Justia Education Law Opinion Summaries

Plaintiffs, Junhai Bai and Xiaofei Li, filed a lawsuit against the San Francisco Unified School District and teacher Stephanie Yip, alleging that their minor daughter, L.B., was physically abused by Yip. The complaint detailed incidents of abuse, including insufficient food and water, physical assault, and resulting injuries such as a concussion and chest contusion. The plaintiffs sought monetary damages for mental harm, impairment of working ability, future illness risk compensation, and family care.The San Francisco City & County Superior Court sustained the defendants' unopposed demurrer and granted their unopposed motion to strike portions of the complaint, allowing leave to amend but without specifying a deadline. Plaintiffs filed a revised version of their complaint several weeks after the time to amend had expired. The trial court did not consider this filing as an amended complaint. Defendants then moved to dismiss the action under section 581, subdivisions (f)(2) and (f)(4) of the Code of Civil Procedure, which the court granted.The California Court of Appeal, First Appellate District, Division Three, reviewed the case. The court held that under the decision in Gitmed v. General Motors Corp., the filing of an amended complaint, even if untimely, precludes dismissal under section 581, subdivision (f)(2), unless and until the amended complaint is stricken. The court found that the plaintiffs' revised pleading should have been treated as an amended complaint, which should have precluded the dismissal of the action. Consequently, the appellate court reversed the judgment and the order granting the motion to dismiss, remanding the case for further proceedings. View "Bai v. Yip" on Justia Law

R.A. filed a lawsuit against her son G.A.'s special education teacher, Robin Johnson, and several school officials, alleging that Johnson mistreated G.A. during the first and second grades. The complaint claimed that Johnson subjected G.A. to physical and emotional abuse and that the school officials negligently failed to intervene despite knowing about the abuse. The school officials moved to dismiss the negligence claims, arguing they were protected by public official immunity. The district court denied the motion, and the school officials filed an interlocutory appeal.The United States District Court for the Western District of North Carolina initially denied the school officials' motion to dismiss the state law claims, leading to an appeal. The Fourth Circuit Court of Appeals previously ruled that the school officials were entitled to public official immunity and that the state law claims against them should be dismissed. Despite this, the district court allowed R.A. to file an amended complaint with additional details from new evidence, which the school officials again moved to dismiss. The district court denied this motion, interpreting the appellate mandate as allowing dismissal without prejudice.The Fourth Circuit Court of Appeals reviewed the case again and held that the district court violated the mandate rule by not dismissing the claims with prejudice as instructed. The appellate court emphasized that its prior decision required dismissal with prejudice and that the district court's interpretation was incorrect. The court reiterated that the mandate rule requires lower courts to follow the appellate court's instructions precisely and that no exceptions to the mandate rule applied in this case. Consequently, the Fourth Circuit reversed the district court's decision, reaffirming that the state law claims against the school officials must be dismissed with prejudice. View "R.A. v. McClenahan" on Justia Law

A medical student at Florida International University (FIU) failed nine courses, including six while on academic probation, and was required to repeat a year. He was also reported for unprofessional behavior by three professors. Despite receiving accommodations for his diagnosed ADHD and anxiety disorder, he continued to perform poorly, failing multiple exams and receiving low scores on others.The student was placed on academic probation and later took a voluntary medical leave. Upon returning, he failed additional courses and was given another chance to repeat the second year. In his third year, he failed five final exams and scored poorly on others, leading to a third hearing by the promotion committee, which recommended his dismissal. The student appealed, citing various personal issues but did not initially claim inadequate disability accommodations.The district court granted summary judgment in favor of FIU, concluding that the student was not a "qualified individual" under the Americans with Disabilities Act (ADA) because he could not meet the university's academic standards even with reasonable accommodations. The student appealed this decision.The United States Court of Appeals for the Eleventh Circuit reviewed the case de novo and affirmed the district court's decision. The court held that the student was not a qualified individual under the ADA, as he failed to meet the essential eligibility requirements of the medical program despite receiving accommodations. The court emphasized the deference given to academic institutions in making judgments about students' academic performance and found that FIU had provided ample opportunities for the student to improve, which he failed to do. View "Nehme v. Florida International University Board of Trustees" on Justia Law

