Justia Education Law Opinion Summaries

A student with Down syndrome, C.B., attends school in the Henry County School District in Georgia. Under the Individuals with Disabilities Education Act (IDEA), the school district was required to develop an individualized education program (IEP) for C.B. After reviewing C.B.’s progress in fourth grade, the school district’s IEP team decided to move C.B. from an interrelated resource (IRR) class to a mild intellectual disability (MID) class for language arts and math. C.B.’s parents disagreed with this new placement, believing the IRR class was less restrictive and more appropriate. They also objected to the school district’s decision to place C.B. on an alternative assessment track, rather than the regular statewide assessment.Following the school district’s decision, C.B.’s parents requested a due process hearing before the Georgia Office of State Administrative Hearings. The administrative law judge conducted a five-day hearing and found that the school district had complied with IDEA in making the placement decision and that the Georgia Alternate Assessment was appropriate for C.B. The United States District Court for the Northern District of Georgia affirmed the administrative law judge’s findings regarding the placement, concluding that the least restrictive environment requirement under IDEA did not apply to the choice between different types of special education classes. The district court also found C.B.’s claim regarding the alternative assessment moot, since C.B. was no longer required to take the alternative assessment.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s decision regarding the placement in the MID class, holding that the least restrictive environment requirement under IDEA does not apply to placement decisions among special education classes. However, the court reversed the district court’s mootness determination on the assessment claim and remanded the case for further proceedings on that issue. View "C.B. v. Henry County School District" on Justia Law

David Christianson was employed during the 2023-24 school year as a teacher at Grand Forks Red River High School, holding both a standard teaching contract and two additional “director contracts” for Pep Band Director and Music-Instrumental Head Director. After two pranks occurred under his supervision at graduation events, Christianson was reassigned to a different school and his director contracts were not renewed. He pursued a grievance with the School District, culminating in a formal hearing and a School Board denial of his appeal. The School Board subsequently issued a written decision two days after the contractual deadline, prompting Christianson to formally object.The case was reviewed by the District Court of Grand Forks County, Northeast Central Judicial District. Both parties moved for summary judgment. The School District argued Christianson was required to arbitrate his grievance before pursuing litigation, while Christianson claimed the School District failed to follow mandatory nonrenewal procedures. The district court found that the School District had waived its right to enforce arbitration by not complying with contractual notice requirements and determined that Christianson’s director contracts were extracurricular, not curricular. Therefore, statutory nonrenewal procedures did not apply. Summary judgment was granted in favor of the School District.Upon appeal, the Supreme Court of the State of North Dakota reviewed the case de novo. The Court affirmed the district court’s judgment, holding that the School District’s failure to timely provide written notice constituted a waiver of its right to require arbitration. The Court further held that Christianson’s director contracts were extracurricular and not subject to teacher contract nonrenewal protections under North Dakota law. The judgment of the district court was affirmed. View "Christianson v. Grand Forks Public School District" on Justia Law

A nonprofit organization and several school boards challenged Kentucky House Bill 9, which authorized state funding for charter schools, alleging it violated Sections 183, 184, and 186 of the Kentucky Constitution. The bill permitted charter schools to receive public funds but allowed them to operate independently from local school districts, with enrollment caps and admissions preferences that could exclude some eligible children. Charter schools were also exempt from certain state and district regulations applicable to public schools.The Franklin Circuit Court reviewed the case and found that HB 9 was inconsistent with the constitutional requirement for an efficient system of common schools. The court concluded that using tax dollars to support charter schools violated constitutional provisions reserving education funding for common schools and public schools only. As a result, the circuit court enjoined the implementation of HB 9 and prohibited the expenditure of tax dollars for charter schools under the statute.The Supreme Court of Kentucky granted motions to transfer the appeals directly to its docket. Upon review, the Court held that charter schools authorized by HB 9 do not qualify as “common schools” or “public schools” as contemplated by Sections 183, 184, and 186 of the Kentucky Constitution. The Court determined that charter schools’ admission limitations, lack of local district oversight, and exemption from certain regulations placed them outside the constitutionally protected common school system. Therefore, funneling public education funds to charter schools under HB 9 is unconstitutional. The Court affirmed the Franklin Circuit Court’s decision, upholding the prohibition on public funding for charter schools unless voter approval is obtained as provided in Section 184. View "COMMONWEALTH OF KENTUCKY V. COUNCIL FOR BETTER EDUCATION, INC." on Justia Law

