Justia Education Law Opinion Summaries

J.M., an 11-year-old student, filed a class action lawsuit through his guardian ad litem against Illuminate Education, Inc., an education consulting business. J.M. alleged that Illuminate obtained his personal and medical information from his school to assist in evaluating his educational progress. Illuminate promised to keep this information confidential but negligently maintained its database, leading to a data breach where a hacker accessed the information. Illuminate delayed notifying J.M. and other victims about the breach for five months, during which J.M. began receiving unsolicited mail and phone calls.The trial court sustained Illuminate's demurrer, concluding that Illuminate did not fall within the scope of the Confidentiality of Medical Information Act (CMIA) or the Customer Records Act (CRA) and that J.M. failed to state a cause of action. J.M. filed a proposed second amended complaint with additional facts and a motion for reconsideration. The trial court reviewed the amended pleadings but maintained that J.M. had not stated a cause of action and could not amend to do so, thus sustaining the demurrer without leave to amend and entering judgment for Illuminate.The California Court of Appeal, Second Appellate District, reviewed the case and concluded that Illuminate falls within the scope of the CMIA and CRA. The court found that J.M. stated sufficient facts to support causes of action under both statutes. The court held that the trial court abused its discretion by sustaining the demurrer without leave to amend. The judgment of dismissal was reversed, and the case was remanded to the trial court, allowing J.M. to file an amended complaint with additional facts. View "J.M. v. Illuminate Education, Inc." on Justia Law

The case involves a dispute between Pima County and the State of Arizona regarding the reimbursement of desegregation expenses. Following amendments to Arizona Revised Statutes (A.R.S.) § 15-910 in 2018, the State ceased reimbursing Pima County for desegregation expenses that exceeded the Arizona Constitution’s 1% limit on residential property taxes. The key issue was whether these expenses, previously classified as "primary property taxes," should still be reimbursed by the State under the new statutory framework.The Arizona Tax Court initially ruled in favor of Pima County, holding that the State must reimburse the desegregation expenses as additional state aid for education. The court found the State's interpretation of the amended statute unworkable and inconsistent with the constitutional mandate. The State appealed this decision.The Arizona Court of Appeals reversed the Tax Court's decision, concluding that the legislature had the authority to amend the statutory scheme and reclassify the desegregation expenses as secondary property taxes. The court reasoned that the new classification did not violate the Arizona Constitution, as the legislature's amendments were within its purview to alter statutory tax classifications.The Arizona Supreme Court reviewed the case and affirmed the Court of Appeals' decision. The Court held that the 2018 amendments to A.R.S. § 15-910 effectively reclassified desegregation expenses as secondary property taxes, which are not subject to reimbursement under A.R.S. § 15-972(E). The Court concluded that the State is not required to reimburse Pima County for these expenses, as the new classification aligns with the legislative intent and does not violate the constitutional 1% limit on residential property taxes. The case was remanded to the Tax Court for the entry of judgment in favor of the State. View "PIMA COUNTY v. STATE OF ARIZONA" on Justia Law

The case involves the Newport School Committee and the Cumberland School Committee (collectively, plaintiffs) and the Rhode Island Department of Education and the Rhode Island Council on Elementary and Secondary Education (collectively, defendants). The dispute arose when the plaintiffs refused to reimburse the Department of Children, Youth, and Families (DCYF) at the "per-pupil special-education" rate for the cost of educating children who were placed in residential treatment programs by DCYF but were not receiving special-education services. The Family Court had placed two children in the temporary custody of DCYF and designated Newport and Cumberland as the residences of the children's custodial parents for the purpose of determining the municipalities' financial responsibility for the children's education.The Commissioner of Elementary and Secondary Education agreed with DCYF's argument that the municipalities were required to pay the per-pupil special-education rate according to the unambiguous language of the relevant statutes. The Commissioner issued two decisions ordering Newport and Cumberland to reimburse DCYF for the cost of educational services provided to the children at the special-education rate. After the Council on Elementary and Secondary Education denied the municipalities' independent appeals of the Commissioner's decisions, the municipalities appealed to the Superior Court. The trial justice consolidated the two cases and issued a written decision, determining that the clear and unambiguous language of the statute required the designated city or town to pay its share of the cost of educational services to DCYF rather than the higher, per-pupil special-education rate.The Supreme Court of Rhode Island reviewed the case and found that there is nothing in the relevant statutes that expressly obligates a municipality to pay the per-pupil special-education rate when the child in question is not actually receiving special-education services. The court concluded that municipalities are not required to reimburse DCYF at the per-pupil special-education rate when there were no special education services rendered and thus, no special education costs incurred. The court directed the parties to file supplemental briefs to resolve the remaining question of what reimbursement, if any, DCYF should receive for the educational cost of non-special-education students placed in residential treatment programs that include the delivery of educational services. View "Newport School Committee v. Rhode Island Department of Education" on Justia Law

