Justia Education Law Opinion Summaries

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

The case involves a challenge to the constitutionality of the 2023 Act No. 8 (S. 39), known as the Education Scholarship Trust Fund (ESTF) Act, which establishes a fund to provide scholarships for qualifying educational expenses, including private school tuition. Petitioners argue that the Act violates South Carolina's constitutional prohibition against using public funds for the direct benefit of private educational institutions.The lower courts did not review this case; it was accepted directly by the South Carolina Supreme Court in its original jurisdiction. Petitioners sought an injunction and declaratory judgment, claiming the Act violated several provisions of the South Carolina Constitution, including Article XI, Sections 2, 3, and 4, and Article X, Sections 5 and 11.The South Carolina Supreme Court held that portions of the Act violate the state constitution's prohibition against using public funds for the direct benefit of private educational institutions. The court found that the ESTF funds are public funds and that using these funds for private school tuition constitutes a direct benefit to private educational institutions, which is unconstitutional under Article XI, Section 4. The court severed and declared unconstitutional the provisions of the Act that allowed payments from ESTF scholarships for tuition and fees at private educational institutions. The court enjoined the Department of Education from disbursing ESTF scholarships for these purposes. The court's decision was guided by the principle that legislative policy must conform to constitutional mandates, and it emphasized the importance of adhering to the plain meaning of constitutional text. View "Candace Eidson v. South Carolina Dept. of Education" on Justia Law

The case involves two transgender girls, Jane Doe and Megan Roe, who wish to participate in girls' sports at their respective schools in Arizona. Both girls have not undergone male puberty due to puberty-blocking medication and hormone therapy. Arizona enacted the Save Women’s Sports Act, which prohibits "students of the male sex," including transgender women and girls, from participating in women’s and girls’ sports. The plaintiffs argue that this Act violates the Equal Protection Clause of the Fourteenth Amendment and Title IX.The United States District Court for the District of Arizona reviewed the case and granted a preliminary injunction, preventing the enforcement of the Act against the plaintiffs. The court found that the Act was adopted with the purpose of excluding transgender girls from girls' sports teams and concluded that the plaintiffs were likely to succeed on their equal protection and Title IX claims. The court determined that before puberty, there are no significant differences in athletic performance between boys and girls and that transgender girls who receive puberty-blocking medication do not have an athletic advantage over other girls.The United States Court of Appeals for the Ninth Circuit reviewed the district court’s decision. The Ninth Circuit affirmed the district court’s order, agreeing that the Act discriminates based on transgender status and is subject to heightened scrutiny. The court held that the Act’s categorical ban on transgender girls from participating in girls' sports is not substantially related to the state’s objectives of ensuring competitive fairness and equal athletic opportunities for female student-athletes. The court also found that the plaintiffs would suffer irreparable harm without the injunction and that the balance of equities and public interest favored granting the preliminary injunction. View "DOE V. HORNE" on Justia Law

Two students receiving special education services filed a class action lawsuit against the Kanawha County Board of Education, alleging that the Board denied them and other similarly situated students a free appropriate public education (FAPE) as guaranteed by the Individuals with Disabilities Education Act (IDEA). The lawsuit also claimed violations of Title II of the Americans with Disabilities Act (ADA) and Section 504 of the Rehabilitation Act. The district court certified a class of all Kanawha County Schools students with disabilities who need behavior supports and have experienced disciplinary removals from any classroom.The United States District Court for the Southern District of West Virginia granted the plaintiffs' motion to certify the class, reasoning that the plaintiffs had presented expert evidence of disproportionate rates of suspension for students with disabilities and a detailed qualitative analysis of student records. The court found that these factors revealed a cohesive pattern indicating the absence of an effective system for developing and implementing behavioral supports for students with disabilities. The Board appealed, arguing that the certification of the plaintiff class was inconsistent with Federal Rules of Civil Procedure 23(a) and (b)(2).The United States Court of Appeals for the Fourth Circuit reviewed the case and reversed the district court’s certification order. The Fourth Circuit held that the certified class failed to satisfy Rule 23(a)(2)’s commonality prerequisite. The court found that the plaintiffs did not identify a common contention central to the validity of all class members’ claims. The court noted that the claims were highly diverse and individualized, involving different practices at different stages of the special education process. The absence of a common contention foreclosed class treatment. The case was remanded for further proceedings consistent with the opinion. View "G.T. v. The Board of Education of the County of Kanawha" on Justia Law

