Justia Education Law Opinion Summaries

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A high school student, K.J., was involved in a fight on campus and was initially suspended for three days. After reviewing surveillance footage and learning about injuries sustained during the fight, school officials extended K.J.'s suspension and recommended his expulsion, without informing him of the new charges or evidence. K.J. was not given an opportunity to respond to these new allegations.The United States District Court for the Southern District of California found that the school officials violated K.J.'s procedural due process rights by not informing him of the new charges or evidence. However, the court granted summary judgment in favor of the defendants, holding that they were entitled to qualified immunity because the law was not clearly established regarding due process protections for suspension extensions. The court also held that K.J. lacked standing to seek expungement of his disciplinary record, as it was speculative that the record would harm his reputation or future prospects.The United States Court of Appeals for the Ninth Circuit reversed the district court's summary judgment. The Ninth Circuit agreed that K.J.'s due process rights were violated, as he was not given notice of the new charges or an opportunity to respond. The court held that the defendants were not entitled to qualified immunity because the requirements for due process in school suspensions were clearly established in Goss v. Lopez. The court also held that K.J. had standing to seek expungement of his disciplinary record and that such relief was not barred by Eleventh Amendment sovereign immunity. The case was remanded to the district court to consider K.J.'s claims for damages and expungement. View "K. J. V. JACKSON" on Justia Law

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William A., a dyslexic student, graduated from high school with a 3.4 GPA but was unable to read. His parents filed a complaint under the Individuals with Disabilities Education Act (IDEA), claiming the school failed to provide him with a free appropriate public education (FAPE). The school had developed an individualized education plan (IEP) for William, which included language therapy and one-on-one instruction, but he made no progress in reading fluency throughout middle and high school. His parents eventually arranged for private tutoring, which helped him make some progress.An administrative law judge (ALJ) held a due-process hearing and found that the school had violated William's right to a FAPE under the IDEA. The ALJ ordered the school to provide 888 hours of dyslexia tutoring. William's parents then sought an order in federal court for the tutoring to be provided by a specific tutor, Dr. McAfee. The school counterclaimed, seeking reversal of the ALJ's order. The district court, applying a "modified de novo" standard of review, affirmed the ALJ's findings and ordered the same relief but denied the request for Dr. McAfee specifically.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court found that the school had not provided William with a FAPE, as his IEPs focused on fluency rather than foundational reading skills necessary for him to learn to read. The court noted that William's accommodations masked his inability to read rather than addressing it. The court affirmed the district court's judgment, holding that the school failed to provide an education tailored to William's unique needs, as required by the IDEA. View "William A. v. Clarksville-Montgomery County School System" on Justia Law

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Three former students of East Gaston High School, who were members of the wrestling team, filed a lawsuit against their coach, Gary Scott Goins, and the Gaston County Board of Education. They alleged that Goins subjected them to sexual abuse, physical violence, and psychological harm during the mid-1990s and early 2000s. Goins was criminally convicted in 2014 and sentenced to over thirty-four years in prison. The plaintiffs sought civil damages from the Board of Education, claiming it knew or should have known about the abuse. The claims were initially time-barred under the three-year statute of limitations, which began running on the victims' eighteenth birthdays.The Superior Court of Wake County, in a divided decision, declared the revival provision of the SAFE Child Act, which allowed previously time-barred claims to be filed during a two-year window, unconstitutional. The court held that the expiration of the statute of limitations created a vested right for the defendants, which the legislature could not retroactively alter.The North Carolina Court of Appeals reversed the lower court's decision, holding that the revival of the statute of limitations did not interfere with vested rights. The court reasoned that statutes of limitations are procedural and do not create property rights. Therefore, the legislature could retroactively alter them without violating the constitution.The Supreme Court of North Carolina affirmed the Court of Appeals' decision, holding that the running of a statute of limitations in a tort claim does not create a constitutionally protected vested right. The court emphasized that statutes of limitations are procedural and affect only the remedy, not the underlying right. The court concluded that the General Assembly has the authority to retroactively alter statutes of limitations for tort claims. View "McKinney v. Goins" on Justia Law

