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The Supreme Court held that Defendant may withdraw his plea of guilty to “knowingly violat[ing]” a provision of the predatory offender registration statute, Minn. Stat. 243.166(5)(a), because Defendant alleged that he did not recall his responsibility under the law at the time of the offense. The court of appeals affirmed Defendant’s conviction, noting that “ignorance of the law is no excuse.” The Supreme Court reversed, holding (1) ignorance of the law is a defense when the charged offense prohibits a knowing violation of a statutory provision; and (2) Defendant’s factual basis failed to satisfy the accuracy requirement for a valid plea because he made statements, never withdrawn or corrected, that negated the mens rea element of the charged offense. View "State v. Mikulak" on Justia Law

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The First Circuit affirmed the district court’s denial of Plaintiff’s motion to amend on the ground that the First Circuit’s earlier decision was law of the case. Plaintiff, acting on behalf of her daughter, brought suit against the Falmouth School Department (Falmouth) alleging that it failed to provide O.M. with a free appropriate public education (FAPE) as guaranteed by the Individuals with Disabilities Education Act, 20 U.S.C. 1400 et seq. The district court entered judgment in favor of Plaintiff. The First Circuit reversed in Falmouth I, holding that Falmouth did not violate O.M.’s right to a FAPE. After the First Circuit’s decision in Falmouth I, Plaintiff sought to amend her complaint to include a claim that she had not included in her district court complaint. The district court denied the motion to amend. The First Circuit affirmed, holding that the district court properly denied Plaintiff’s motion to amend under the law of the case doctrine. View "Ms. M. v. Falmouth School Department" on Justia Law

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The Supreme Court affirmed the judgment of the court of appeals dismissing the petition of Appellant for a writ of mandamus against the Ohio Adult Parole Authority (APA). In his petition, Appellant argued that he had received multiple punishments for the same parole violation in violation of the Double Jeopardy Clause. The court of appeals dismissed the action, ruling that Appellant ha not received multiple punishments and that Appellant had failed to demonstrate any constitutional injury. The Supreme Court denied Appellant’s motion for leave to supplement his reply brief and affirmed the judgment of the court of appeals, holding (1) double jeopardy protections were not violated by the sanctions imposed for Appellant’s parole violation; and (2) the APA did not violate Appellant’s due process rights by holding a parole hearing after his parole officer had imposed sanctions against him. View "Clark v. Adult Parole Authority" on Justia Law

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The Supreme Court denied the writ of mandamus sought by Kurt Singer to, among other things, compel Fairland Local School District Board of Education (Fairland) to recognize him as a “regular nonteaching school employee” under Ohio Rev. Code 3319.081 with continuing-contract status. Singer worked for Fairland as a substitute custodian without signing a written employment contract with Fairland. Singer alleged that Fairland wrongly designated him as a “substitute,” and consequently, he had been paid less than a full-time custodian, lost health benefits and some pension benefits, and had been deprived of certain paid leave. Singer requested a writ of mandamus directing Fairland to recognize him as a regular nonteaching employe with a continuing contract and ordering Fairland to make him whole by awarding him back wages and benefits and crediting him with paid leave and other accrued rights. The Supreme Court denied the writ, holding that Singer was not entitled to continuing status because he failed to establish that he was a “regular nonteaching employee” under section 3319.081. View "State ex rel. Singer v. Fairland Local School District Board of Education" on Justia Law

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Twenty-one public school districts claimed the Mississippi Legislature’s appropriations for public education during fiscal years 2010-2015 were statutorily inadequate. The districts contended Mississippi Code Section 37-151-6 mandated the Legislature fully fund the Mississippi Adequate Education Program (MAEP), but the Legislature failed to follow this mandate. They sought judicial enforcement of this statute in Hinds County Chancery Court, requesting more than $235 million in State funds - the difference between what they received and what they claim they should have received had the Legislature fully funded MAEP. The chancellor found the school districts were not entitled to relief because he determined that Section 37-151-6 was not a binding mandate. The chancellor, therefore, ​dismissed the school districts’ claim. Because the Mississippi Supreme Court found that Section 37-151-6 was not mandatory, it affirmed. View "Clarksdale Municipal School District et al. v. Mississippi" on Justia Law

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Certain records compiled by Respondent, New York State Education Department, relating to municipalities’ plans for auditing special education preschool provider costs, as redacted, are exempt from disclosure under N.Y. Pub. Off. Law 87(2)(e)(i). Petitioner submitted a request to Respondent pursuant to the Freedom of Information Law seeking disclosure of documents relating to municipalities’ plans for auditing special education preschool provider costs. The Department initially denied the request but, after Petitioner commenced this proceeding directing the Department to provide her with the records sought, eventually released fifty-five pages. Supreme Court granted Petitioner's petition to the limited extent of requiring the Department to disclose two previously redacted pages, upheld the remainder of the redactions, and otherwise dismissed the proceeding, concluding that the majority of the Department’s redactions were appropriate under section 87(2)(e). The Appellate Division affirmed. The Court of Appeals affirmed as modified, holding (1) the redactions at issue fit within the exemption permitting an agency to deny access to records compiled for law enforcement purposes where their disclosure would interfere with an investigation; and (2) the Appellate Division erred in denying Petitioner’s request for attorneys’ fees. View "Madeiros v. New York State Education Department" on Justia Law

