, and that her needs would receive prompt attention. 128. After Shari Lueken was removed from Mountain Park, Ralph Lueken had her tested for drugs. 129. Ralph Lueken has spent tens of thousands of dollars to obtain “competent professional services to undo the damage done by the Defendants” to Shari Lueken. Lueken Deck, ¶ 9. 130. Ralph Lueken Hoover would not have enrolled Shari Lueken at Mountain Park had he known how she would be treated, or about the drugging of students, the physical abuse of students, including being dragged by other students, and deprivations of medical care and other essentials of life. Discussion. A. Americans with Disabilities Act Claim. Plaintiff Jamie Kaufmann Woods alleges that defendants violated the Americans with Disabilities Act, 42 U.S.C. §§ 12101, et seq. (the “ADA”). The complaint (Part 1, Count 1) alleges that Ms. Woods was deaf and wore hearing aids as a result of congenital hearing loss. Ms. Woods sometimes had difficulty understanding others even while wearing hearing aids, and could hear and understand very poorly or not at all without hearing aids. Complaint, ¶¶ 74-77. The complaint states that Ms. Woods wore prescribed hearing aids at the time of her enrollment at Mountain Park, but was not actually wearing the hearing aids at the time her parents took her to Mountain Park, and that she immediately informed the staff that she was deaf and needed her hearing aids. Id., ¶¶ 79-80. Ms. Woods’ parents sent her the hearing aids at an unspecified later time, but Ms. Woods complained that she still could not hear. Id., ¶ 86. The complaint alleges that Ms. Woods did not receive hearing aids until approximately seven to nine months after she was enrolled at Mountain Park and did not receive professional medical services during the same period. Id., ¶¶ 80, 85, 88. The complaint also alleges that Ms. Woods was constantly derided by her orientation guide, Meaghan Richter, for being unable to hear, and on one occasion defendant Betty Wills shoved her hand and fingers into Ms. Woods’ chest, called her a liar and said she could hear just fine, and punished Ms. Woods by requiring her to write lines. Defendants move for summary judgment on the basis that the ADA provides an express exemption from a private right of action against a religious organization. Defendants state that plaintiff Woods’ claim could only be brought pursuant to the public accommodations portion of Title III of the ADA, 42 U.S.C. §§ 12181-12189. Defendants assert that as a religious organization they cannot be sued under Title III because 42 U.S.C. § 12187 provides an exemption for “private clubs or establishments exempted from coverage under title II of the Civil Rights Act of 1964 (42 U.S.C.2000-a(e)) or to religious organizations or entities controlled by religious organizations, including places of worship.” 42 U.S.C. § 12187. Defendants assert it is undisputed that Mountain Park, an unincorporated association, was an independent fundamental Baptist church founded by defendants Bob and Betty Wills in 1987 with the mission of serving troubled teens through a boarding school, and that it maintained certain fundamental religious principles which were integral to the curriculum, including regular Bible study services and church services several days per week. Defendants assert that Mountain Park, and the defendants as its agents and employees, was a “religious organization” as defined by 42 U.S.C. § 12187 and associated regulations, and therefore defendants are exempt from a private right of action under Title III of the ADA. Defendants cite two decisions interpreting the religious organization exemption to Title III, White v. Denver Seminary, 157 F.Supp.2d 1171 (D.Colo.2001), and Doe v. Abington Friends School, 2005 WL 289929 (E.D.Pa. Feb. 4, 2005). Plaintiffs respond that defendants have not shown any minutes of a corporation or organization or otherwise established that Mountain Park is run by a bona fide church. Plaintiffs state that the public was not invited to attend Mountain Park’s “church” services. Plaintiffs also state that defendants were operating Mountain Park on a for-profit basis, and that real estate records of Wayne County, Missouri show that the defendants paid taxes on the Mountain Park property, which indicate it was a business rather than a church. Plaintiffs also submit the declaration of Ms. Woods, which asserts her belief that Mountain Park was not a church because “outside individuals” were not allowed in the church, and that “church” was “just an excuse to get all the kids together and yell at them.” Woods Decl., ¶¶ 2-3. Woods asserts “on information and belief’ that Mountain Park is operated as a for-profit business, has never created a formal church or religious organization, or joined any recognized religious group. Id., ¶4. Woods also asserts that while at Mountain Park, she “saw no evidence that the ‘church’ owned the school” and that it “appeared to [her] that the Wills and the Gerhardts owned the entire property and used them as their personal possessions.” Id., ¶ 6. Defendants