This case involves a dispute between the University of Rhode Island Board of Trustees and the University of Rhode Island (plaintiffs) and the Hellenic Society Paideia – Rhode Island Chapter (defendant). The dispute arose from a breach-of-contract related to the construction of a Center for Hellenic Studies at the University of Rhode Island. The plaintiffs and defendant had entered into a Ground Lease Agreement that established the parameters for this construction project. The defendant failed to construct the Center for Hellenic Studies within the agreed timeframe, leading to litigation.The Superior Court stayed the litigation pending arbitration, as per the mandate. The arbitration proceedings were held, and the arbitrator issued a decision. The arbitrator found that the defendant had breached the lease agreement by failing to construct the Center for Hellenic Studies within the requisite timeframe, among other failures. The arbitrator also determined that a joint venture did not exist between the parties. The arbitrator directed the defendant to reimburse the plaintiffs for the cost and expenses that they will incur in their efforts to restore the construction site to its prior status.The plaintiffs filed a motion in Superior Court to confirm the arbitration award, which the defendant objected to and cross-moved to vacate. The trial justice granted the plaintiffs' motion to confirm the award and denied the defendant's cross-motion to vacate. The trial justice declined to review the arbitrator’s determination that the plaintiffs properly terminated the lease agreement and rejected the defendant’s objection to the arbitral remedy.The Supreme Court of Rhode Island affirmed the judgment of the Superior Court. The court concluded that the arbitrator's award drew its essence from the parties' lease agreement and lacked any indication that the arbitrator manifestly disregarded the law. The court rejected the defendant's arguments that the arbitrator had exceeded his authority. The court affirmed the trial justice's order confirming the arbitration award. View "The University of Rhode Island Board of Trustees v. Hellenic Society Paideia-Rhode Island Chapter" on Justia Law

This case involves a child with significant developmental disabilities, B.D., who attended Georgetown Public Schools. B.D.'s parents, Rachel and Michael Doucette, sued the school district and various personnel, alleging that the school's failure to properly implement B.D.'s individualized education program (IEP) and health and safety plan led to a series of five severe seizures that B.D. experienced at school in 2012. The Doucettes claimed that the school district violated B.D.'s constitutional rights under 42 U.S.C. § 1983 and Massachusetts tort law.The district court granted the school district's motion for summary judgment, finding that a reasonable jury could not conclude that the school district engaged in the conscience-shocking conduct necessary to sustain the constitutional claim, nor that the school district was liable under the state-law claims.The United States Court of Appeals for the First Circuit affirmed the district court's decision. The court found that the school district's conduct, while flawed, did not rise to the level of "conscience-shocking" behavior necessary to establish a violation of B.D.'s substantive due process rights. The court also found that the Doucettes failed to establish that the school district's conduct was the but-for cause of B.D.'s seizures, a necessary element of their state-law claims. View "Doucette v. Jacobs" on Justia Law

The Regents of the University of California (Regents) approved the construction of a new hospital at the University of California San Francisco (UCSF) Parnassus Heights campus. The Parnassus Neighborhood Coalition (the Coalition), a group of local property owners, sued to halt the construction, arguing it would violate local building height and bulk restrictions. The Regents countered that as a state entity, they were immune from local building and zoning regulations when engaging in governmental activities, such as constructing university buildings. The trial court disagreed, ruling that the question of whether the construction constituted a governmental or proprietary activity could not be resolved at this stage.The trial court concluded that the Regents' immunity depended on whether the proposed construction was a governmental or proprietary activity, a question of fact that could not be resolved on a demurrer. The court further concluded that the exemption only applies when a project is solely for educational purposes. The Regents petitioned for a writ of mandate to vacate the trial court’s order.The Court of Appeal of the State of California First Appellate District Division Three reviewed the case. The court held that the proposed hospital would facilitate the provision of clinical services, thereby advancing UCSF’s academic mission and the Regents’ educational purpose, which is a governmental activity. Therefore, the project falls within the Regents’ broad public purpose, and the Regents are exempt from the local regulations at issue. The court concluded that the demurrer should have been sustained and issued the writ of mandate. The court also ordered modifications to the published opinion filed on June 13, 2024, but there was no change in the judgment. View "Regents of the University of Calif. v. Super. Ct." on Justia Law

