Justia Education Law Opinion Summaries

M.D., a high school soccer player, sought a waiver from the West Virginia Secondary School Activities Commission (WVSSAC) to play for both her high school and club soccer teams during the same season. The WVSSAC denied her request, leading M.D. and her parents to file a lawsuit seeking a preliminary injunction to prevent the enforcement of the WVSSAC's Non-school Participation Rule, which prohibited participation in non-school teams during the school season for team sports but not for individual sports.The Circuit Court of Ohio County granted M.D. a preliminary injunction, allowing her to play for both teams. Subsequently, the court granted her summary judgment and a permanent injunction, ruling that the Non-school Participation Rule was arbitrary and capricious because it unfairly differentiated between team and individual sports without a rational basis.The WVSSAC appealed the circuit court's decision. While the appeal was pending, the WVSSAC's Board of Control amended the Non-school Participation Rule to eliminate the distinction between team and individual sports, applying the same restrictions to all student athletes regardless of the type of sport.The Supreme Court of Appeals of West Virginia reviewed the case and determined that the amendments to the Non-school Participation Rule rendered the appeal moot. The court found that the substantive changes to the rule addressed the issues raised by M.D., and there were no sufficient collateral consequences or issues of great public interest that warranted further review. Consequently, the court dismissed the appeal as moot. View "West Virginia Secondary School Activities Commission v. David D. and Elizabeth D., Parents and Legal Guardians of M.D." on Justia Law

In August 2021, New York City’s Department of Education mandated COVID-19 vaccinations for all staff and contractors working in school settings. This mandate was updated over time, including a religious exemption process. The plaintiffs, New York City public sector employees, challenged the constitutionality of the mandate and the exemption process, both facially and as applied.The Southern District of New York denied a preliminary injunction and dismissed the consolidated amended complaint on the merits. The Eastern District of New York also denied a similar preliminary injunction motion. The plaintiffs appealed these decisions, leading to a consolidated review by the United States Court of Appeals for the Second Circuit.The Second Circuit affirmed in part and dismissed in part the denials of preliminary injunctions, affirmed the dismissal of the facial challenges, and affirmed in part while vacating and remanding in part the dismissal of the as-applied challenges. The court found that the request to rescind the vaccine mandate was moot due to its official rescission and denied the request for reinstatement and backpay, as the plaintiffs could not show irreparable harm post-termination. The court upheld the dismissal of the facial challenges, finding no evidence that the Citywide Panel process preferred certain religions or was infected with religious animus. However, the court vacated and remanded the as-applied challenges for plaintiffs Natasha Solon and Heather Clark, who plausibly alleged that their religious accommodation requests were improperly denied. View "New Yorkers for Religious Liberty v. City of New York" on Justia Law

A class of over 500,000 federal student loan borrowers sued the U.S. Department of Education for failing to process their borrower defense (BD) applications. The Department and the plaintiffs reached a settlement, which included automatic debt forgiveness for certain borrowers and streamlined adjudication for others. Three for-profit universities (the Schools) listed in the settlement as having substantial misconduct intervened, claiming reputational harm.The U.S. District Court for the Northern District of California approved the settlement and denied the Schools' motion to intervene as of right but allowed them to object to the settlement. The Schools appealed, arguing that the settlement caused them reputational and financial harm and interfered with their procedural rights.The United States Court of Appeals for the Ninth Circuit held that the Schools had Article III standing due to alleged reputational harm but lacked prudential standing to challenge the settlement because they did not demonstrate formal legal prejudice. The court found that the dispute between the plaintiffs and the Department was not moot, as the Department's voluntary cessation of issuing pro forma denials did not render the case moot. The court also affirmed the district court's denial of the Schools' motion to intervene as of right, concluding that the Schools did not have a significantly protectable interest and failed to show prejudice from the denial of intervention as of right.The Ninth Circuit dismissed the appeal in part and affirmed the district court's denial of intervention as of right. View "Sweet v. Everglades College, Inc." on Justia Law