reply that the Woods Declaration cannot create an issue of material fact on the ADA claim because it is mere opinion about what Ms. Woods considers to be a church, and also contains statements made on information, belief and conjecture. Defendants also object that there is no foundation for the purported Wayne County real estate records, as the documents are not authenticated. As defendants observe, the complaint does not indicate under which aspect of the ADA Ms. Woods asserts her claim. The ADA consists of three titles addressing discrimination against the disabled in different contexts. “Title I prohibits employment discrimination, 42 U.S.C. § 12112, Title II prohibits discrimination in the services of public entities, 42 U.S.C. § 12132, and Title III prohibits discrimination by public accommodations involved in interstate commerce such as hotels, restaurants, and privately operated transportation services, 42 U.S.C. §§ 12182, 12184.” Gorman v. Bartch, 152 F.3d 907, 911 (8th Cir.1998). The Court agrees with defendants that Title III is the only potentially applicable section, as Ms. Woods does not claim that defendants discriminated against her in employment or that defendants are a public entity. Title III of the ADA prohibits any person who owns, leases, or operates a place of public accommodation from discriminating against an individual on the basis of that individual’s disability. See 42 U.S.C. § 12182(a) (1994). A person alleging discrimination under Title III must show that (1) she is disabled within the meaning of the ADA, (2) the defendant is a private entity that owns, leases, or operates a place of public accommodation, (3) the defendant took adverse action against the plaintiff based upon her disability, and (4) the defendant failed to make reasonable modifications that would accommodate the plaintiffs disability without fundamentally altering the nature of the public accommodation. See 42 U.S.C. § 12182(a) and (b)(2)(A)(ii); Amir v. St. Louis University, 184 F.3d 1017, 1026 (8th Cir.1999). Title III by its terms does not apply to “religious organizations or entities controlled by religious organizations, including places of worship.” 42 U.S.C. § 12187; PGA Tour, Inc. v. Martin, 532 U.S. 661, 689 n. 51, 121 S.Ct. 1879, 149 L.Ed.2d 904 (2001) (noting that Congress “expressly exempted” religious organizations or entities from Title Ill’s coverage). 28 C.F.R. Pt. 36, App. B states, The ADA’s exemption of religious organizations and religious entities controlled by religious organizations is very broad, encompassing a wide variety of situations. Religious organizations and entities controlled by religious organizations have no obligations under the ADA. Even when a religious organization carries out activities that would otherwise make it a public accommodation, the religious organization is exempt from ADA coverage. Thus, if a church itself operates a day care center, a nursing home, a private school, or a diocesan school system, the operations of the center, home, school, or schools would not be subject to the requirements of the ADA or this part. The religious entity would not lose its exemption merely because the services provided were open to the general public. The test is whether the church or other religious organization operates the public accommodation, not which individuals receive the public accommodation’s services In White v. Denver Seminary, 157 F.Supp.2d at 1174, the court held that a religious seminary was exempt from the requirements of Title III of the ADA because the seminary was a “religious organization” as a matter of law. In reaching this conclusion, the court found that the seminary was a “pervasively religious organization” providing a graduate education founded on Biblical teachings, and its sole mission was to train students for Christian ministry. Id. The court observed that the seminary was founded by the Conservative Baptist Association of Colorado, and a majority of its Board of Trustees must be members of the Conservative Baptist Association; faculty and other employees must sign a statement of religious beliefs in order to remain at the seminary; and students are required to participate in a religious curriculum and attend weekly chapel. Id. In Doe v. Abington Friends School, 2005 WL 289929 (E.D.Pa. Feb.4, 2005), the court held as a matter of law that a Quaker-operated school was a “religious organization” entitled to summary judgment on an ADA Title III claim by a former student. The court relied on the affidavit of the school’s headmaster to find the following facts which established that the school was a religious organization: (1) the school was owned and controlled by the Abington Monthly Meeting of the Religious Society of Friends, which owned the school grounds and building; (2) the Monthly Meeting, through its Schools Committee, ensured the school’s adherence to Quaker principles, managed the school’s financial welfare and selects its head; (3) students who attend the school are taught Quaker principles and values and required to attend weekly Quaker