Justia Education Law Opinion Summaries

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

An 11-year-old student, Therese, died by suicide at her father's home during her school’s winter break. Her parents brought claims against the school district, alleging negligent hiring, supervision, and training of staff, failure to protect Therese from bullying, and inadequate response to her expressions of suicidal ideation. They argued the district failed to fulfill its duty to supervise students and to inform them of Therese’s condition. The parents also pursued a survival claim for Therese’s pre-death suffering, alleging harm occurred on campus due to the district’s negligence.The Superior Court of Solano County denied the school district’s motion for summary judgment, finding triable issues of fact as to whether the district exercised reasonable care and whether Therese suffered injury on campus due to the district’s negligence. The court relied on the California Supreme Court’s decision in Hoyem v. Manhattan Beach City School District, determining that statutory immunity under Education Code section 44808 did not apply because there were factual questions about on-campus harm and failure to exercise reasonable care.The Court of Appeal of the State of California, First Appellate District, Division Four, reviewed the case on a petition for writ of mandate. The appellate court held that under section 44808, the district is immune from liability for harms resulting from Therese’s off-campus suicide, as she was not under the district’s supervision at the time. However, the court determined that this immunity does not extend to the survival claim, which concerns alleged on-campus harm while Therese was under the district’s supervision. The appellate court ordered the trial court to grant summary adjudication in favor of the district on the wrongful death and related claims but allowed the survival claim to proceed. View "Vallejo City Unified School Dist. v. Superior Court" on Justia Law

The case involved a dispute between a public school district and several charter schools, along with a resident, regarding the mode of free transportation provided to charter school students. Previously, the district had provided school bus transportation to all students, including those attending charter schools within ten miles of the district. However, to reduce costs, the district switched to giving charter school students free passes to use public buses operated by the county transit authority, a move that resulted in significant savings due to differences in state reimbursement. The charter schools continued to provide private transportation for younger students but not for older ones, who used the public transit passes.After the change, the charter schools and the resident sued in the Allegheny County Court of Common Pleas, seeking a declaration that the district’s provision of public bus passes did not constitute “free transportation” as required by state law and an injunction to stop the practice. The trial court, after a non-jury trial, ruled in the district’s favor, holding that state statutes allowed school districts to use common carriers for student transportation and that the law did not require identical modes of transportation for charter and district students. On appeal, the Commonwealth Court initially reversed on a procedural issue but, after remand from the Supreme Court, ultimately affirmed the trial court, finding no violation of the relevant statutes.The Supreme Court of Pennsylvania reviewed whether state law requires school districts to provide the same mode of free transportation to charter school students as to traditional public school students. The court held that the statute entitles charter school students to “free transportation” but does not require that the mode of transportation be identical to that provided to other public school students. The court affirmed the order of the Commonwealth Court, ruling that the district’s use of public bus passes for charter school students was permissible under the law. View "Bell v. Wilkinsburg SD" on Justia Law

A former assistant principal at a middle school in the Central Valley School District posted a Facebook comment about the Democratic National Convention that included epithets, slurs, and violent language. The post, though made on his private account and shared with Facebook friends, was seen by other school district employees and quickly forwarded to administrators. Within days, the assistant principal was placed on paid administrative leave, prohibited from contacting district staff or students, and ultimately transferred to a non-administrative teaching position. The school district’s investigation revealed additional concerns about derogatory comments he had made at work. The district offered him a voluntary transfer if he signed a release of claims, which he rejected, leading to further administrative proceedings and the final transfer decision.Previously, the United States District Court for the Eastern District of Washington reviewed the case. The court initially denied summary judgment to individual administrators on qualified immunity, a decision affirmed by the Ninth Circuit on interlocutory appeal. After further discovery and cross-motions for summary judgment, the district court granted summary judgment to the school district and the individual administrators. The court found the plaintiff had established a prima facie First Amendment retaliation claim but held that the district’s interests outweighed the plaintiff’s under the Pickering balancing test. Qualified immunity was also found to apply to the individual defendants.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s rulings. It held that while the plaintiff’s Facebook post was private speech on a matter of public concern and he made a prima facie case for retaliation, the school district showed a reasonable prediction of disruption and its interest in maintaining a safe and inclusive environment outweighed the plaintiff’s First Amendment interests. The court also affirmed qualified immunity for the individual administrators. View "Thompson v. Central Valley School District No 365" on Justia Law

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