Grace Smith, a high school junior, was repeatedly suspended from Laramie High School for refusing to comply with a COVID-19 indoor-mask mandate imposed by the Albany County School District No. 1 Board of Trustees. After her suspensions, she was arrested for trespassing on school grounds. Grace and her parents, Andy and Erin Smith, filed a lawsuit in the United States District Court for the District of Wyoming against the Board members, the superintendent, and the principal, alleging violations of Grace’s constitutional rights and state law claims.The district court dismissed the federal claims for lack of jurisdiction, ruling that Grace did not suffer an injury in fact necessary for standing. The court reasoned that her injuries were hypothetical because the mask mandate had expired and she was no longer a student at LHS, and that her injuries were self-inflicted. The court declined to exercise supplemental jurisdiction over the state-law claims.The United States Court of Appeals for the Tenth Circuit reviewed the dismissal de novo and reversed the district court’s decision. The appellate court held that Grace had standing to bring her claims because she suffered concrete and particularized injuries from the enforcement of the mask mandate, including suspensions and arrest. The court found that her injuries were directly inflicted by the defendants’ actions and were not self-inflicted. The case was remanded for further proceedings consistent with the appellate court’s opinion. View "Smith v. Albany County School District No. 1" on Justia Law

The case involves the Hawai‘i Disability Rights Center (HDRC), which represents individuals with developmental disabilities, including children with autism. HDRC alleges that the Hawai‘i Departments of Education (DOE) and Human Services (DHS) unlawfully deny students with autism access to Applied Behavioral Analysis (ABA) therapy during school hours, even when medically necessary. DOE provides ABA services only if deemed educationally relevant, and DHS does not provide ABA services during school hours, even if medically necessary and covered by Medicaid or private insurance.The United States District Court for the District of Hawaii granted summary judgment in favor of DOE and DHS, holding that HDRC's failure to exhaust administrative procedures under the Individuals with Disabilities Education Act (IDEA) was fatal to all its claims, including those under the Americans with Disabilities Act (ADA), Section 504 of the Rehabilitation Act, and the Medicaid Act. The court concluded that HDRC, as a protection and advocacy organization, must ensure that parents of its constituents exhaust the IDEA’s administrative process.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that HDRC, as Hawai‘i’s designated protection and advocacy system, can pursue administrative remedies under the IDEA and is therefore bound by the IDEA’s administrative exhaustion requirement for its own claim. However, HDRC need not ensure that parents of individual children with autism exhaust their individual IDEA claims. The court found that HDRC did not exhaust its administrative remedies, and no exceptions to IDEA exhaustion applied.The Ninth Circuit also held that HDRC was not required to exhaust the IDEA’s administrative procedures before bringing its claims under the ADA, Section 504, and the Medicaid Act. The court concluded that HDRC’s non-IDEA claims do not allege the denial of a free appropriate public education (FAPE) and therefore do not require exhaustion under the IDEA. The court affirmed in part, reversed in part, and remanded the case. View "HAWAI'I DISABILITY RIGHTS CRT. V. KISHIMOTO" on Justia Law

M.D., a high school soccer player, sought a waiver from the West Virginia Secondary School Activities Commission (WVSSAC) to play for both her high school and club soccer teams during the same season. The WVSSAC denied her request, leading M.D. and her parents to file a lawsuit seeking a preliminary injunction to prevent the enforcement of the WVSSAC's Non-school Participation Rule, which prohibited participation in non-school teams during the school season for team sports but not for individual sports.The Circuit Court of Ohio County granted M.D. a preliminary injunction, allowing her to play for both teams. Subsequently, the court granted her summary judgment and a permanent injunction, ruling that the Non-school Participation Rule was arbitrary and capricious because it unfairly differentiated between team and individual sports without a rational basis.The WVSSAC appealed the circuit court's decision. While the appeal was pending, the WVSSAC's Board of Control amended the Non-school Participation Rule to eliminate the distinction between team and individual sports, applying the same restrictions to all student athletes regardless of the type of sport.The Supreme Court of Appeals of West Virginia reviewed the case and determined that the amendments to the Non-school Participation Rule rendered the appeal moot. The court found that the substantive changes to the rule addressed the issues raised by M.D., and there were no sufficient collateral consequences or issues of great public interest that warranted further review. Consequently, the court dismissed the appeal as moot. View "West Virginia Secondary School Activities Commission v. David D. and Elizabeth D., Parents and Legal Guardians of M.D." on Justia Law

In August 2021, New York City’s Department of Education mandated COVID-19 vaccinations for all staff and contractors working in school settings. This mandate was updated over time, including a religious exemption process. The plaintiffs, New York City public sector employees, challenged the constitutionality of the mandate and the exemption process, both facially and as applied.The Southern District of New York denied a preliminary injunction and dismissed the consolidated amended complaint on the merits. The Eastern District of New York also denied a similar preliminary injunction motion. The plaintiffs appealed these decisions, leading to a consolidated review by the United States Court of Appeals for the Second Circuit.The Second Circuit affirmed in part and dismissed in part the denials of preliminary injunctions, affirmed the dismissal of the facial challenges, and affirmed in part while vacating and remanding in part the dismissal of the as-applied challenges. The court found that the request to rescind the vaccine mandate was moot due to its official rescission and denied the request for reinstatement and backpay, as the plaintiffs could not show irreparable harm post-termination. The court upheld the dismissal of the facial challenges, finding no evidence that the Citywide Panel process preferred certain religions or was infected with religious animus. However, the court vacated and remanded the as-applied challenges for plaintiffs Natasha Solon and Heather Clark, who plausibly alleged that their religious accommodation requests were improperly denied. View "New Yorkers for Religious Liberty v. City of New York" on Justia Law