meetings; and (4) the Pennsylvania Department of Education classified the school as religiously affiliated. The court also noted that in other contexts, Quaker schools had been found to be religious organizations. Id., *2. This case differs from White and Doe in several respects. First, the defendants in this case are individuals, not a secondary private school. It is not clear to the Court whether the individual defendants could be considered either a “public accommodation” or a “religious organization” within the meaning of Title III, and the parties did not address these points. Further, although there are uncontroverted affidavits indicating that the Mountain Park curriculum included religious instruction and was based on religious principles, unlike the White and Doe cases there is no evidence in the record that Mountain Park is affiliated with or belongs to a recognized religious organization apart from the two individuals who founded it, or that Mountain Park was recognized by any authority as a religious institution. The Court need not determine whether the defendants are a religious organization undér Title III, however, because it concludes that plaintiff Woods fails to state a claim against defendants under Title III for other reasons. To the extent Ms. Woods’ claim is based on defendants’ failure to provide her with hearing aids, applicable administrative regulations make it clear that a public accommodation is not required to provide its “customers, clients, or participants with ... individually prescribed devices, such as prescription eyeglasses or hearing aids .... ” 28 C.F.R. subpt. C, § 36.306 (emphasis added). This aspect of her claim must therefore fail. To the extent Ms. Woods’ claim is based on other aspects of denial of public accommodation, she cannot state a claim because the only relief she seeks, monetary damages, is unavailable under Title III. Title III borrows the remedies and procedures set forth in section 204(a) of the Civil Rights Act of 1964, 42 U.S.C. § 2000a-3(a). See 42 U.S.C. § 12188(a). Section 204(a) provides for a “civil action for preventive relief, including an application for a permanent or temporary injunction, restraining order, or other order....” 42 U.S.C. § 2000a-3(a). The United States Supreme Court has held that monetary damages are not available under 42 U.S.C. § 2000a-3(a). Newman v. Piggie Park Enters., Inc., 390 U.S. 400, 401-02, 88 S.Ct. 964, 19 L.Ed.2d 1263 (1968). It is well established that individual claims for damages based on alleged disability discrimination in violation of Title III of the ADA are precluded, and injunctive relief is the only available remedy. See, e.g., Steger v. Franco, Inc., 228 F.3d 889, 892 (8th Cir.2000) (recognizing that Title III of the ADA grants a private right of action for injunctive relief); Pona v. Cecil Whittaker’s Inc., 155 F.3d 1034, 1038 (8th Cir.1998) (Panner, D.J., concurring) (in a civil action under Title III of the ADA, a private plaintiff can only obtain injunctive relief), cert. denied, 526 U.S. 1131, 119 S.Ct. 1805, 143 L.Ed.2d 1009 (1999); see also Fischer v. SJB P.D. Inc., 214 F.3d 1115, 1120 (9th Cir.2000) (“Monetary relief is not an option for private individuals under Title III of the ADA.”); Riggs v. CUNA Mutual Ins. Soc’y, 171 F.Supp.2d 1210, 1214 (D.Kan.2001) (where ADA Title III plaintiffs request for relief was limited to money damages, she failed to state a claim upon which relief could be granted and dismissal was appropriate), aff'd, 42 Fed.Appx. 334 (10th Cir.2002). Because plaintiff Woods did not seek injunctive relief in the complaint, her claims under Title III of the ADA fail to state a claim upon which relief may be granted. Defendants’ motion for summary-judgment, construed as a motion to dismiss, should therefore be granted on this claim. B. Fair Labor Standards Act Claims. Each of the Student plaintiffs alleges that defendants violated the federal Fair Labor Standards Act (FLSA), 29 U.S.C. §§ 201-210 (2000), because defendants failed to pay each student for “acting as a security guard at all times.” Complaint, ¶¶ 141, 167, 229 and 307. The basis for this allegation is that each student was expected to “catch or attack” any other student who tried to “escape.” Id. Plaintiff Ozuna also alleges that she should be paid for serving as an orientation guide, id., ¶ 297, and plaintiffs Ozuna and Deboi allege they should be paid for being on safety patrol for about one hour per day while at Mountain Park. Id., ¶¶299, 303-06, 343-44. Defendants move for summary judgment on the FLSA claims asserting that the Student plaintiffs were not employees under the FLSA. Defendants assert that the activities at issue did not include being “engaged in commerce or in the production of goods for commerce” as required by 29 U.S.C. § 206(a), and under the economic realities of the situation, the duties the students performed were an integral part of the educational curriculum because they provided “the positive peer pressure that is critical to the curriculum” and fostered “Biblical self-image, self-discipline and responsibility, as well as leadership skills.” Defs.’ Mem. Supp. Summ. J. at 10. Plaintiffs respond that, at the time of briefing, the issue whether the defendants were subject to the FLSA was before the Eighth Circuit Court of Appeals in Blair v. Wills, 420 F.3d 823, 829 (8th Cir.2005). Plaintiffs state, “The most efficient method of dealing with this question is to wait for the Eighth Circuit to render its opinion.” Pis.’ Consol. Brief in Supp. of Response to Mot. for Summ. J. at 7. As discussed below, the Eighth Circuit has now rendered its decision in the Blair case. “Under the FLSA, an employer must pay a minimum wage to its employees who work in covered activities. See 29 U.S.C. § 206 (2000).” Blair, 420 F.3d at 829. “The Supreme Court has defined ‘work’ to include ‘physical or mental exertion ... controlled or required by the employer and pursued necessarily and primarily for the benefit of the employer and his business.’ ” Id. (quoted case omitted). “In determining whether an entity functions as an individual’s employer, courts generally look to the economic reality of the arrangement.” Id. Under the economic reality test, the focus is on “the circumstances of the whole activity,” Rutherford Food Corp. v. McComb, 331 U.S. 722, 730, 67 S.Ct. 1473, 91 L.Ed. 1772 (1947), with the ultimate point of reference being the economic reality of the relationship. Goldberg v. Whitaker House Coop., Inc., 366 U.S. 28, 33, 81 S.Ct. 933, 6 L.Ed.2d 100 (1961). In Blair, 420 F.3d 823, Blair, a student at Mountain Park and its sister school, Palm Lane Academy in Florida, alleged that he was forced to work without pay in violation of the FLSA. Blair testified he was required to perform chores including laundry, cleaning, lawn mowing, brush clearing, painting, general maintenance, and other chores. The defendants testified that performing the chores was an integral part of the learning environment and was “intended to instill in each student a sense of teamwork, responsibility, accomplishment, and pride.” Id. at 829. The Eighth Circuit observed that “although having students perform chores helped defray certain costs that the [defendants] would have incurred had they hired employees to perform those tasks, looking at the totality of the economic circumstances” there was insufficient evidence from which a reasonable jury could conclude that Blair’s activities constituted employment under the FLSA. Id. As a result, this Court’s grant of judgment as a matter of law on Blair’s FLSA claim was proper. Other courts have addressed the issue of student work in the context of the FLSA. In Marshall v. Regis Educational Corp., 666 F.2d 1324, 1328 (10th Cir.1981), the Tenth Circuit applied the economic reality test to determine whether student residence hall assistants (“RA’s”) were employees of a college for purposes of the FLSA. The RA’s were required to distribute mail, answer phones, unlock doors, maintain discipline in the halls, be available twenty hours a week and maintain a specified grade point average. In exchange, the college gave them a reduced room rate, free telephone use and a $1,000 tuition credit. Id. at 1326. The Secretary of Labor sued the college, alleging that it violated the FLSA by failing to compensate the RA’s at minimum wage for their services. The Secretary argued that the RA’s were employees because their services economically benefitted the college. Id. at 1326-27. The Tenth Circuit disagreed and stated that the government’s view ignored the “expressed educational objectives of the student resident assistant program” and did not focus on the whole circumstances of the activity. The Court stated that although the RA’s services benefitted the college, the relationship between the RA’s and the college had to be considered in light of the educational context. Id. at 1327. Quoting the reasoning of the district court, the Tenth Circuit stated, The RA’s ... did not come to [college] to take jobs. They enrolled as full-time students seeking growth and development ... and desiring to earn the recognition of an academic degree. The opportunity to reduce the cost of college by being helpful to other students and to the administration in assisting the residence hall program is only one circumstance in the whole activity. Id. at 1328. Thus, the Court considered the students’ participation in the RA program as one component of their entire educational experience. Focusing on the circumstances of the whole activity and applying the economic reality test, the Tenth Circuit concluded that the students who participated in the RA program were not employees of the college for purposes of the FLSA. Id. In an earlier case, Bobilin v. Board of Education, State of Hawaii, 403 F.Supp. 1095 (D.Haw.1975), a public school student challenged a state law that required school children from fourth to twelfth grades to perform work and chores in the school cafeteria without pay, asserting that the law violated the FLSA. In determining whether the students were “employees” under the FLSA, the district court considered the students’ tasks