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K.S., a minor, through his guardian James Seeger, sued Richland School District Two, alleging gross negligence in supervising K.S.'s first-grade teacher and seeking liability under respondeat superior for injuries K.S. suffered due to the teacher's actions. The teacher, under personal stress, humiliated K.S. and other students, and physically grabbed K.S., causing him pain. K.S. experienced significant emotional distress and was diagnosed with persistent depressive disorder and anxiety.The trial court granted the District a directed verdict, ruling that the District could not be liable for negligence as K.S. suffered no physical injury. The court also excluded Seeger's expert testimony and ruled that the Safe School Climate Act did not repeal the South Carolina Tort Claims Act. The court of appeals affirmed the directed verdict, agreeing that no physical injury occurred and did not address the expert testimony exclusion or the Safe Schools Act ruling.The South Carolina Supreme Court reviewed the case and reversed the directed verdict, finding that the teacher's forceful grabbing of K.S. constituted sufficient physical harm to support a negligence claim. The court also reversed the exclusion of Seeger's expert, Dr. McEvoy, ruling that his testimony was not needlessly cumulative and would have provided crucial insight into the District's policies and their implementation. The court affirmed the trial court's ruling that the Safe Schools Act did not repeal the Tort Claims Act, maintaining that the Act does not create a private right of action or alter tort liability.The Supreme Court remanded the case for further proceedings consistent with its opinion, allowing Seeger's negligence claims to proceed and permitting the District to renew objections to Dr. McEvoy's testimony on remand. View "K.S. v. Richland School District Two" on Justia Law

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F.B. and M.B. filed a lawsuit on behalf of themselves and their minor child, L.B., under Section 504 of the Rehabilitation Act, alleging that Our Lady of Lourdes Parish and School failed to comply with procedural standards and requirements mandated by the Act's implementing regulations. L.B. had ADHD and reduced vision, and her parents claimed that the school initially provided necessary accommodations but later failed to do so after a change in school administration. This led to L.B. receiving failing grades and eventually being expelled from the school.The United States District Court for the Eastern District of Missouri dismissed the case, holding that Section 504 does not create a private right of action for claims based solely on an alleged failure to comply with procedural standards and requirements of the implementing regulations. The plaintiffs appealed this decision.The United States Court of Appeals for the Eighth Circuit reviewed the case and concluded that the plaintiffs lacked Article III standing to bring their claims. The court found that the plaintiffs' alleged injury, L.B.'s expulsion, was not fairly traceable to the school's failure to comply with the procedural regulations of Section 504. Additionally, the court determined that the relief sought by the plaintiffs would not redress their alleged injury. Consequently, the Eighth Circuit vacated the district court's judgment and remanded the case with instructions to dismiss for lack of jurisdiction. View "F.B. v. Our Lady of Lourdes Parish and School" on Justia Law

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Plaintiff Curtis Hier requested records from the Slate Valley Unified School District related to incidents of restraint and seclusion of students at Fair Haven Grade School. Specifically, he sought redacted copies of "Rule 4500 forms" from January to April 2021, documents related to the use of certain rooms between 2015 and 2022, and any redacted restraint and seclusion documents concerning the assistant principal. The school district denied the requests, claiming the records were student records and thus exempt from disclosure under the Public Records Act.The Superior Court, Rutland Unit, Civil Division, denied the school district's motion for summary judgment and granted summary judgment to the plaintiff. The court found that the Rule 4500 forms were not student records but were meant for monitoring the use of restraint and seclusion in schools. It ordered the school district to disclose the forms with specific redactions to protect student privacy. The court also denied the plaintiff's motion to amend the judgment to remove certain redactions.The Vermont Supreme Court reviewed the case and reversed the trial court's decision. The Supreme Court held that the Rule 4500 forms are categorically exempt from disclosure as student records under the Public Records Act. The court emphasized that the language of the student records exception is broad and unqualified, similar to its previous ruling in Caledonian-Record Publishing Co. v. Vermont State Colleges. The court concluded that the forms, which contain information related to specific students and incidents, fall squarely within the statutory exception for student records and are not subject to redaction or disclosure. View "Hier v. Slate Valley Unified School District" on Justia Law

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John Doe 2, a student athlete at North Carolina State University, alleged that he was sexually abused by Robert Murphy, the university’s Director of Sports Medicine, under the guise of medical treatment. Doe claimed that the university was deliberately indifferent to prior complaints of Murphy’s sexual misconduct. The district court dismissed Doe’s complaint, finding that he failed to plead facts supporting an inference that the university had actual notice of Murphy’s sexual harassment.The United States District Court for the Eastern District of North Carolina dismissed the complaint under Federal Rule of Civil Procedure 12(b)(6). The court concluded that a report of “sexual grooming” could not provide actual notice to the university of sexual harassment. The district court assumed without deciding that the report was made to an official with the requisite authority for Title IX purposes but found that the report did not describe an incident of sexual harassment and thus could not support a plausible inference of actual notice.The United States Court of Appeals for the Fourth Circuit reviewed the case and vacated the district court’s judgment. The Fourth Circuit held that a report of “sexual grooming” can objectively be construed as alleging sexual harassment, thus providing actual notice to the university. The court found that the district court erred in its conclusion and remanded the case for further proceedings to determine whether the report was made to an appropriate official with the authority to address complaints of sexual harassment and to institute corrective measures on behalf of the university. View "John Doe 2 v. North Carolina State University" on Justia Law

