Justia Education Law Opinion Summaries

Kenya Taylor hired Los Angeles Unified School District (LAUSD) employee Tyler Martin-Brand to babysit her six-year-old son, Dayvon, during the winter break in 2019. Tragically, Martin-Brand killed Dayvon. Taylor sued LAUSD, alleging negligent hiring and supervision of Martin-Brand. A jury found in favor of Taylor, awarding her $30 million in damages. LAUSD appealed the trial court's denial of its motion for judgment notwithstanding the verdict (JNOV) and the judgment itself.The Superior Court of Los Angeles County denied LAUSD's motions for JNOV and a new trial, asserting that LAUSD was immune from liability under Education Code section 44808. The jury had found LAUSD negligent in hiring and supervising Martin-Brand, attributing 90% of the fault to LAUSD and 10% to Taylor.The Court of Appeal of the State of California, Second Appellate District, Division Three, reviewed the case. The court concluded that LAUSD was immune from liability for Dayvon’s off-campus death under Education Code section 44808, which limits school district liability for student injuries occurring off school property unless the district has specifically undertaken responsibility for the student. The court found that Dayvon’s death did not occur during any school-sponsored activity or under LAUSD’s supervision. Consequently, the court reversed the trial court's order and judgment, directing the trial court to enter judgment in favor of LAUSD. View "Taylor v. Los Angeles Unified School Dist." on Justia Law

The Oakland Education Association (OEA) represents certain employees of the Oakland Unified School District (District). Following a dispute over school closures approved by the District, OEA members conducted a one-day strike. OEA filed an unfair practice charge with the Public Employment Relations Board (PERB), claiming the District committed unfair practices under the Educational Employment Relations Act (EERA). The District filed a competing charge, claiming OEA’s strike was an unfair practice under EERA.PERB issued separate complaints for the competing charges and bifurcated the hearings. In its first decision, PERB found the District violated EERA. In its second decision, PERB held that OEA’s strike was legal because it was provoked by the District’s unfair practices and OEA had negotiated in good faith. The District did not challenge the first decision but contested the second, arguing that OEA’s strike was illegal and violated constitutional rights.The California Court of Appeal, First Appellate District, reviewed the case. The court held that public school employees may engage in unfair practice strikes under EERA. It concluded that PERB did not clearly err in finding that such strikes are allowed and that OEA’s one-day strike did not violate the rights to education, due process, or equal protection. The court also found that neither EERA nor the due process clause prohibits pre-impasse unfair practice strikes conducted before PERB determines an unfair practice has occurred. However, the court noted that PERB erred by excluding evidence of educational harm but deemed this error harmless. The court affirmed PERB’s decision. View "Oakland Unified School Dist. v. Public Employment Relations Board" on Justia Law

The case involves a challenge to the constitutionality of the State of New Hampshire's funding for public education. The plaintiffs, which include several school districts and individuals, argue that the amount of base adequacy aid provided under RSA 198:40-a, II(a) is insufficient to cover the cost of providing a constitutionally adequate education as defined by RSA 193-E:2-a. They seek a declaratory judgment and injunctive relief to increase the funding.The Superior Court (Ruoff, J.) ruled in favor of the plaintiffs, declaring RSA 198:40-a, II(a) unconstitutional on its face. The court found that the current funding level of $4,100 per pupil was significantly below the amount necessary to provide an adequate education. The court determined a conservative minimum threshold of $7,356.01 per pupil, which it found to be the minimum amount that base adequacy aid must exceed. The court also directed the State to immediately increase base adequacy aid payments to this threshold amount pending further legislative action.The State appealed to the Supreme Court of New Hampshire, arguing that the trial court erred in its findings and that the immediate payment directive violated the separation of powers doctrine. The State contended that the trial court should have considered the total funding provided under RSA 198:40-a, including differentiated aid, rather than focusing solely on base adequacy aid.The Supreme Court of New Hampshire affirmed the trial court's rulings on the admissibility of expert testimony, the declaration that RSA 198:40-a, II(a) is facially unconstitutional, and the determination of a conservative minimum threshold for base adequacy aid. However, the court reversed the trial court's immediate payment directive, finding that it failed to properly weigh separation of powers concerns and the history of school funding litigation. The court emphasized the need for the legislative and executive branches to act expeditiously to remedy the constitutional deficiency in funding public education. View "Contoocook Valley Sch. Dist. v. State" on Justia Law