by evaluating the “entire fabric” of the relationship between the students and school. Id. at 1107. The court rejected the student’s argument and concluded that the primary purpose of the program was educational, to teach responsibility and civic-mindedness, and the fact that the schools may have derived some economic benefit from the program alone did not render students “employees.” Id. at 1108. The court stated, [W]hile not all forms of human experience ... are educational, it is clear that many “services” performed by students do serve “educational” purposes. For example, this Court notes the widespread and common practice of requiring elementary school children to perform small tasks such as erasing blackboards, putting their chairs on their desks after school, and serving as crosswalk monitors. These experiences teach not only neatness and responsibility but also civic attitudes fundamental in a collective society where a citizen is often called upon to “do his share” without economic compensation. Such small tasks admittedly do have economic value to the state in that they save the cost of hiring adults to perform these same tasks. Nevertheless, looking to the “economic reality” of the entire situation, it is obvious to this Court that such economically valuable activities could not reasonably be considered employment under the FLSA, which would require the payment of minimum wages to students. Id. at 1108. Based on the reasoning of Blair, Marshall and Bobilin, and applying the economic reality test to the entire circumstances of plaintiffs’ enrollment at Mountain Park, the Court concludes that plaintiffs were not employees of Mountain Park for purposes of the FLSA. The defendants’ uncontroverted testimony is that the mission of Mountain Park was to develop Christian values of respect for authority, for Biblical self-image, and self-discipline, and to foster academic development. The declarations of Betty and Bob Wills state that to develop the social skills and self-discipline of each student, Mountain Park established and maintained tiers of student status and achievement. New students were placed on orientation upon enrollment. The students on orientation were provided an orientation guide, a more senior student who had demonstrated responsibility and faith in God to help the new students become acclimated to Mountain Park. Both the new students and their guides engaged in the same activities, including attending school, performing chores including dorm cleaning, prayer, Bible study, and other activities. The orientation program was a fundamental part of Mountain Park’s curriculum because it “was the primary mechanism for directing the positive peer pressure that was critical to Mountain Park’s missions.” Betty Wills Decl., ¶ 8. More senior and responsible students also performed “safety patrol,” where a student would observe part of the dormitory for approximately one hour during the night, to help maintain a safe and secure environment. Id., ¶ 10. These tasks were part of the curriculum and were intended to help the development of personal qualities in the students, such as self-respect and responsibility. Although having students perform these tasks rather than hiring adults helped defray the defendants’ costs, under the totality of the economic circumstances, the complained-of activities were not “work” under the FLSA and the defendants were not “employers.” Defendants’ motion for summary judgment should therefore be granted on the plaintiffs’ FLSA claims. C. Intentional Infliction of Emotional Distress Claims. Each of the Student plaintiffs asserts a claim for intentional infliction of emotional distress under Missouri law. Defendants move for summary judgment on these claims, asserting that plaintiffs are unable to make a submissible case because they lack expert medical testimony to establish that the emotional distress they allegedly suffered is medically diagnosable and medically significant, citing Gibson v. Brewer, 952 S.W.2d 239, 249 (Mo.1997) (en banc) and other cases. Defendants state that plaintiffs have only a psychologist expert, Jeffrey Kline, Ph.D., and that under Missouri law, testimony of a psychologist is insufficient to establish that emotional distress is medically diagnosable and medically significant, citing Childs v. Williams, 825 S.W.2d 4, 10 (Mo.Ct.App.1992). Plaintiffs respond that the issue whether a psychologist can supply evidence of legally significant emotional distress is before the Eighth Circuit in Blair v. Wills, and this Court should wait for and be guided by that decision. Plaintiffs also respond that plaintiff Shari Lueken has alleged that defendants caused their servants to drag her around a running track, and this physical injury “takes the place of medical proof,” citing Gordon v. City of Kansas City, Mo., 241 F.3d 997, 1001 (8th Cir.2001). This is the entirety of plaintiffs’ response to defendants’ motion for summary judgment on their intentional infliction of emotional distress claims. Defendants reply that there was no intentional infliction of emotional distress claim tried or appealed in the Blair v. Wills case, so plaintiffs’ first point lacks merit. Defendants further reply that plaintiffs misread the Gordon opinion for the proposition that a physical injury obviates the requirement of a medically diagnosable and significant condition because, defendants state, an “intentional infliction claim arises from the principle that a plaintiff who does not suffer a physical injury should be able to recover if he or she witnesses or experiences an event so emotionally traumatic that it causes a medically diagnosable and significant condition.” Defs.’ Reply Mem. at 5 (emphasis in original). As a threshold matter, defendants are correct that no issue concerning intentional infliction of emotional distress and psychologist testimony was present in the Blair case. The elements of the tort of intentional infliction of emotional distress in Missouri are: (1) the defendant acted in an intentional or reckless manner; (2) the defendant’s conduct must be extreme or outrageous; and (3) the defendant’s conduct caused severe emotional distress that results in bodily harm. Gibson, 952 S.W.2d at 249. The conduct must be “intended only to cause extreme emotional distress to the victim.” Id. (quoting K.G. v. R.T.R., 918 S.W.2d 795, 799 (Mo.1996) (en banc)). In Bass v. Nooney, 646 S.W.2d 765, 772-73 (Mo.1983) (en banc), a negligence case, the Missouri Supreme Court abandoned the traditional “impact rule” and permitted a plaintiff to recover for emotional distress even in the absence of physical trauma, if the distress was sufficiently severe to be “medically diagnosable” and “medically significant.” Id. at 772-73. Some Missouri courts have extrapolated the Bass standard to cases involving the intentional infliction of emotional distress. See, e.g., Childs v. Williams, 825 S.W.2d 4, 10-11 (Mo.Ct.App.1992) (summary judgment proper where plaintiff had no medical expert to testify as to the medical significance of her emotional distress and psychologist who was identified as plaintiffs expert stated he could not comment on whether her mental problems were medically significant); Greco v. Robinson, 747 S.W.2d 730, 735-36 (Mo.Ct.App.1988) (summary judgment proper where neither plaintiff sought medical care and no physician would testify at trial as to either plaintiffs mental condition). The Eighth Circuit has stated it is “satisfied that the cases requiring medically diagnosable distress” for intentional infliction of emotional distress claims “represent current Missouri law,” Collins v. Burg, 169 F.3d 563, 565 (8th Cir.1999), and has so held on more than one occasion. Id. (citing Glover v. McDonnell Douglas Corp., 981 F.2d 388, 395 (8th Cir.1992), vacated on other grounds, 510 U.S. 802, 114 S.Ct. 42, 126 L.Ed.2d 13 (1993), and Hanks v. General Motors Corp., 906 F.2d 341, 343 (8th Cir.1990)). Based on Collins, the Court concludes that plaintiffs must prove they suffered medically diagnosable and medically significant distress in order to present a submissible case of intentional infliction of emotional distress. The issue is whether the testimony of a psychologist is sufficient to establish medically diagnosable and significant distress. In Childs, the Missouri Court of Appeals held that a psychologist who admitted he was unable to testify on matters of “medical certainty” and “medical significance” was properly excluded as a witness with respect to the plaintiffs mental condition. Childs, 825 S.W.2d at 10. The court did not, however, “rule definitively that psychologists can never testify on matters of medicine.” Id. at 11. In this case, plaintiffs have made no effort to argue that their psychologist expert witness, Dr. Kline, is qualified to offer a medical opinion as to their emotional distress. According to Dr. Kline’s deposition testimony, he is not a licensed physician or a licensed psychiatrist. Kline Dep. at 7. In the absence of any other information concerning Dr. Kline’s qualifications, the Court concludes that Dr. Kline is not qualified to provide expert medical testimony that the plaintiffs suffered medically significant and medically diagnosable emotional distress. See Childs, 825 S.W.2d at 10. Defendants’ motion for summary judgment on the plaintiffs’ intentional infliction of emotional distress claims should therefore be granted, on the basis that plaintiffs cannot establish that the emotional distress they allegedly suffered was medically diagnosable and medically significant. With respect to plaintiff Shari Lueken, plaintiffs contend that because she was physically dragged around the school’s track, she does not need to establish that her resulting emotional distress was medically significant or diagnosable, citing the Eighth Circuit’s statement in Gordon that “in order to recover for emotional distress where no physical injury is involved, there must be proof by expert medical testimony that the emotional distress or mental injury was medically significant.” Gordon, 241 F.3d at 1004 (internal punctuation and citations omitted) (emphasis added). The Court disagrees