Justia Education Law Opinion Summaries

Scott Williams was elected to serve on the Addison Community School Board for a six-year term and was chosen by his fellow board members to act as president for one year. During his presidency, Williams had a dispute with a staff member, leading to allegations that he harassed staff and improperly requested confidential information. Following an investigation and resolution drafted by board members, the Board voted to censure Williams and remove him from the presidency. Williams was not informed of the allegations against him before the meeting where his removal was voted upon.Williams filed suit in the United States District Court for the Eastern District of Michigan, alleging, among other claims, a violation of the Fair and Just Treatment clause of the Michigan Constitution and asserting that the school district was liable under respondeat superior. The district court granted summary judgment to the defendants on all claims, including the federal constitutional claims, and denied Williams’s motion for partial summary judgment on his Fair and Just Treatment claim. The district court chose to exercise supplemental jurisdiction over the state law claims after dismissing the federal claims.The United States Court of Appeals for the Sixth Circuit reviewed the case and determined that the district court abused its discretion by retaining supplemental jurisdiction over Williams’s Fair and Just Treatment claim. The appellate court found that the state law claim presented a novel and complex issue under Michigan law, particularly because Michigan courts have not yet determined whether a private right of action exists under the Fair and Just Treatment clause. The court held that, given the dismissal of all federal claims and the complexity of the remaining state constitutional issue, the district court should have declined to exercise supplemental jurisdiction. As a result, the Sixth Circuit vacated the district court’s judgment on the Fair and Just Treatment claim and remanded with instructions to dismiss this claim without prejudice. View "Williams v. Addison Community Schools" on Justia Law

A middle school student with significant mental health needs struggled academically and emotionally while enrolled in a public school district during the COVID-19 pandemic, when instruction was provided virtually. His parents, finding that the school’s Individualized Education Program (IEP) was inadequate to address his needs during this period, placed him in two successive out-of-state private residential treatment centers offering in-person education and mental health services. Throughout this time, the parents participated in several meetings with the district’s IEP Team and communicated their concerns about the insufficiency of the educational program provided.Afterward, the parents sought reimbursement from the school district for the costs associated with the residential placements, arguing that the district failed to offer their child a free appropriate public education (FAPE) as required under the Individuals with Disabilities Education Act (IDEA). An Administrative Law Judge (ALJ) denied their claim, concluding that the district had no duty to offer a FAPE during the relevant period because the parents had not expressly requested a new IEP document, and instead, had only requested IEP meetings. The United States District Court for the Southern District of California affirmed this determination, also reasoning that the parents’ requests for meetings did not obligate the district to develop or offer a new IEP.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that under both federal and California law, the purpose of an IEP meeting is to develop or revise an IEP that offers a FAPE. The court concluded that it was irrelevant whether the parents had requested an IEP “meeting” or an IEP “document,” and that participation in IEP meetings triggered the district’s ongoing obligation to offer a FAPE. The Ninth Circuit reversed the district court’s decision and remanded for further proceedings to determine whether the IEP offered satisfied the IDEA’s requirements and, if not, whether the student was entitled to reimbursement or other remedies. View "L.B. V. SAN DIEGO UNIFIED SCHOOL DISTRICT" on Justia Law

A teacher who had previously attained tenure in the Montgomery County public-school system resigned from that position in September 2019 after accepting an offer for a probationary teaching job with the Alabama Department of Youth Services School District (DYS). The teacher received an email in mid-September confirming the job offer, with instructions to begin work on October 7, 2019, after completing mandatory training. The teacher’s salary, benefits, and job responsibilities with DYS all began on October 7, and he completed multiple school years in the new role before receiving notice in April 2023 that his contract would not be renewed.The teacher filed suit in the Montgomery Circuit Court, seeking a declaration that he had acquired tenure under the Students First Act of 2011, which would entitle him to due-process protections before dismissal. The trial court held a bench trial and concluded that the teacher was tenured at the time of his nonrenewal, reasoning that his employment was “effective” upon the agreement in September 2019 and, in the alternative, that DYS was estopped from denying him tenure because he relied on the September email when resigning from his previous tenured position.On appeal, the Supreme Court of Alabama reversed the trial court’s decision. It held that, for purposes of the Students First Act, “effective employment” occurs when a teacher is required to report for work and is paid, not at the time of an offer or acceptance. Because the teacher’s employment with DYS became effective on October 7, 2019—after the statutory October 1 cutoff—he did not accrue a “complete” school year for 2019-2020 and did not acquire tenure before his contract was nonrenewed. The Court also rejected the application of equitable estoppel, finding no misleading conduct by DYS. The judgment was reversed and the case remanded. View "Smitherman v. Roberts" on Justia Law

A school administrator responsible for special education at a high school in Texas alleged that his employment was terminated in retaliation for reporting incidents of child abuse by teachers under his supervision and for cooperating with a subsequent Child Protective Services (CPS) investigation. He reported the incidents to his principal, participated in a CPS interview, and raised concerns about disciplinary actions and workplace conduct. After additional workplace conflicts and an EEOC complaint, his contract was ultimately terminated by the district’s Board of Trustees following a hearing, and his administrative appeal was unsuccessful.The United States District Court for the Eastern District of Texas reviewed the administrator’s claims, which included constitutional violations under the First and Fourteenth Amendments, retaliation for whistleblowing, and a civil conspiracy to violate his rights. The district court granted the defendants’ motions to dismiss for failure to state a claim, denied leave to amend the complaint, and denied a motion to alter or amend the judgment.On appeal, the United States Court of Appeals for the Fifth Circuit affirmed the district court’s judgment. The Fifth Circuit held that the administrator’s speech—reporting child abuse to his supervisor, participating in the CPS investigation, and refusing to characterize events as his supervisor wished—was made in his official capacity as an employee, not as a citizen, and was therefore not protected by the First Amendment. The court also found that he received appropriate procedural due process related to his termination and did not state a claim for substantive due process. The individual defendants were entitled to qualified immunity, and the civil conspiracy claim failed because there was no underlying constitutional violation. The court also concluded that the district court did not abuse its discretion in declining to take judicial notice of the administrative record and found other claims waived. View "Castille v. Port Arthur Independent School District" on Justia Law

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