Justia Education Law Opinion Summaries

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The case involves plaintiff-appellant Cassandra Kincaid, an assistant principal at Central Middle School in Kansas, who claimed that she was harassed by the Unified School District No. 500 in retaliation for her reporting a student-on-student sexual assault. The United States Court of Appeals for the Tenth Circuit affirmed the district court's grant of summary judgment in favor of the school district. The court concluded that Kincaid did not satisfy her burden of creating a genuine dispute of material fact that the reasons given for the alleged material adverse actions against her were pretextual. The court examined various aspects of the case under Title VII and Title IX, which prohibit retaliation against individuals for complaining of sex discrimination. It considered numerous allegedly adverse employment actions, including two emails sent by the school principal, a request for Kincaid's transfer, and a letter of concern. The court concluded that none of the evidence Kincaid provided created a genuine dispute of material fact about pretext. View "Kincaid v. Unified School District No. 500, Kansas City, KS" on Justia Law

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The case involves Pablo Abreu, a student who was expelled from Howard University College of Medicine. Abreu appealed his expulsion, arguing that the university violated his rights under Title III of the Americans with Disabilities Act (ADA) and the Rehabilitation Act of 1972 by refusing to grant him additional opportunities to retake a required examination, in light of his diagnosed test-taking-anxiety disability. The district court dismissed his complaint, applying a one-year statute of limitations and ruling that his claims were time-barred.The United States Court of Appeals for the District of Columbia Circuit disagreed with the lower court's application of a one-year statute of limitations to Abreu’s ADA and Rehabilitation Act claims. The court pointed to its decision in another case, Stafford v. George Washington University, in which it concluded that a three-year statute of limitations should apply to civil rights claims under Title VI of the Civil Rights Act of 1964. Since Abreu's ADA and Rehabilitation Act claims were also civil rights claims alleging discrimination, the court ruled that the three-year statute of limitations should apply. This made Abreu’s claims timely since he filed the suit less than three years after his expulsion.The court then remanded the case back to the district court for further proceedings on the ADA and Rehabilitation Act claims. However, it affirmed the dismissal of Abreu's contractual claims, agreeing with the district court that Abreu failed to state a claim for breach of contract. View "Abreu v. Howard University" on Justia Law

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The case involves Dr. Robert H. Wainberg, a tenured biology professor at Piedmont University, who filed a lawsuit against several officers and trustees of the university. He alleged that they conspired to retaliate against him for filing a prior lawsuit and to deter witnesses from participating in that lawsuit, and negligently refused to prevent that conspiracy. The district court dismissed Wainberg’s claims as time-barred, concluding that the statute of limitations ran from the first overt act Wainberg alleged as part of the conspiracy.On appeal, the United States Court of Appeals for the Eleventh Circuit held that under its precedent, each overt act triggers its own statute of limitations. Therefore, Wainberg’s claims arising out of some overt acts were timely. The court vacated the district court’s dismissal and remanded for further proceedings. The court also held that the continuing-violation doctrine, which allows a plaintiff to sue on an otherwise time-barred claim when additional violations of the law occur within the statutory period, did not apply in this case because the alleged violations were not ongoing but were discrete acts, each triggering its own statute of limitations. View "Wainberg v. Mellichamp" on Justia Law

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In Georgia, the Fair Dismissal Act (FDA) offers certain protections to public school teachers after they have fulfilled a contract for the fourth consecutive school year with the same local board of education. This case considered whether the Charter Schools Act's waiver provision, which relieves public charter schools from complying with Title 20 (including the FDA), impairs the vested rights of teachers who had earned FDA protections before their school converted to a charter system. The Supreme Court of Georgia decided that the teachers' constitutional claims failed as a matter of law. The justices reasoned that the 1993 Charter Schools Act had already clarified that the FDA did not afford teachers any rights enforceable against charter schools. Therefore, the Charter Systems Act's retention of an FDA exemption for charter schools did not impair any rights for teachers who earned FDA rights after the 1993 Charter Schools Act was enacted. View "WOODS v. BARNES" on Justia Law

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The Supreme Court of Texas evaluated a case in which a land development company, Bellpas, Inc., sought to detach property from one school district and annex it to another. According to the Texas Education Code, if the school boards of the affected districts disagree on the petition, the Commissioner of Education can resolve the issue in an administrative appeal. However, the Lampasas Independent School District (LISD) board neglected to approve or disapprove the petition, leading to a disagreement over whether the Commissioner of Education had jurisdiction over the administrative appeal.The Supreme Court of Texas held that the Commissioner of Education did have jurisdiction over the administrative appeal. The court reasoned that a school board "disapproves" a petition if it does not approve it within a reasonable time after a hearing, as per the plain reading of the Education Code. The court also concluded that the Commissioner did not lose jurisdiction by failing to issue a ruling within 180 days, as the statute's deadline is not jurisdictional.The case was returned to the Court of Appeals to resolve the appeal on its merits. The Supreme Court of Texas stressed that the delay in the administrative appeal process should not deprive the appellant of a decision on the merits of their petition and criticized the school board for refusing to make a decision, thus avoiding any ruling on the merits. View "MORATH v. LAMPASAS INDEPENDENT SCHOOL DISTRICT" on Justia Law