During the 2022-2023 school year, the Montgomery County Board of Education introduced LGBTQ+-inclusive storybooks into the public school curriculum for kindergarten through fifth grade. Initially, the Board allowed parents to opt their children out of this instruction, consistent with its guidelines for respecting religious diversity. However, the Board later rescinded this opt-out policy, citing disruptions and potential social stigma for students who opted out. A group of parents from diverse religious backgrounds, who believe the curriculum undermines their religious teachings on sexuality and gender, filed a lawsuit seeking to reinstate the opt-out option.The United States District Court for the District of Maryland denied the parents' request for a preliminary injunction, dismissing their reliance on Wisconsin v. Yoder and characterizing their claim as an objection to school indoctrination. The court held that the curriculum did not violate the Free Exercise Clause. A divided panel of the Fourth Circuit affirmed, finding insufficient evidence that the storybooks coerced students to change their views or act contrary to their faith.The Supreme Court of the United States reversed the Fourth Circuit's decision, holding that the parents are entitled to a preliminary injunction. The Court found that the Board's policies substantially interfere with the religious development of the children and impose a burden on religious exercise similar to that in Yoder. The Court concluded that the parents are likely to succeed on the merits of their claim, suffer irreparable harm without relief, and that an injunction is in the public interest. The Board must notify parents in advance when the books will be used and allow their children to be excused from that instruction. View "Mahmoud v. Taylor" on Justia Law

Parents and students in Louisiana challenged a state statute requiring public schools to permanently display the Ten Commandments in every classroom. The statute, House Bill 71 (H.B. 71), mandated that the Ten Commandments be displayed prominently and legibly, with an optional inclusion of other historical documents. Plaintiffs argued that this statute violated the Establishment Clause and Free Exercise Clause of the First Amendment.The United States District Court for the Middle District of Louisiana found the statute facially unconstitutional and issued a preliminary injunction to prevent its enforcement. The court ruled that the statute's primary purpose was religious, not secular, and that it coerced students into religious observance, thus violating the Establishment Clause. Louisiana officials appealed the decision, arguing that the statute had a valid secular purpose and that the plaintiffs lacked standing.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court's decision. The Fifth Circuit held that the statute was unconstitutional under the Establishment Clause, relying on the precedent set by Stone v. Graham, which struck down a similar statute in Kentucky. The court found that the statute's requirement to display the Ten Commandments in every classroom, without integrating them into an educational curriculum, served no secular educational purpose and was inherently religious.The court also determined that the plaintiffs had standing to challenge the statute, as they would be directly affected by the displays. The court rejected Louisiana's arguments regarding ripeness, standing, and sovereign immunity. The preliminary injunction was upheld, preventing the enforcement of H.B. 71 and requiring Louisiana officials to notify all public schools of the court's ruling. View "Roake v. Brumley" on Justia Law

In this case, Olivia Boone, on behalf of her autistic son K.A., challenged the Rankin County Public School District's decision to move K.A. to a new program at a different school without her consent. Boone filed a complaint with the Mississippi Department of Education, alleging that the school district violated the Individuals with Disabilities Education Act (IDEA) by unilaterally making the placement decision. A hearing officer found that the school district violated the IDEA and ordered relief but denied Boone's request for compensatory educational services. Boone then filed a suit seeking compensatory educational services and attorneys' fees.The United States District Court for the Southern District of Mississippi affirmed the hearing officer's decision, holding that Boone was entitled to attorneys' fees but not compensatory educational services. Boone appealed the denial of compensatory educational services, and the school district cross-appealed the finding that it violated the IDEA and the award of attorneys' fees.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court's judgment. The court held that the school district denied K.A. a free appropriate public education by failing to individualize his education plan to address his elopement tendencies and by predetermining his placement without Boone's input. However, the court found that Boone did not prove that Brandon Middle School was not K.A.'s least restrictive environment. The court also held that Boone was not entitled to compensatory educational services, as the district court did not abuse its discretion in limiting relief to address Boone's primary concerns. Finally, the court affirmed that Boone was a prevailing party entitled to attorneys' fees, as the relief awarded altered the legal relationship between K.A. and the school district and fostered the purposes of the IDEA. View "Boone v. Rankin County" on Justia Law

A group of nonpublic schools and organizations representing them challenged regulations issued by the New York State Commissioner of Education. These regulations required nonpublic schools to provide an education substantially equivalent to that of public schools. If a nonpublic school failed to meet this standard, it would no longer be considered a school providing compulsory education under New York law.The Supreme Court of New York upheld most of the regulations but invalidated the specific provisions that deemed noncompliant nonpublic schools as not fulfilling compulsory education requirements. The court found that these provisions exceeded the Commissioner’s authority. The respondents, including the Commissioner, appealed this decision.The Appellate Division reversed the Supreme Court’s decision, ruling that the Commissioner had the authority to promulgate the challenged regulations. The court held that the regulations were within the Commissioner’s statutory authority and did not compel parents to unenroll their children from noncompliant schools or authorize school closures. One Justice dissented, arguing that the regulations exceeded the Commissioner’s authority.The New York Court of Appeals affirmed the Appellate Division’s decision. The court concluded that the Commissioner lawfully promulgated the regulations, which simply enforced the statutory mandate that nonpublic schools provide substantially equivalent education. The court found that the regulations did not require parents to unenroll their children or authorize school closures but merely stated that noncompliant schools did not meet the statutory requirements for compulsory education. The court also addressed mootness issues related to recent legislative amendments but found that the challenge to the specific regulatory provisions remained a live controversy. View "Matter of Parents for Educ. & Religious Liberty in Schs. v Young" on Justia Law