The case concerns a dispute between a parent and the New York City Department of Education regarding the appropriate special education classroom placement for a student, O.F., who has severe disabilities including cerebral palsy, visual impairment, seizure disorder, and scoliosis. In 2020, O.F.’s Committee on Special Education (CSE) recommended a 6:1:1 placement in a specialized public school. The following year, after O.F. had not attended school during the pandemic, the CSE recommended a 12:1+(3:1) class configuration, considering O.F.’s lack of progress and his need for more individualized and specialized instruction. The parent challenged this recommendation, seeking tuition reimbursement for O.F.’s placement at a private school.After a due process complaint, the matter was reviewed in an administrative hearing before an impartial hearing officer (IHO), who found the 12:1+(3:1) class appropriate for O.F. Upon appeal, the State Review Officer (SRO) upheld the IHO’s finding. The parent then brought the case to the United States District Court for the Southern District of New York, which granted summary judgment in favor of the City DOE, agreeing the placement was suitable based on O.F.’s needs and the regulatory requirements. The parent appealed, and the United States Court of Appeals for the Second Circuit certified a question to the New York Court of Appeals regarding the interpretation of 8 NYCRR 200.6 (h) (4).The New York Court of Appeals held that 8 NYCRR 200.6 (h) (4) sets forth a list of mutually exclusive alternatives for special education class sizes and staffing. The court determined that a CSE must select the listed alternative that best meets a student’s individual needs, rather than fulfilling multiple class size constraints simultaneously. The certified question was answered accordingly. View "Cruz v Banks" on Justia Law

A field consultant for a public teachers’ union brought a lawsuit after a school board held a closed executive session during a grievance hearing involving a teacher’s transfer and removal of extracurricular duties. The board’s attorney presented the school district’s legal position and rationale in an open meeting before the board entered executive session to receive additional legal advice. The board later voted in public to deny the grievance, and the plaintiff, who was not the aggrieved teacher, claimed the executive session violated North Dakota’s open meetings laws. She sought disclosure of the executive session recording as a remedy. The District Court of Grand Forks County granted summary judgment to the school district, finding no waiver of the right to enter executive session, that the requirements for the attorney consultation exemption were met, and that the plaintiff’s due process rights were not violated by her lack of access to the executive session transcript. The court declined to review the executive session recording, relying instead on declarations from board representatives and the parties’ stipulation that no material facts were in dispute. On appeal, the Supreme Court of the State of North Dakota affirmed in part and reversed in part. The court held that the school board did not waive its right to an executive session by publicly stating its legal position and that the statutory requirements for entering executive session were satisfied. The court also found no due process violation from not providing the plaintiff access to the transcript. However, the Supreme Court concluded that the district court abused its discretion by not conducting an in camera review of the executive session recording before granting summary judgment. The judgment of dismissal and the award of costs to the school district were reversed, and the case was remanded for the district court to review the recording and proceed accordingly. View "Haskell v. Grand Forks Public Schools" on Justia Law

In 1965, individuals filed a class action lawsuit against the public schools in St. Mary Parish, Louisiana, seeking to end segregation and secure injunctive relief. The district court granted an injunction requiring desegregation and oversight, with subsequent orders and modifications over the years as the parties and courts responded to compliance issues and changes in the law. After a period of inactivity, new representatives and counsel stepped in around 2018–2019, seeking to further modify the original injunction. The School Board responded by filing motions challenging the procedural propriety of the new plaintiffs, the court’s subject matter jurisdiction, and the ongoing validity of the injunction.The United States District Court for the Western District of Louisiana allowed the substitution of new plaintiffs, denied the Board’s motions to dismiss, and recertified the class, despite acknowledging factors that weighed against doing so. The Board did not appeal immediately but later renewed its objections, moving to dissolve the decades-old injunction and to strike or dismiss the new plaintiffs’ motions for further relief. The district court denied the Board’s motions to dismiss and to strike, and clarified that the Board could not present certain arguments under Rule 60(b)(5) at an upcoming hearing. The Board appealed these rulings.The United States Court of Appeals for the Fifth Circuit reviewed whether it had appellate jurisdiction under 28 U.S.C. § 1292(a)(1), which allows interlocutory appeals of orders granting, continuing, modifying, or refusing to dissolve injunctions. The Fifth Circuit held that the district court’s orders did not have the practical effect of continuing, modifying, or refusing to dissolve the injunction, but merely maintained the status quo pending further proceedings. As such, the appellate court determined it lacked jurisdiction to consider the appeal and dismissed it for want of appellate jurisdiction. View "Navy v. Sch Bd of St. Mary Prsh" on Justia Law

Several organizations and individuals petitioned to prevent the Idaho State Tax Commission from implementing a newly enacted parental choice tax credit. This tax credit, established in 2025, provides refundable credits to parents, guardians, and foster parents for certain private educational expenses, including private school tuition and related services, for dependent students not enrolled in public schools. The law caps total annual credits and includes prioritization based on income and previous participation. The petitioners, including advocacy groups, a school district, and parents, argued that the statute creates a separate, non-public education system funded by public resources, allegedly violating the Idaho Constitution’s mandate for a single, general, uniform, and thorough system of public schools. They also claimed the statute failed the “public purpose doctrine,” asserting it primarily benefits private rather than public interests.Before the Idaho Supreme Court, the petitioners sought a writ of prohibition, which would prevent the Tax Commission from carrying out the law. The respondents, including the State and the Idaho Legislature, contested the petitioners’ standing and the merits of the constitutional claims. The Supreme Court determined that the petitioners lacked traditional standing but, given the urgency and importance of the constitutional question and the absence of another suitable challenger, relaxed standing requirements to address the merits.The Supreme Court of Idaho denied the petition. It held that Article IX, section 1 of the Idaho Constitution does not restrict the legislature from enacting educational measures beyond the required public school system, so long as the public system remains intact and constitutionally sufficient. The Court also found that the tax credit serves a legitimate public purpose—supporting parental choice in education—even if private entities benefit. The petition was dismissed, and the Tax Commission was awarded attorney fees and costs. View "Committee to Protect and Preserve v. State" on Justia Law

