Justia Education Law Opinion Summaries

After a fatal school shooting occurred at a high school in Michigan, H.H., an eighth-grade student at a different school, was reported by several classmates to have made threatening comments about possessing or bringing a gun to campus. The school administration, in response to these reports and heightened safety concerns, questioned H.H. with assistance from law enforcement, searched his person, backpack, and locker, and ultimately found no firearm. Despite this, the administration determined that H.H. had violated the school district’s code of conduct and referred him for an expulsion hearing, which resulted in his expulsion for 180 days.Following the expulsion, H.H.’s parents filed a lawsuit in the United States District Court for the Eastern District of Michigan against the school district and various officials. They raised claims under 42 U.S.C. § 1983 for alleged violations of H.H.’s Fourth Amendment rights (unlawful search and seizure), procedural and substantive due process, and also asserted state law tort claims. The district court granted summary judgment in favor of the defendants on all claims, finding no constitutional violations and determining that the defendants were immune from state law liability.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo. The court held that the search and seizure of H.H. were reasonable under the circumstances, given the nature of the reported threat and school safety concerns. It found that the procedures afforded to H.H. during the expulsion process satisfied due process requirements, and there was no evidence of bias or arbitrary conduct by the school board. The court also concluded that the individual defendants were entitled to qualified immunity, and that governmental immunity barred the state tort claims. The Sixth Circuit affirmed the district court’s judgment in full. View "Halasz v. Cass City Public Schools" on Justia Law

A group of Oklahoma taxpayers, parents of public school children, teachers, and clergy challenged the adoption of the 2025 Oklahoma Academic Standards for Social Studies. They argued that the new standards promoted Christianity over other religions, required teaching religious stories as historical fact, and included instructions to question the legitimacy of the 2020 Presidential Election and the origins of COVID-19. The petitioners claimed these standards violated state statutes, the Oklahoma Constitution, and their rights as parents and citizens. They further alleged that the procedure used to adopt the standards violated the Oklahoma Open Meeting Act, as the public and several Board members received the final version less than twenty-four hours before the Board meeting where the standards were approved.No lower court reviewed this case prior to the current proceeding. The petitioners brought their claims directly to the Supreme Court of the State of Oklahoma by seeking original jurisdiction, requesting declaratory, injunctive, and mandamus relief, and a stay of enforcement. The Supreme Court previously issued a temporary stay to prevent the implementation of the 2025 Standards while considering the matter.The Supreme Court of the State of Oklahoma assumed original jurisdiction due to the statewide importance and urgency of the controversy. The Court held that the 2025 Oklahoma Academic Standards for Social Studies were adopted in violation of the Oklahoma Open Meeting Act, specifically because the public and Board members did not receive proper notice of the content to be considered and acted upon. The Court determined that legislative “deemed approval” did not cure this procedural violation. As a result, the Court declared the 2025 Standards unenforceable, dissolved the earlier stay, and reinstated the 2019 standards until new standards are properly adopted and reviewed. The request for mandamus relief was withheld without prejudice. View "RANDALL v. FIELDS" on Justia Law

Several parents of disabled children brought a class action against the New York City Department of Education, the Board of Education of the City School District of New York, and the Chancellor, alleging that the defendants violated the Individuals with Disabilities Education Act (IDEA). The plaintiffs claimed the defendants maintained a policy of discontinuing special education services to disabled students before their twenty-second birthday, despite federal and state guidance and previous case law indicating that such services should continue until that age.The United States District Court for the Southern District of New York dismissed the suit, finding that it lacked subject-matter jurisdiction because the plaintiffs had not exhausted administrative remedies as generally required under the IDEA. The district court agreed with the defendants’ argument that exhaustion was necessary and rejected the plaintiffs’ contention that exhaustion would be futile due to the existence of a blanket, citywide policy.On appeal, the United States Court of Appeals for the Second Circuit reviewed the district court’s dismissal. The appellate court clarified that the IDEA’s exhaustion requirement is not jurisdictional but is instead a claim-processing rule, meaning that failure to exhaust is not a bar to the court’s power to hear the case. The Second Circuit held that exhaustion of administrative remedies is excused when plaintiffs challenge a policy or practice of general applicability that is contrary to law and when the purposes of exhaustion—such as developing a factual record or utilizing agency expertise—would not be served. Because the plaintiffs’ claims raised a purely legal question regarding the validity of a blanket policy, the court found that exhaustion would be futile. The Second Circuit vacated the district court’s dismissal and remanded the case for further proceedings. View "J.M. v. New York City Dept. of Ed." on Justia Law