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Davina Ricketts, a sophomore at a high school in North Carolina, decided to run for student council to address its lack of diversity. She faced racial harassment and cyberbullying from peers, and the school district allegedly failed to intervene. Ricketts filed a lawsuit claiming the school district was deliberately indifferent to her harassment. The district court dismissed her complaint and denied her motion to amend, stating her proposed amended complaint also failed to state a claim. Ricketts appealed the denial of her motion for leave to amend.The United States District Court for the Eastern District of North Carolina initially dismissed Ricketts' complaint and denied her motion to amend on futility grounds. The court reasoned that her proposed amended complaint did not sufficiently state claims for deliberate indifference, retaliation, or equal protection violations.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court found that Ricketts sufficiently alleged deliberate indifference, retaliation, and equal protection claims. The court held that Ricketts' allegations of racial harassment, the school administrators' authority and actual knowledge of the harassment, and their deliberate indifference were sufficient to state a Title VI claim. The court also found that Ricketts sufficiently alleged retaliation by showing she engaged in protected activity, faced materially adverse actions, and established a causal connection between the two. Additionally, the court held that Ricketts sufficiently alleged an equal protection claim against individual defendants and the Board of Education by showing discriminatory intent and a municipal custom or policy of indifference.The Fourth Circuit reversed the district court's judgment, directed the district court to allow Ricketts to amend her complaint, and remanded the case for further proceedings. View "Ricketts v. Wake County Public School System" on Justia Law

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The Austin American-Statesman requested the University of Texas at Austin to disclose the final results of disciplinary hearings involving sex offenses. The University refused to provide the information without seeking a decision from the Office of the Attorney General (OAG). The Statesman sued the University, seeking a writ of mandamus to compel the disclosure of the records.The trial court granted the Statesman’s motion for summary judgment, ordering the University to produce the requested information. The court found that the University was required to seek an OAG decision and that its failure to do so raised the presumption that the information was subject to disclosure. The court of appeals affirmed the trial court’s decision, holding that the University did not establish a compelling reason for withholding the information and that Section 552.114(b) of the Texas Public Information Act (PIA) did not give the University discretion to withhold the records. The court of appeals also reversed the trial court’s denial of attorney fees to the Statesman.The Supreme Court of Texas reviewed the case and held that Section 552.026 of the PIA grants educational institutions discretion to disclose information in education records if the disclosure is authorized by the Family Educational Rights and Privacy Act (FERPA). The Court concluded that the PIA does not require the release of such information. Additionally, the Court held that the University was not required to seek an OAG decision before withholding the information, as Section 552.114(d) allows educational institutions to redact information without requesting an OAG decision. The Supreme Court of Texas reversed the court of appeals’ judgment and rendered judgment for the University. View "THE UNIVERSITY OF TEXAS AT AUSTIN v. GATEHOUSE MEDIA TEXAS HOLDINGS II, INC." on Justia Law

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Howard University’s Board of Trustees amended the institution’s bylaws to remove trustee positions that had been filled by alumni, students, and faculty for several decades. A group of alumni sued the University and the Board in D.C. Superior Court, seeking a declaration that the Board’s amendment was ultra vires because it violated the governing bylaws. Howard removed the case to federal court, arguing that the governance dispute hinged on the University’s federal charter. The alumni moved to remand the case back to state court.The United States District Court for the District of Columbia denied the alumni’s motion to remand, holding that the suit implicated a significant federal issue under Grable & Sons Metal Products, Inc. v. Darue Engineering & Manufacturing. The District Court then granted Howard’s motion to dismiss the case under Federal Rule of Civil Procedure 12(b)(6).The United States Court of Appeals for the District of Columbia Circuit reviewed the case and held that the District Court erred in exercising jurisdiction. The Court of Appeals determined that the case did not arise under federal law nor present a significant, disputed federal issue under Grable. Consequently, the Court of Appeals reversed the District Court’s decision and remanded the case with instructions to dismiss it without prejudice for lack of subject matter jurisdiction. View "Jenkins v. Howard University" on Justia Law