G.M., a second-grade student with dyslexia and ADHD, was deemed ineligible for special education by Howard County Public Schools (HCPS) under the Individuals with Disabilities Education Act (IDEA). His parents, disagreeing with this determination, pursued the IDEA’s dispute resolution process, which included a state administrative hearing. The administrative law judge (ALJ) sided with HCPS, leading G.M.’s parents to file a lawsuit in federal district court. The district court upheld the ALJ’s decision, prompting an appeal to the United States Court of Appeals for the Fourth Circuit.The ALJ conducted a six-day hearing, considering evidence from both sides. G.M.’s parents presented private evaluations indicating deficiencies in reading and writing, while HCPS provided assessments showing average performance. The ALJ found HCPS’s evidence more persuasive, concluding that G.M. did not exhibit a pattern of strengths and weaknesses necessary to qualify as having a specific learning disability (SLD) under the IDEA. The ALJ also determined that although G.M. had an other health impairment (OHI) due to ADHD, he did not need special education because he was performing adequately relative to grade-level standards.The United States Court of Appeals for the Fourth Circuit affirmed the district court’s judgment. The court held that the ALJ’s factual findings and credibility determinations were regularly made and thus entitled to deference. The court agreed that G.M. did not qualify as a “child with a disability” under the IDEA because he did not exhibit the necessary pattern of strengths and weaknesses in reading and writing, and his ADHD did not necessitate special education. The court also found that G.M. received a free appropriate public education (FAPE) without special education services, as he was achieving passing marks and advancing from grade to grade. Consequently, HCPS did not substantively violate the IDEA, and G.M. was not entitled to the requested relief. View "G.M. v. Barnes" on Justia Law

K.N., an eight-year-old boy with multiple disabilities, lives in a non-wheelchair-accessible apartment in the District of Columbia. His mother, Margda Pierre-Noel, requested that the District and his school, Bridges Public Charter School, provide assistance to move K.N. from their apartment door to the school bus. The District denied the request, citing its policy that staff only retrieve students from the outermost door of their dwelling and do not physically lift or carry students.The Office of the State Superintendent of Education (OSSE) hearing officer ruled that it was beyond his authority to order the requested assistance but required OSSE to offer transportation services to and from the outer door of K.N.'s apartment building. Pierre-Noel then filed a lawsuit in the United States District Court for the District of Columbia, which granted summary judgment in favor of the District, ruling that the service requested was not a transportation service under the Individuals with Disabilities Education Act (IDEA).The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court held that the IDEA requires the District to provide door-to-door transportation services for K.N., as such services are necessary for him to benefit from his special education. The court found that the term "transportation" under the IDEA includes moving a child from their apartment door to the vehicle that will take them to school. The court vacated the district court's grant of summary judgment and remanded the case for further proceedings consistent with its opinion. The appeal was dismissed as moot with respect to Bridges Public Charter School, as K.N. was no longer enrolled there. View "Pierre-Noel v. Bridges Public Charter School" on Justia Law

The plaintiff, Jane Doe, challenged the Manchester School District's policy regarding transgender and gender non-conforming students. The policy allowed students to keep their transgender status private and required school personnel to use a student's preferred name and pronouns, without disclosing this information to parents unless legally required or authorized by the student. Jane Doe, the parent of a minor child (M.C.) in the district, discovered that M.C. had asked to be called by a different name and pronouns. She requested the school to use M.C.'s birth name and pronouns, but the school adhered to the district policy.The Superior Court dismissed Jane Doe's claims, finding that the policy did not infringe upon a fundamental right and thus did not warrant strict scrutiny. The court applied the rational basis test and concluded that the policy was constitutional. The court also found that the policy was not ultra vires and did not violate federal laws such as the Family Educational Rights and Privacy Act (FERPA) or the Protection of Pupil Rights Act (PPRA).The Supreme Court of New Hampshire reviewed the case and affirmed the lower court's decision. The court held that the policy did not directly interfere with the fundamental right to parent, as it did not prevent parents from obtaining information from other sources or restrict their ability to parent their child. The court agreed that the policy did not infringe on a fundamental right and thus was subject to rational basis review, which it survived. The court did not find it necessary to address the plaintiff's facial and as-applied challenges separately, as the policy was found to be constitutional under the rational basis test. View "Doe v. Manchester School District" on Justia Law

The plaintiffs, parents of Idaho school children, sought reimbursement for fees associated with educational and extracurricular activities within Idaho public school districts. They argued that these fees were improperly assessed because the Idaho Constitution mandates "free common schools," and that the payment of such fees constituted a taking of property without due process, violating the Takings Clause of the Fifth Amendment.The United States District Court for the District of Idaho initially denied the school districts' motion for summary judgment, concluding that the plaintiffs had a property interest in a free education under the Idaho Constitution. However, the case was later reassigned to a different district judge, who revisited the issue. The second district judge granted summary judgment in favor of the school districts, concluding that the plaintiffs did not possess a property right protected by the Takings Clause because the right to a free public education in Idaho does not constitute a vested private property interest.The United States Court of Appeals for the Ninth Circuit affirmed the district court's summary judgment. The court held that the Idaho Constitution does not create a vested private property interest in specific educational benefits. It determined that public education in Idaho lacks the essential characteristics of private property, such as the right to possess, use, dispose of, or sell. Therefore, money paid to satisfy fees related to supplemental educational services is not subject to a Takings Clause claim. The court also clarified that a second district judge should not reconsider a prior judge's ruling unless specific conditions are met, but found any procedural error in this case to be harmless. View "Zeyen v. Bonneville Joint District" on Justia Law