The Borough of Sea Bright previously operated as a non-operating school district, sending its kindergarten through eighth-grade students to the Oceanport School District and its high school students to Shore Regional High School District. In 2009, following legislative changes, Sea Bright merged with Oceanport for K-8 education, while continuing its relationship with Shore Regional for grades 9-12. In 2022, Sea Bright sought to withdraw from both Oceanport and Shore Regional in order to join with the Boroughs of Highlands and Atlantic Highlands and Henry Hudson Regional High School to form an all-purpose regional school district serving all grade levels. Sea Bright adopted a resolution supporting this proposal.After Sea Bright and other municipalities filed a joint petition for regionalization with the New Jersey Commissioner of Education, Oceanport and Shore Regional challenged Sea Bright’s authority to seek withdrawal under N.J.S.A. 18A:13-47.11(a). The Commissioner of Education determined that Sea Bright was empowered by statute to pursue withdrawal from the two districts. Oceanport and Shore Regional appealed, arguing that merged districts were not included in the statutory authorization for withdrawal. The Superior Court, Appellate Division, affirmed the Commissioner’s decision, holding that Sea Bright was eligible to seek withdrawal and that statutory terms such as “consolidated” and “merged” were not intended to be distinct for this purpose.The Supreme Court of New Jersey reviewed the case and affirmed the Appellate Division’s judgment. The Court held that, based on the plain language of the relevant statutes and the legislative intent to promote regionalization, a municipality in Sea Bright’s position is a governing body authorized to pursue withdrawal from a school district to form or enlarge a regional school district under N.J.S.A. 18A:13-47.11(a). The Court did not address whether Sea Bright satisfied other statutory criteria, leaving that determination to the Commissioner of Education if Sea Bright files a petition. View "In the Matter of the Verified Petition for the Proposed Creation of a PK-12 All-Purpose Regional School District" on Justia Law

An elementary school student with autism, intellectual disability, and a speech impediment exhibited severe behavioral issues, including frequent elopement from school and toileting problems, which impeded his academic and social development. The student communicated primarily through gestures and a specialized iPad, and his academic performance lagged significantly behind grade level. The school district developed an individualized education program (IEP) that included special classes, therapy, and behavioral interventions. While the IEP initially included a limited extended-school-year (ESY) program to combat regression over breaks, the student continued to regress, particularly after school vacations, resulting in dangerous incidents and increasing parental concern.After disagreements arose regarding the adequacy of summer ESY services, the student’s parent requested a due process hearing, seeking more robust ESY support and additional accommodations. The hearing officer found that the school district had failed to provide a free appropriate public education under the Individuals with Disabilities Education Act (IDEA), ordering full-summer ESY services and year-round access to a communication device. The school district appealed the decision to the United States District Court for the Western District of Texas, which upheld the hearing officer’s findings, determining that the IEP was not sufficiently individualized and did not adequately address the student’s behavioral regression.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed whether the district court erred in finding the IEP deficient under IDEA standards. The Fifth Circuit affirmed the district court’s judgment, holding that the IEP was insufficiently individualized given the student’s severe behavioral regression and that the educational benefits provided—while academically positive—were outweighed by the failure to address nonacademic, safety-critical needs. The court concluded that the school district’s refusal to provide more effective ESY services denied the student an IDEA-appropriate education. View "North East Independent School District v. I.M." on Justia Law