Keith Schiebel, a veteran agriculture educator, brought an educational program called the "Mobile Maple Experience" to the Schoharie Central School District (SCSD) campus. Following the event, a student's mother reported that Schiebel made her daughter feel uncomfortable, leading to a Title IX investigation. Schiebel was accused of reaching around the student and touching her breast and buttocks while retrieving supplies. Schiebel denied recalling the incident but speculated that he might have reached around a student to get something. The Title IX coordinator, Kristin DuGuay, found the allegations credible and determined that Schiebel had committed sexual harassment, resulting in a five-year ban of the Mobile Maple Experience from the SCSD campus.The United States District Court for the Northern District of New York dismissed Schiebel's Title IX claim, stating that while he plausibly alleged an erroneous finding, he did not plausibly allege that sex-based bias was a motivating factor. The court declined to exercise supplemental jurisdiction over Schiebel's state law claims.The United States Court of Appeals for the Second Circuit reviewed the case and concluded that Schiebel plausibly alleged that SCSD violated Title IX. The court found that the investigation was so deficient as to constitute a sham and that the decision was inexplicable. Additionally, the court noted that the Title IX coordinator exhibited sex-based bias against Schiebel. The Second Circuit reversed the district court's judgment and remanded the case for further proceedings consistent with its opinion. View "Schiebel v. Schoharie Cent. Sch. Dist." on Justia Law

Justine Ferreira sought reimbursement from the New York City Department of Education (DOE) for her disabled son's private education during the 2019-2020 school year, claiming the DOE failed to provide a free appropriate public education (FAPE) as required by the Individuals with Disabilities Education Act (IDEA). The DOE had developed an individualized education plan (IEP) for her son, but Ferreira disagreed with it and enrolled him in a private school, iBrain. She alleged that the DOE's proposed public school placement was inadequate.The Impartial Hearing Officer (IHO) and the State Review Officer (SRO) both found that Ferreira's conduct impeded the DOE's efforts to develop a suitable IEP, as she failed to cooperate and provide necessary information. They concluded that the balance of equities did not favor reimbursement. The United States District Court for the Southern District of New York (Judge Torres) granted summary judgment in favor of the DOE, agreeing with the IHO and SRO that Ferreira's actions frustrated the DOE's attempts to fulfill its obligations under the IDEA.On appeal, the United States Court of Appeals for the Second Circuit held that a district court must independently evaluate the equities in IDEA reimbursement cases without deferring to the state administrative agency's conclusions. However, the court found that the district court had indeed conducted an independent review and did not abuse its discretion in denying reimbursement. The court affirmed the district court's judgment, concluding that Ferreira's lack of cooperation and obstruction justified the denial of reimbursement for her son's private school tuition. View "Ferreira v. Aviles-Ramos" on Justia Law

Orthodox Jewish families and schools challenged California's requirement that private schools be nonsectarian to provide special education under the IDEA. The families argued this requirement violated their Free Exercise and Equal Protection rights by preventing them from advocating for religious school placements for their children with disabilities. The schools claimed the requirement barred them from certification solely due to their religious affiliation.The U.S. District Court for the Central District of California dismissed the case, ruling the schools and one family lacked standing and denying the families' motion for a preliminary injunction. The court found the schools did not demonstrate they were "able and ready" to apply for certification and that the nonsectarian requirement did not affect the educational placement of one family's child. However, it held that another family had standing to challenge the requirement.The U.S. Court of Appeals for the Ninth Circuit affirmed the dismissal of the schools' and one family's claims for lack of standing but reversed the dismissal of the other families' claims. The court held that the nonsectarian requirement burdened the families' free exercise rights by preventing them from advocating for religious school placements. It found the requirement was not neutral to religion and applied strict scrutiny, concluding the State failed to show the requirement was narrowly tailored to serve a compelling interest. The court vacated the denial of the preliminary injunction and remanded for further consideration of the injunction factors. View "LOFFMAN V. CALIFORNIA DEPARTMENT OF EDUCATION" on Justia Law

The State of New York, through its Attorney General, sued the Niagara-Wheatfield Central School District, alleging that school officials failed to address repeated complaints of student-on-student sexual assault, harassment, and gender-based violence and bullying. The complaint detailed incidents involving four students who suffered from such misconduct and claimed that the school district ignored at least thirty similar incidents. The State argued that the school district's inaction affected not only the victims but also the broader school community, creating an unsafe environment.The United States District Court for the Western District of New York dismissed the case, concluding that the State lacked parens patriae standing. The court reasoned that the incidents were factually distinct and did not demonstrate a broader policy or practice of discrimination by the school district. Without such a policy or practice, the court held that the State could not show that the school district's conduct affected a substantial segment of the population, which is required for parens patriae standing.The United States Court of Appeals for the Second Circuit reviewed the case and reversed the district court's decision. The appellate court held that showing an injurious policy or practice is not necessary to satisfy the substantial-segment prong of the parens patriae standard. The court concluded that the State of New York had met its burden of pleading parens patriae standing at this stage of the litigation. The case was remanded for further proceedings consistent with the appellate court's opinion. View "New York v. Niagara-Wheatfield Central School District" on Justia Law