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Plaintiffs are parents of children with disabilities who were enrolled at the Charter School, which did not consistently satisfy its Individuals with Disabilities Education Act (IDEA) obligations to provide the children with a “free appropriate public education,” 20 U.S.C. 1412(a)(1)(A). In 2014, the School entered with Plaintiffs into settlement agreements. The School was to fund compensatory education for each child and contribute toward Plaintiffs’ attorneys’ fees. The School permanently closed in December 2014 and never met its obligations under the agreements. Plaintiffs filed administrative due process complaints with the Pennsylvania Department of Education, alleging that the Department should provide compensatory education. The hearing officer dismissed the complaints. Plaintiffs then sued the School and the Department, seeking reversal of the administrative decisions dismissing their claims, remand, and attorneys' fees and costs. Aside from the requested award of fees and costs, Plaintiffs obtained all of the relief they sought. On remand, Plaintiffs and the Department agreed on the number of hours of compensatory education. Plaintiffs unsuccessfully sought attorneys’ fees. The Third Circuit reversed, rejecting the district court’s reasoning that the Plaintiffs received only interlocutory procedural relief and were not prevailing parties. Success on a claim for procedural relief can constitute “a victory ‘on the merits’ that confer[s] ‘prevailing party’ status.” View "H. E. v. Walter D. Palmer Leadership Learning Partners Charter School" on Justia Law

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Anthony Burke was a child diagnosed with an autism-spectrum disorder. Throughout the first six months of 2010, Anthony and his family were covered by a group health insurance policy (the “Policy”) with Appellant, Independence Blue Cross (“Insurer”), maintained through Anthony’s father, John Burke’s employer. Initially, Anthony received “applied behavioral analysis” (ABA) treatment at home. In August 2009, before an Autism Coverage Law became effective relative to the Burkes’ coverage, the family requested benefits, under the Policy, for ABA services to be provided at the parochial elementary school attended by Anthony. Insurer denied coverage on account of an express place-of-services exclusion in the Policy delineating that services would not be covered if the care was provided in certain locations, including schools. In a motion for judgment on the pleadings, Mr. Burke argued that the place-of-services exclusion in the Policy was nullified, as it pertained to in-school services, by the Autism Coverage Law. The Pennsylvania Supreme Court found that the Pennsylvania Legislature intended to permit only general exclusions that would not substantially undermine the mandatory coverage requirement: “we simply do not believe that the Legislature intended to permit insurers to exclude coverage in the sensory-laden educational environment where children spend large portions of their days, or to require families to litigate the issue of medical necessity discretely in individual cases to secure such location-specific coverage for the treatment.” The Supreme Court affirmed judgment in favor of the Burkes, and that the Policy’s place-of-services exclusion was ineffective under the Autism Recovery Law. View "Burke v. Independence Blue Cross" on Justia Law

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The State did not meet its burden of showing that Senate Bill 19 meets the adequacy and equity requirements set forth in Kan. Const. art. VI, 6(b). S.B. 19 was remedial legislation passed by the legislature in an attempt to bring the State’s education financing system into compliance with Article 6. In one of the four previous decisions by this court in this case, the Supreme Court issued a mandate for the State to create a school funding system that complies with Article 6 of the Kansas Constitution. The Supreme Court held that although S.B. 19 makes positive strides, the State’s public education financing system passes neither the test for adequacy nor the test for equity. As a remedy, the Supreme Court stayed the issuance of its mandate until June 30, 2018, at which time the State will have to satisfactorily demonstrate that its proposed remedy brings the State’s education financing system into compliance with Article 6 regarding adequacy and equity. View "Gannon v. State" on Justia Law

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In 2008, Arise, a Dayton community school (charter school), faced declining enrollment, financial troubles, and scandal after its treasurer was indicted for embezzlement. The school’s sponsor sought a radical change in administration, elevated Arise’s former principal, Floyd, to superintendent, removed all board members, and appointed Floyd’s recommended candidates to the new board. Floyd set up a kickback scheme, using former business partners to form Global Educational Consultants, which contracted with Arise. Global received $420,919 from Arise. While Global was being paid, Arise teachers’ salaries were cut and staff members were not consistently paid. Arise ran out of money and closed in 2010. The FBI investigated and signed a proffer agreement with Ward, the “silent partner” at Global, then indicted Floyd, Arise board members, and Global's owner. They were convicted of federal programs bribery, conspiracy to commit federal programs bribery, and making material false statements, 18 U.S.C. 666(a)(1)(B), (a)(2); 18 U.S.C. 371; 18 U.S.C. 1001(a)(2). Two African-American jurors reported that they were initially unconvinced; the jury foreperson, a white woman, reportedly told them that she believed they were reluctant to convict because they felt they “owed something” to their “black brothers.” This remark prompted a confrontation, requiring the marshal to intervene.The Sixth Circuit affirmed their convictions, rejecting arguments based on the Supreme Court’s 2017 decision, Pena-Rodriguez v. Colorado. Although Pena-Rodriguez permitted, in very limited circumstances, an inquiry into a jury’s deliberations, this case did not fit into those limited circumstances. View "United States v. Robinson" on Justia Law