A class of over 500,000 federal student loan borrowers sued the U.S. Department of Education for failing to process their borrower defense (BD) applications. The Department and the plaintiffs reached a settlement, which included automatic debt forgiveness for certain borrowers and streamlined adjudication for others. Three for-profit universities (the Schools) listed in the settlement as having substantial misconduct intervened, claiming reputational harm.The U.S. District Court for the Northern District of California approved the settlement and denied the Schools' motion to intervene as of right but allowed them to object to the settlement. The Schools appealed, arguing that the settlement caused them reputational and financial harm and interfered with their procedural rights.The United States Court of Appeals for the Ninth Circuit held that the Schools had Article III standing due to alleged reputational harm but lacked prudential standing to challenge the settlement because they did not demonstrate formal legal prejudice. The court found that the dispute between the plaintiffs and the Department was not moot, as the Department's voluntary cessation of issuing pro forma denials did not render the case moot. The court also affirmed the district court's denial of the Schools' motion to intervene as of right, concluding that the Schools did not have a significantly protectable interest and failed to show prejudice from the denial of intervention as of right.The Ninth Circuit dismissed the appeal in part and affirmed the district court's denial of intervention as of right. View "Sweet v. Everglades College, Inc." on Justia Law

Keith Schiebel, a veteran agriculture educator, brought an educational program called the "Mobile Maple Experience" to the Schoharie Central School District (SCSD) campus. Following the event, a student's mother reported that Schiebel made her daughter feel uncomfortable, leading to a Title IX investigation. Schiebel was accused of reaching around the student and touching her breast and buttocks while retrieving supplies. Schiebel denied recalling the incident but speculated that he might have reached around a student to get something. The Title IX coordinator, Kristin DuGuay, found the allegations credible and determined that Schiebel had committed sexual harassment, resulting in a five-year ban of the Mobile Maple Experience from the SCSD campus.The United States District Court for the Northern District of New York dismissed Schiebel's Title IX claim, stating that while he plausibly alleged an erroneous finding, he did not plausibly allege that sex-based bias was a motivating factor. The court declined to exercise supplemental jurisdiction over Schiebel's state law claims.The United States Court of Appeals for the Second Circuit reviewed the case and concluded that Schiebel plausibly alleged that SCSD violated Title IX. The court found that the investigation was so deficient as to constitute a sham and that the decision was inexplicable. Additionally, the court noted that the Title IX coordinator exhibited sex-based bias against Schiebel. The Second Circuit reversed the district court's judgment and remanded the case for further proceedings consistent with its opinion. View "Schiebel v. Schoharie Cent. Sch. Dist." on Justia Law

Justine Ferreira sought reimbursement from the New York City Department of Education (DOE) for her disabled son's private education during the 2019-2020 school year, claiming the DOE failed to provide a free appropriate public education (FAPE) as required by the Individuals with Disabilities Education Act (IDEA). The DOE had developed an individualized education plan (IEP) for her son, but Ferreira disagreed with it and enrolled him in a private school, iBrain. She alleged that the DOE's proposed public school placement was inadequate.The Impartial Hearing Officer (IHO) and the State Review Officer (SRO) both found that Ferreira's conduct impeded the DOE's efforts to develop a suitable IEP, as she failed to cooperate and provide necessary information. They concluded that the balance of equities did not favor reimbursement. The United States District Court for the Southern District of New York (Judge Torres) granted summary judgment in favor of the DOE, agreeing with the IHO and SRO that Ferreira's actions frustrated the DOE's attempts to fulfill its obligations under the IDEA.On appeal, the United States Court of Appeals for the Second Circuit held that a district court must independently evaluate the equities in IDEA reimbursement cases without deferring to the state administrative agency's conclusions. However, the court found that the district court had indeed conducted an independent review and did not abuse its discretion in denying reimbursement. The court affirmed the district court's judgment, concluding that Ferreira's lack of cooperation and obstruction justified the denial of reimbursement for her son's private school tuition. View "Ferreira v. Aviles-Ramos" on Justia Law