The case involves Susan George, a teacher who had worked for the Susanville Elementary School District for several years before resigning to teach at another school district. She later returned to the District. Upon her return, the District did not credit her for the years of experience she gained at the other school district following her resignation. George filed a petition for writ of mandate arguing the District violated the uniformity requirement of Education Code section 45028 and the restoration requirement of section 44931 when placing her on the salary schedule without accounting for the years of experience she gained while outside the District after her resignation.The trial court found that the District complied with the Education Code. It ruled that the collective bargaining agreement prevented George from acquiring credit for the two years she worked for another school district. The trial court further found the uniformity requirement did not afford George relief and the District complied with the restoration requirement by restoring George to her prior position. Consequently, the trial court denied George’s petition for writ of mandate.The Court of Appeal of the State of California Third Appellate District reversed the trial court's decision. The appellate court held that the District violated the uniformity requirement by failing to place George at step 15 of the District’s salary schedule. The court disagreed with the District's argument that the uniformity requirement is inapplicable to George’s placement on the salary schedule because the restoration requirement controls the placement of teachers rehired within 39 months. The court found that the District must credit George with up to 12 years of out-of-district experience. The court remanded the case with directions to issue a writ compelling the District to place George on its salary schedule in compliance with Education Code section 45028 as construed herein, with appropriate back pay and benefits. The District was ordered to pay costs on appeal. View "George v. Susanville Elementary School District" on Justia Law

The case involves two groups of plaintiffs, referred to as the Schneider plaintiffs and the Page plaintiffs, who challenged the title and one-sentence "yes/no" statements prepared by the Attorney General and the Secretary of the Commonwealth (Secretary) for Initiative Petition 23-36. This petition proposed to replace the Massachusetts Comprehensive Assessment System (MCAS) tests, currently used as a measure of student competency for high school graduation, with a system where students must satisfactorily complete coursework certified by their district as showing mastery of state academic standards.The plaintiffs filed their complaints in the Supreme Judicial Court for Suffolk County, arguing that the title and one-sentence statements were misleading and inconsistent with the requirements of G. L. c. 54, § 53. The Page plaintiffs contended that the statements only mentioned the elimination of MCAS without stating that it would be replaced with something else. The Schneider plaintiffs argued that the statements did not disclose that the petition would prohibit the use of any uniform statewide assessment as a graduation requirement.The Supreme Judicial Court of Massachusetts found that the title and one-sentence statements accurately characterized the petition's proposal to eliminate MCAS tests as a graduation requirement. The court noted that while the petition also proposed a new assessment scheme and prohibited any future statewide assessment from being used as a graduation requirement, these were not distinct regulatory features of the petition. The court concluded that the title and one-sentence statements did not need to describe every feature of the petition. The court also rejected the additional arguments forwarded by the Page plaintiffs. The court remanded the matter to the county court for entry of a judgment declaring that the Attorney General and Secretary's title and one-sentence statements were in compliance with the requirements of G. L. c. 54, § 53. View "Schneider v. Attorney General" on Justia Law

The case involves Shannon Blick, a former principal of an elementary school in the Ann Arbor Public School District. In 2019, Blick was placed on paid leave while the school district investigated her role in a custodian's over-billing scheme. The leave lasted two years, and the school district eventually terminated Blick's contract. Blick filed a lawsuit while still on leave, alleging that various officials violated her freedoms of speech and association under the First Amendment. She also brought race-discrimination, due-process, and conspiracy claims against these officials. The district court rejected Blick's First Amendment claims at the summary-judgment stage and dismissed the other claims on the pleadings.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court's decision. The court found that Blick failed to show a reversible error. She argued that the school district violated the First Amendment by imposing a prior restraint that barred her from speaking during her leave and by taking harmful actions against her in retaliation for her speech. However, the court found that Blick's lawyers did not provide sufficient information about what she wanted to say or what she did say. The court also found that Blick's opening brief did not preserve her challenges to much of the district court's motion-to-dismiss decision. As a result, the court affirmed the district court's decision. View "Blick v. Ann Arbor Public School District" on Justia Law

The case revolves around a disabled child, Abigail P., who filed a due process complaint against the Old Forge School District under the Individuals with Disabilities Education Act (IDEA), Section 504 of the Rehabilitation Act, and Pennsylvania state law. Abigail, who suffers from severe disabilities, claimed that the school district denied her a free appropriate public education (FAPE) when it moved to remote instruction during the COVID-19 pandemic.The case was first heard by a hearing officer appointed by the Pennsylvania Department of Education, who disagreed with Abigail's claim. The United States District Court for the Middle District of Pennsylvania also disagreed and affirmed the hearing officer's decision.The case was then brought before the United States Court of Appeals for the Third Circuit. The court was tasked with deciding whether Abigail received a FAPE during the COVID-19 pandemic. The court affirmed the lower courts' decisions, stating that the school district did not deny Abigail a FAPE. The court concluded that the school district provided an educational program reasonably calculated to confer meaningful educational benefits in light of Abigail's individual circumstances, even during the period of remote instruction. The court also clarified that its opinion does not give school districts carte blanche to reduce a disabled student’s school day for any reason or no reason at all. View "Abigail P. v. Old Forge School District" on Justia Law