A student at Kankakee Junior High School sustained a serious arm injury during a gym class soccer game. The physical education teacher, Dayhoff, was accused of failing to adequately supervise the class, specifically neglecting to monitor a student known as “Student A,” who allegedly had a history of physical aggression. The injured student and his parent filed suit against both the school district and Dayhoff, claiming willful and wanton conduct in supervision and seeking damages for medical expenses.The Circuit Court of Kankakee County granted summary judgment for the defendants—the school district and Dayhoff—finding they were immune from liability under the Local Governmental and Governmental Employees Tort Immunity Act. The court concluded that Dayhoff’s actions fell within discretionary policy determinations, and the plaintiffs’ allegations did not rise to willful and wanton conduct, but at most described negligence, which is immunized under the Act. The court also found no basis for recovery under the Family Expense Act.The Appellate Court of Illinois, Third District, reversed the circuit court’s ruling, holding that disputed issues of fact regarding Student A’s disciplinary history and the defendants’ knowledge thereof precluded summary judgment on the question of willful and wanton conduct. On appeal, the Supreme Court of Illinois reviewed the record de novo and determined that the plaintiffs failed to provide evidence that Dayhoff knew or should have known of Student A’s history of aggression, and did not plead an independent claim against the district for failing to inform teachers. The Supreme Court held that the facts supported only a claim of negligent supervision, not willful and wanton conduct, and that section 3-108 of the Tort Immunity Act immunized the defendants. The Supreme Court reversed the appellate court and affirmed summary judgment for the defendants. View "Haase v. Kankakee School District 111" on Justia Law

The case involves claims brought by the parents of a minor child, P.F., who was allegedly bullied, harassed, and assaulted by another student at Clay Elementary School during the 2022–2023 school year due to his sexual orientation. The parents assert that the school district and three employees were aware of these incidents but failed to protect P.F. or notify his parents, instead blaming P.F. or dismissing the other student’s conduct. After removing P.F. from the school and filing reports with authorities, the parents pursued legal action, first filing a complaint with the Iowa Civil Rights Commission (ICRC), which issued a right-to-sue letter. The parents then filed an amended petition in the Iowa District Court for Polk County, asserting three claims under the Iowa Civil Rights Act (ICRA) and three common law tort claims.The defendants moved to dismiss all claims, arguing that the heightened pleading requirements and qualified immunity provisions of the Iowa Municipal Tort Claims Act (IMTCA), as amended by Iowa Code section 670.4A, applied. The Iowa District Court for Polk County denied the motion, finding that the ICRA claims were not torts subject to the IMTCA and that the common law claims met the IMTCA’s pleading standard. The defendants appealed, asserting a right to immediate appeal under section 670.4A(4).The Iowa Supreme Court reviewed the appeal and held that the IMTCA’s qualified immunity and heightened pleading requirements do not apply to claims brought under the ICRA or to common law tort claims, as clarified in Doe v. Western Dubuque Community School District. Because section 670.4A did not apply to any of the claims, the defendants were not entitled to an appeal as of right. The court dismissed the appeal for lack of appellate jurisdiction and remanded the case. View "Fogle v. Clay Elementary School-Southeast Polk Community School District" on Justia Law