Two children were placed in the temporary custody of the Department of Children, Youth, and Families (DCYF) by the Family Court in 2018. The Family Court determined that Newport and Cumberland were responsible municipalities for the children’s education, as they were the residences of the custodial parents. DCYF placed the children in residential treatment facilities where they received general education services, but not special education services.DCYF requested orders from the Commissioner of Elementary and Secondary Education that Newport and Cumberland reimburse DCYF for education costs at the per-pupil special-education rate. The commissioner agreed and ordered the municipalities to pay at that rate. Both municipalities appealed to the Council on Elementary and Secondary Education, which denied their appeals. The municipalities then appealed to the Rhode Island Superior Court under the Administrative Procedures Act. The Superior Court consolidated the cases and found that the statute required the municipalities to pay their share of educational costs, but not at the special-education rate unless special education services were provided. The trial justice also held that, even after statutory amendments removed references to general education, the municipalities were still responsible for the per-pupil general-education rate for children not receiving special education.On review, the Supreme Court of Rhode Island considered whether the municipalities were obligated to pay the general-education rate after the statutory reference to general education was removed. The Court held that the plain language of the statute only requires reimbursement for special education costs and does not obligate municipalities to pay for general education where no special education services are provided. The Supreme Court quashed the decision of the Superior Court. View "Newport School Committee v. Rhode Island Department of Education" on Justia Law

Three parents of students in Philadelphia challenged the School District’s 2022 Admissions Policy for four selective public high schools. Prior to 2022, admissions decisions were made by individual schools using academic criteria, attendance, and sometimes additional requirements such as interviews and writing samples. After a report identified geographic disparities in school representation, and following the School District’s public commitments to anti-racism and equity, a new centralized policy was adopted. This policy introduced revised academic standards, eliminated certain prior requirements, and implemented a zip code preference favoring applicants from six areas with high Black and Hispanic populations. Qualified applicants from these zip codes received automatic admission, while others had to enter a lottery for remaining seats.The parents, whose children lived outside the preferred zip codes and met the new criteria but were not admitted to their first-choice schools, filed suit in the United States District Court for the Eastern District of Pennsylvania. They alleged violations of Title VI, the Equal Protection Clause, and related state constitutional provisions, arguing that the new process was racially discriminatory. The District Court granted summary judgment for the School District, finding that no reasonable factfinder could conclude the policy had a racially discriminatory purpose or impact. The court applied rational basis review, holding the policy was rationally related to legitimate interests such as increasing access for underrepresented geographic areas.On appeal, the United States Court of Appeals for the Third Circuit held that, viewing the evidence in the light most favorable to the parents, a reasonable factfinder could conclude the Admissions Policy had both discriminatory purpose and impact. The Third Circuit vacated the District Court’s judgment and remanded for further proceedings, directing that strict scrutiny must be applied if a discriminatory purpose and impact are found. View "Sargent v. School District of Philadelphia" on Justia Law

A student was enrolled in a respiratory therapy program at a community college from 2017 to 2022. During her final year, supervisors at several hospitals where she completed clinical rotations reported concerns about her clinical performance, including patient safety issues and unprofessional conduct. After a series of incidents, she was suspended and ultimately dismissed from the program for violating the student code of conduct, specifically for conduct that endangered patient safety. The student argued that her difficulties were due to academic deficiencies rather than misconduct and also claimed she experienced discrimination based on her race and national origin.After her initial dismissal, the student sought review in the Somerset County Superior Court, which found the administrative record insufficient and remanded the matter for a new hearing. The college’s disciplinary committee held a second hearing, reviewed evidence from both the student and the administration, and again upheld her dismissal, explicitly finding no evidence of discrimination or bias. The student then brought a three-count action in the Superior Court: (1) an administrative appeal of her dismissal under Rule 80B, (2) a claim under 42 U.S.C. § 1983 for violation of procedural due process, and (3) a claim of unlawful educational discrimination under Maine law.The Maine Supreme Judicial Court held that the college’s decision to dismiss the student was not arbitrary or capricious and that the disciplinary process afforded her meaningful notice and an opportunity to be heard. The Court affirmed dismissal of the § 1983 and discrimination claims as duplicative of the administrative appeal, finding that her grievances were properly addressed through Rule 80B review, and that there was no evidence of discrimination or due process violations. The judgment of the Superior Court was affirmed. View "Hogan v. Kennebec Valley Community College" on Justia Law