Justia Education Law Opinion Summaries

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D.T.’s parents, concerned that their son, who has autism, was not getting an appropriate education in the Tennessee schools, removed him from public school and placed him in a private therapy program, where he improved. They were convicted of truancy. To avoid further prosecution. they enrolled D.T. in a state-approved private school and a private therapy program. To have the option of removing him from school again in the future, they sought a preliminary injunction to keep the state from charging them with truancy. They argued they had the right to remove D.T. from school because federal disability law preempts state educational requirements. The district court found that D.T.’s parents had not yet suffered an immediate and irreparable injury. The Third Circuit affirmed the denial of relief. The hypothetical threat of prosecution is not an “immediate,” “irreparable” injury that warrants the “extraordinary remedy” of a preliminary injunction. View "D.T. v. Sumner County Schools" on Justia Law

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The Supreme Court affirmed the judgment of the district court declining to modify a restriction on alienability of paintings painted by artist Grant Wood and donated in 1976 to Coe College in Cedar Rapids, holding that the 1976 gift was restricted. A foundation donated the paintings to the college, and the gift letter stated that "this would be their permanent home, hanging on the walls of Stewart Memorial Library." While the college traditionally treated the paintings on its books as an unrestricted gift that could be sold or otherwise alienated, in 2016, an auditor determined the paintings should be treated as a restricted gift. The college subsequently filed a petition seeking a judicial interpretation of the gift's terms. The district court ruled that there existed a restriction on the alienability of the paintings and declined to modify the restriction. The Supreme Court affirmed, holding (1) the language in the gift letter did restrict the gift; (2) the Uniform Prudent Management of Institutional Funds Act does not apply; and (3) it was premature to consider the application of the common law doctrine of cy pres because there was no showing the gift restrictions cannot be carried out at present. View "In re Application of Coe College for Interpretation of Purported Gift Restrictions v. Coe College" on Justia Law

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Parents, students, taxpayers, and community organizations filed suit alleging that the school district adopted and implemented a district-wide disciplinary program that was biased toward minority students, students who speak limited English, and others similarly situated. This case arose from information released to the public regarding suspensions, transfers, and other disciplinary proceedings in the school district that allegedly demonstrated that racial bias affected how the school district disciplined minority students, and actions taken by the school district to actively hide this fact from the public. The Court of Appeal affirmed the trial court's dismissal of most of plaintiffs' claims against the state level defendants, either because the claims did not state a cause of action or such claims may be brought against the local level defendants but not the state level defendants. The court held, however, that plaintiffs have stated a cause of action for disparate impact under California's equal protection clause and they have properly petitioned for a writ of mandate based on the state level defendants' ministerial duty to monitor the practices of local school districts for violations of federal law. Therefore, the court held that the trial court wrongly sustained the state-level defendants' demurrer on those claims, along with plaintiffs' request for declaratory relief on the same issues. The court also held that plaintiffs' complaint contained sufficient allegations to demonstrate associational standing for one of the community organizations to pursue these claims against the state level defendants. View "Collins v. Thurmond" on Justia Law

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After M.L. was dismissed from the cheerleading squad when her coaches discovered her Twitter posts contained profanity and sexual innuendo, her mother filed suit against defendants under 42 U.S.C. 1983, alleging violation of M.L.'s rights to free speech, due process, and equal protection. The district court held that the individual defendants were entitled to qualified immunity and dismissed M.L.'s complaint for failure to state a claim. The Fifth Circuit affirmed, holding that no clearly established law placed the constitutionality of defendants' conduct beyond debate at the time of M.L.'s dismissal from the team. The court held that nothing in its precedent allows a school to discipline nonthreatening off campus speech simply because an administrator considers it offensive, harassing, or disruptive; it is indisputable that non-threatening student expression is entitled to First Amendment protection, even though the extent of that protection may be diminished if the speech is composed by a student on campus, or purposefully brought onto a school campus; and as a general rule, speech that the speaker does not intend to reach the school community remains outside the reach of school officials. In this case, the court held that no clearly established law placed M.L.'s right's beyond debate at the time of the sanction, particularly given the unique extracurricular context. The court also affirmed the district court's dismissal of the claims for municipal liability, vagueness, and overbreadth, because M.L. failed to plead facts that would entitle her to relief. View "Longoria v. San Benito Independent Consolidated School District" on Justia Law

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The Supreme Court affirmed the opinion of the court of appeals insofar as it vacated the trial court's judgment convicting Defendant of tampering of physical evidence but reversed insofar as the court reversed Defendant's other convictions, holding that there was insufficient evidence to convict Defendant of tampering with physical evidence. Defendant, while in the presence of a police officer, dropped or tossed physical evidence of a possessory crime. Defendant was subsequently convicted of first-degree possession of a controlled substance, possession of drug paraphernalia, and tampering with physical evidence. The court of appeals reversed, holding that there was insufficient evidence to support all three crimes. The Supreme Court reversed in part, holding that the trial court (1) did not err in denying Defendant's motion for a directed verdict on the possession charges; but (2) erred in denying Defendant's motion for a directed verdict with respect to the tampering with physical evidence charge. View "Commonwealth v. James" on Justia Law