A.P. was a student in Pearland Independent School District who, after a period of homeschooling, returned to the District and began experiencing significant attendance problems. Despite passing her classes with targeted intervention, her absenteeism persisted, and she failed multiple advanced courses that her parents insisted she take against the District’s advice. Her teachers consistently attributed her academic struggles to poor attendance rather than any suspected learning disability. The District recommended less challenging courses and additional support programs, but her parents declined these options and continued to excuse her absences for non-serious reasons.After withdrawing A.P. from the District and homeschooling her, her parents requested a due process hearing, alleging that the District failed to identify and evaluate her for learning disabilities under the Individuals with Disabilities in Education Act (IDEA). The District offered to conduct an evaluation, but her parents refused consent. Instead, they obtained an independent evaluation, which found some learning disabilities but lacked classroom observations and teacher input. The District determined it did not have enough information to assess her eligibility for special education services. A Special Education Hearing Officer found no IDEA violation, and the United States District Court for the Southern District of Texas affirmed, concluding that the District met its child find obligation and that A.P.’s academic issues were primarily due to absenteeism.The United States Court of Appeals for the Fifth Circuit reviewed the case, applying de novo review to mixed questions of law and fact and clear error review to factual findings. The Fifth Circuit held that the District’s child find duty was not triggered by A.P.’s absenteeism or poor grades alone, and that her parents failed to prove she qualified for special education under IDEA. The court affirmed the district court’s judgment. View "A.P. v. Pearland Independent School District" on Justia Law

Several former students and their parents challenged a school district’s policy restricting the length of male students’ hair, alleging that the policy constituted race and sex discrimination and violated constitutional and statutory rights. The school district amended its hair policy during the 2019–2020 school year, removing language that previously allowed certain hairstyles, such as cornrows or locs, if they complied with other requirements. The plaintiffs argued that the enforcement of this policy infringed upon their rights under the Fourteenth Amendment, the First Amendment, Title VI, Title IX, and Texas law.The case was initially heard in the United States District Court for the Southern District of Texas. During discovery, the plaintiffs sought to depose the superintendent and a former board president. The school district moved for a protective order, asserting legislative privilege to prevent inquiries into the subjective motivations of board members regarding the hair policy. The district court partially denied the motion, establishing a procedure where deponents could assert the privilege but would still be required to answer, with disputed portions of testimony marked confidential for later review. The district court declined to rule on the privilege’s applicability until specific questions were asked during depositions.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed whether the district court erred in its handling of the legislative privilege and the protective order. The Fifth Circuit held that none of the appellants—including the school district, the board of trustees, and the individual former officials—had standing to appeal the district court’s order because the privilege holders had not personally invoked the privilege or participated adequately in the proceedings. As a result, the Fifth Circuit dismissed the appeal for lack of jurisdiction and also dismissed the pending motion to stay as moot. View "Arnold v. Barbers Hill Independent School District" on Justia Law

A group of student and parent organizations, along with individual students, brought suit against state and city officials responsible for New York City’s public education system. They alleged that admissions and screening policies, curriculum content, and a lack of teacher diversity in the city’s schools discriminated against Black and Latino students, resulting in segregation, unequal educational opportunities, and poor educational outcomes. The plaintiffs claimed these practices violated the New York State Constitution’s Education Article, the State Equal Protection Clause, and the New York State Human Rights Law, seeking declaratory and injunctive relief to eliminate admissions screens and address alleged discrimination.The Supreme Court, New York County, dismissed the complaint, finding the issues nonjusticiable as they involved educational policy decisions reserved for the legislature. The Appellate Division, First Department, modified that decision, holding that the claims were justiciable and that the complaint stated viable causes of action under the Education Article, the Equal Protection Clause, and, as to the City defendants, the Human Rights Law. The Appellate Division granted leave to appeal and certified the question of whether its order was properly made.The New York Court of Appeals reviewed the sufficiency of the complaint under the standard for motions to dismiss. The Court held that the plaintiffs failed to adequately plead a deprivation of a sound basic education, as their allegations of deficient resources and discriminatory policies were vague, conclusory, and did not demonstrate a district-wide failure or causation. The Court also found that the equal protection claim lacked sufficient allegations of intentional discrimination, and the Human Rights Law claim was not supported by specific facts. The Court of Appeals modified the Appellate Division’s order and dismissed the complaint, answering the certified question in the negative. View "IntegrateNYC, Inc. v State of New York" on Justia Law