The case involves a challenge to Oklahoma's H.B. 1775, which prohibits mandatory gender or sexual diversity training and restricts the teaching of certain concepts related to race and sex in public schools and higher education institutions. Plaintiffs, including the Black Emergency Response Team and other organizations, argue that the law is unconstitutional under the First and Fourteenth Amendments, claiming it is vague, overbroad, and imposes viewpoint-based restrictions.The United States District Court for the Western District of Oklahoma reviewed the case and certified several questions of state law to the Oklahoma Supreme Court. The district court granted in part and denied in part motions from both plaintiffs and defendants, enjoining certain provisions of the law as unconstitutionally vague. Specifically, the court enjoined the enforcement of the second sentence of § 24-157(A)(1) and parts of § 24-157(B)(1).The Oklahoma Supreme Court addressed the certified questions, determining that the term "requirement" in § 24-157(A)(1) pertains only to orientation requirements and does not apply to classes, courses, or curricular speech. The court declined to answer the remaining certified questions related to § 24-157(B)(1), stating that the terms and phrases in question could be interpreted using their common, ordinary meanings and that the federal court could undertake this task. The court also noted that answering these questions would not avoid or alter the constitutional challenge to the statute and could result in an advisory opinion. View "BLACK EMERGENCY RESPONSE TEAM v. DRUMMOND" on Justia Law

A student, E.I., attended El Segundo Middle School during the 2017-2018 school year and experienced bullying from classmates, particularly Skylar. Despite E.I. and her parents repeatedly reporting the bullying to school officials, including the principal and counselor, the school failed to take effective action. The bullying included verbal harassment, social media abuse, and physical aggression, which led E.I. to self-harm and develop PTSD and depression. The school’s anti-bullying policies were not adequately followed by the staff.The case was initially reviewed by the Superior Court of Los Angeles County, where a jury found the El Segundo Unified School District negligent and awarded E.I. $1 million in damages. The District moved for a new trial and for judgment notwithstanding the verdict, both of which were denied by the court.The California Court of Appeal, Second Appellate District, reviewed the case. The District argued several points on appeal, including errors in allowing reliance on certain Education Code provisions, claims of immunity under Government Code section 820.2, insufficient evidence of causation, improper consideration of a negligent training and supervision theory, admission of expert testimony, and attorney misconduct during closing arguments. The appellate court found that many of the District’s arguments were either waived or lacked merit. The court held that the District was not immune from liability under Government Code section 820.2, as the actions in question were operational rather than policy decisions. The court also found substantial evidence supporting the jury’s causation finding and determined that any potential errors were not prejudicial. Consequently, the appellate court affirmed the judgment in favor of E.I. View "E.I. v. El Segundo Unified School Dist." on Justia Law

A transgender girl, D.P., and her mother challenged a new policy by the Mukwonago Area School District that required D.P. to use the boys’ bathroom or a gender-neutral alternative. They argued that the policy violated Title IX of the Education Amendments of 1972 and the Fourteenth Amendment’s Equal Protection Clause. They filed an emergency motion for a temporary restraining order and a preliminary injunction to prevent the policy's enforcement during litigation, citing the precedent set by Whitaker v. Kenosha Unified School District No. 1 Board of Education.The United States District Court for the Eastern District of Wisconsin granted the temporary restraining order and, shortly after, converted it to a preliminary injunction without holding a hearing. The judge found that the case was controlled by the Whitaker precedent and concluded that D.P. was likely to succeed on the merits of her claims. The school district appealed, arguing that the judge erred by not holding an evidentiary hearing and urging the court to overrule Whitaker and a related case, A.C. v. Metropolitan School District of Martinsville.The United States Court of Appeals for the Seventh Circuit affirmed the district court’s decision. The appellate court held that an evidentiary hearing is not always required before issuing a preliminary injunction, especially when the opponent does not request one or identify material factual disputes. The court also declined to revisit or overrule Whitaker and Martinsville, reaffirming that the district judge did not abuse his discretion in granting the preliminary injunction based on binding circuit precedent. The court concluded that the slight differences in D.P.'s case did not warrant a different outcome. View "Doe v Mukwonago Area School District" on Justia Law