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The Fifth Circuit reversed the district court's dismissal of plaintiff's Title IX complaint for failure to exhaust administrative remedies under the Individuals with Disabilities Education Act (IDEA). Plaintiff's claims stemmed from an incident at school where another student raped her special needs child. Based on the Supreme Court's recent decision in Fry v. Napoleon Community Schools, 137 S. Ct. 743 (2017), the court held that if a disabled person seeks Title IX relief that a non-disabled person could also seek and requests relief that is different from or in addition to a free appropriate public education (FAPE), the IDEA's exhaustion requirement does not apply. In this case, plaintiff's claim involved simple discrimination, irrespective of the IDEA's FAPE obligation. Were all traces of the child's disabilities removed, the court explained that plaintiff's claim would look nearly identical to allegations that the school was deliberately indifferent to the child's sexual abuse. Therefore, the court held that the gravamen of the complaint was not about the denial of a FAPE, and the IDEA's exhaustion requirement does not apply. Accordingly, the court remanded for further proceedings. View "Doe v. Dallas Independent School District" on Justia Law

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The Fifth Circuit affirmed the district court's grant of summary judgment to the university in an action brought by a student, alleging substantive due process and equal protection claims in connection with the university's evaluation of allegations that the student cheated on an exam. The court held that the district court abused its discretion by refusing to consider the student's expert reports solely because they were unsworn, without considering whether the opinions were capable of being presented in a form that would be admissible in evidence. In regard to the substantive due process claim, the court held that the student failed to identify any summary judgment evidence raising a genuine fact issue that defendants did not actually exercise professional judgment in resolving the cheating allegations, or that the result of the process was beyond the pale of reasoned academic decision-making. Likewise, the court held that the student failed to demonstrate a genuine issue of material fact as to his equal protection claim. In this case, there was nothing in the record to suggest that the student was intentionally treated in a manner irrationally different from other similarly situated students. View "Patel v. Texas Tech University" on Justia Law

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The named plaintiff, Mike Zeyen sought declaratory relief and recovery of damages from Pocatello/Chubbuck School District No. 25 on behalf of all students currently enrolled in the district and their guardians. Zeyen alleged that School District 25’s practice of charging fees violated Article IX, section 1, of the Idaho Constitution. Zeyen first sought to certify the class to include all students within School District 25. Zeyen’s later motion to amend sought to add a takings claim under both the Idaho and U.S. Constitutions. The district court denied Zeyen’s motion for class certification based on lack of standing and denied his motion to amend both as untimely and prejudicial to School District 25. The Idaho Supreme Court determined Zeyen failed to show that the district court abused its discretion by denying his second motion for leave to amend the complaint. Furthermore, the Court determined Zeyen lacked standing to bring his class action suit. The Court therefore affirmed the district court's denial of Zeyen's motion to certify the class and denial of his motion for leave to amend the first amended complaint. View "Zeyen v. Pocatello/Chubbuck School Dist 25" on Justia Law

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In 2015, plaintiffs sued 88 school districts and the California Department of Education, seeking relief for alleged violations of Education Code section 51210(g). That law requires no less than 200 minutes of physical education instruction every 10 school days for pupils in first through sixth grades. In 2017, five of the districts sought to have the court issue a writ of mandamus against them, granting the relief sought in the petition. The superior court granted the motion. The court of appeal affirmed, rejecting arguments that it was error for the trial court to enter the judgments without an evidentiary proceeding; that the allegations did not preclude writ relief beyond the limited relief contained in the judgments (injunctive relief); and the trial court should have allowed amendment of the petition to state a cause of action for declaratory relief. The plaintiffs unsuccessfully argued that a writ of mandate was an inadequate remedy because it cannot compel the school districts’ employees to comply with the PE mandate and that no writ could issue unless the Districts admit noncompliance with the PE mandate. View "Cal200, Inc., v. Apple Valley Unified School District" on Justia Law

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The Supreme Court affirmed in part and reversed in part the order of the district court entering an injunction directing Defendants to place on the ballot a measure asking voters whether they approved the demolition of Hoover Elementary School and the use of the proceeds for school district purposes, holding that the district court erred in granting Plaintiffs injunctive relief. The Iowa City Community School District refused to authorize the placement of the ballot issue at an election after a petition bearing more than 2000 signatures had been timely filed with the Board. When the Board refused to direct the county auditor to place the matter on the ballot for the upcoming election, Plaintiffs sought injunctive relief and damages against the school district court individual board members. The district court entered an injunction and directed the district court to place the matter on the next general election ballot. The district court then granted Defendants summary judgment on Plaintiffs' claims for damages. The Supreme Court reversed in part, holding that Defendants were entitled to summary judgment on all claims because the school district was under no legal obligation to require the county auditor to place the matter on the ballot. View "Young v. Iowa City Community School District" on Justia Law