A former public school principal in Brooklyn, New York, brought a lawsuit against the New York City Department of Education (DOE) and its former chancellor, alleging retaliation after she complained about racially segregated sports teams at her school. The principal claimed that the DOE's investigation into her was a retaliatory action for her complaints about race discrimination affecting her students.The United States District Court for the Southern District of New York dismissed the principal's Title VI claim, reasoning that her challenge was related to an employment practice and that the primary objective of the federal funds received by the DOE was not to provide employment. The court also denied her motion for leave to amend her complaint, even after reconsidering its initial decision.The United States Court of Appeals for the Second Circuit reviewed the case and held that the principal's retaliation claim was not an action "with respect to any employment practice" under Title VI because her underlying protected activity was unrelated to the DOE’s employment practices. The court concluded that Title VI does provide a private right of action for retaliation claims when the retaliation is for opposing non-employment-related race discrimination. The court affirmed the dismissal of the claim against the former chancellor but vacated the dismissal of the Title VI claim against the DOE and remanded the case for further proceedings. View "Bloomberg v. N.Y.C. Department of Education" on Justia Law

A.H., a student at Tamalpais High School, was sexually abused by his tennis coach, Normandie Burgos. A.H. sued the Tamalpais Union High School District (the District) for negligent supervision, arguing that the District's employees failed to properly investigate a prior complaint against Burgos and did not adequately supervise him, which enabled the abuse. A jury found the District negligent and awarded A.H. $10 million in damages.The District appealed, claiming the trial court improperly instructed the jury and allowed inadmissible evidence regarding Burgos's conduct with other students. The District argued that the jury instructions failed to clarify that the District could not be held vicariously liable for Burgos's actions and that the District could only be liable for the conduct of its supervisory employees. The District also contended that evidence of Burgos's misconduct with other students and his 2019 criminal conviction was irrelevant and prejudicial.The California Court of Appeal, First Appellate District, Division Two, reviewed the case. The court found no instructional error, noting that the jury was properly instructed on the District's liability for negligent supervision and that the instructions adequately covered the relevant legal principles. The court also held that the evidence of Burgos's prior misconduct and the 2005 complaint were relevant to show what the District should have known about Burgos's propensity for abuse. Additionally, the court ruled that evidence of Burgos's 2019 criminal conviction was relevant to the issue of damages, as it demonstrated the ongoing psychological impact on A.H.The Court of Appeal affirmed the trial court's judgment, upholding the $10 million damages award to A.H. View "A.H. v. Tamalpais Union High School Dist." on Justia Law

A coalition of organizations and individuals, led by the Chinese American Citizens Alliance of Greater New York, filed a lawsuit against New York City's Mayor and Department of Education Chancellor. They challenged the revised admissions policy for the Discovery Program in the Specialized High Schools (SHSs), alleging it was intended to discriminate against Asian-American applicants by reducing their admission rates. The plaintiffs argued that the new policy, which included an Economic Need Index (ENI) criterion, negatively impacted Asian-American students.The United States District Court for the Southern District of New York granted summary judgment in favor of the City. The court concluded that the plaintiffs failed to demonstrate an aggregate disparate impact on Asian-American students, as required under Village of Arlington Heights v. Metropolitan Housing Development Corp. The court held that without showing a group-wide effect, the plaintiffs could not establish the necessary discriminatory effect for an equal protection claim.The United States Court of Appeals for the Second Circuit reviewed the case. The court assumed, for the purpose of the appeal, that the plaintiffs could prove the policy changes were made with discriminatory intent. The court concluded that the district court erred in requiring an aggregate disparate impact to establish discriminatory effect. Instead, the court held that if discriminatory intent is proven, a negative effect on individual Asian-American students would suffice to trigger strict scrutiny review. The court found that the exclusion of economically disadvantaged Asian-American students from certain middle schools due to the new ENI criterion constituted a sufficient discriminatory effect. Consequently, the Second Circuit vacated the district court's grant of summary judgment and remanded the case for further proceedings. View "Chinese Am. Citizens All. of Greater N.Y. v. Adams" on Justia Law