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In the case at hand, the United States Court of Appeals for the Third Circuit affirmed the dismissal of claims brought by a group of students and Children’s Health Defense, Inc. against Rutgers University. The plaintiffs challenged the university's COVID-19 vaccination policy, which required in-person students to be vaccinated or else enroll in online programs or seek exemptions for medical or religious reasons. The court found that the university's policy did not violate the plaintiffs' constitutional or statutory rights.The court held that there is no fundamental right to refuse vaccination. It applied the rational basis review and concluded that Rutgers University had a rational basis for its policy given the challenges posed by the COVID-19 pandemic. The court also rejected the plaintiffs' claim that the policy was ultra vires under New Jersey law, determining that Rutgers was authorized to require COVID-19 vaccinations under state law. Furthermore, the court dismissed the plaintiffs' equal protection claim, concluding that Rutgers had a rational basis for its differential treatment of students and staff, as well as vaccinated and unvaccinated students. View "Children's Health Defense Inc. v. Rutgers, the State University of New Jersey" on Justia Law

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This case was brought under the Individuals with Disabilities Education Act (IDEA) by the parents of A.O., a child with severe hearing loss who uses cochlear implants. The parents had rejected the Los Angeles Unified School District's proposed individualized education program (IEP) for their daughter, which they felt didn't specify the frequency and duration of proposed speech therapy and audiology services, offer a meaningful educational benefit, or place A.O. in the least restrictive environment appropriate for her. The United States Court of Appeals for the Ninth Circuit affirmed the district court's decision largely supporting the parents' objections. The court found that the school district's proposed IEP violated the IDEA by not clearly specifying the frequency and duration of proposed speech therapy and audiology services. The court also concluded that the proposed IEP wouldn't offer A.O. a meaningful educational benefit and failed to place her in the least restrictive environment appropriate for her. The court reversed the district court's conclusion that the school district's proposed IEP did not need to provide individual speech therapy. The court remanded the case to the district court to modify its judgment. View "LAUSD V. A. O." on Justia Law

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The Supreme Court of New Jersey examined whether N.J.S.A. 18A:6-16 limits an arbitrator’s authority to penalize conduct under the Tenure Employees Hearing Law (TEHL), N.J.S.A. 18A:6-10 to -18.1. The defendant, the Board of Education for the Town of West New York Public Schools, brought tenure charges against the plaintiff, Amada Sanjuan, for conduct unbecoming. The charges were based on alleged false claims made by Sanjuan about an accident at the school. An arbitrator concluded that Sanjuan's conduct warranted a penalty, but not dismissal. The arbitrator demoted Sanjuan from her tenured administrative position to a tenured teaching role, without backpay. Sanjuan sought to vacate the arbitration award, arguing that the arbitrator exceeded his authority by demoting her. The Appellate Division agreed, interpreting N.J.S.A. 18A:6-16 to allow sustained tenure charges to result only in termination or loss of salary, but not demotion. The Supreme Court of New Jersey reversed, holding that N.J.S.A. 18A:6-16 provides the basis to refer a case to arbitration but does not limit an arbitrator’s authority to impose penalties. Therefore, the Supreme Court reinstated the arbitrator's award demoting Sanjuan. View "Sanjuan v. School District of West New York" on Justia Law

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In this case, a doctor, Dr. Gabriel Fine, sued the University of Utah School of Medicine, alleging that the University deprived him of his clinical privileges without following the procedures required by its bylaws. The University moved for summary judgment, pointing to a provision in its bylaws where Dr. Fine had agreed not to sue "for any matter relating to appointment, reappointment, clinical privileges, or the individual’s qualifications for the same." The district court granted summary judgment in favor of the University, agreeing that Dr. Fine had released his claims against the University.Dr. Fine appealed the decision, arguing that the district court erred in interpreting the release to apply to his case. He asserted that the release only applied to actions taken during a formal review process and his claims arose from actions taken during an informal process.The Supreme Court of the State of Utah disagreed with Dr. Fine's argument. The court interpreted the release using its traditional tools of contract interpretation and found no textual justification for limiting the release's application only to actions taken during the formal review process. The court held that Dr. Fine’s claims against the University fell within the scope of the release and therefore affirmed the district court's decision. View "Fine v. University of Utah" on Justia Law

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This case is about a dispute between Richard Roe and St. John’s University (SJU) and Jane Doe. Roe, a male student at SJU, was accused of sexually assaulting two female students, Doe and Mary Smith, on separate occasions. SJU's disciplinary board found Roe guilty of non-consensual sexual contact with both Doe and Smith and imposed sanctions, including a suspension and eventual expulsion. Roe then sued SJU, alleging that his rights under Title IX of the Education Amendments of 1972 and state contract law had been violated. He also sued Doe for allegedly defaming him in an anonymous tweet accusing him of sexual assault. The United States District Court for the Eastern District of New York dismissed Roe's Title IX and state law claims, and declined to exercise jurisdiction over his defamation claim. On appeal, the United States Court of Appeals for the Second Circuit affirmed the district court's decision, holding that Roe's complaint failed to state a plausible claim of sex discrimination under Title IX. The court found that, while Roe had identified some procedural irregularities in SJU's disciplinary proceedings, these were not sufficient to support a minimal plausible inference of sex discrimination. Furthermore, the court ruled that Roe's hostile environment claim was fatally deficient, as the single anonymous tweet at the center of his claim was not, standing alone, sufficiently severe to support a claim of a hostile educational environment under Title IX. View "Roe v. St. John's University" on Justia Law