Justia Education Law Opinion Summaries

A plaintiff alleged that, between 1965 and 1969, while he was a young child attending an elementary school in a California school district, he was repeatedly sexually assaulted by the school’s principal. The complaint stated that school staff and faculty were aware or suspected the abuse, and that similar abuse occurred to other students. The plaintiff claimed ongoing psychological and emotional harm as a result. He brought four negligence-based causes of action against the school district, asserting that he was not required to present a government tort claim before filing suit due to statutory changes exempting such claims.The Superior Court of Merced County sustained the school district’s demurrer without leave to amend, dismissing the complaint. The court found that the plaintiff’s failure to comply with the Government Claims Act’s claim presentation requirement was fatal to his case, and concluded that legislative changes extending the statute of limitations for childhood sexual assault did not alter the deadline for filing a claim against a public entity.On appeal, the California Court of Appeal, Fifth Appellate District, reviewed whether Assembly Bill No. 218’s retroactive waiver of the Government Claims Act’s claim presentation requirement for claims under Code of Civil Procedure section 340.1 violated the California Constitution’s gift clause. The appellate court held that the retroactive waiver did not create a new liability or cause of action, but merely removed a procedural barrier to suit. The court further found that the legislative purpose of aiding victims of childhood sexual assault served a valid public purpose and did not constitute an unconstitutional gift of public funds. The judgment of dismissal was reversed and the case remanded for further proceedings. View "Doe R.L. v. Merced City School District" on Justia Law

A public elementary school district arranged for its students to attend a four-day overnight outdoor science camp operated by the county office of education. The county office provided direct overnight supervision, while district teachers were present but only on call. A student alleged that, during her attendance at the camp as a fifth grader, she was repeatedly sexually assaulted by a county office employee who served as a night monitor. The student claimed that both the district and the county office knew or should have known of the employee’s prior misconduct and failed to protect her.The student filed a negligence claim against the district, the county office, and the employee. The district moved for summary judgment in the Santa Clara County Superior Court, arguing that it was immune from liability under Education Code sections 35330 and 44808. The district contended that the camp was a “field trip or excursion” subject to a statutory waiver of claims and that, alternatively, it could not be liable because its employees were not providing immediate and direct supervision at the time of the alleged assaults. The trial court granted summary judgment for the district based solely on section 35330, finding the statutory waiver applied.The California Court of Appeal, Sixth Appellate District, reviewed the case de novo. It held that the district failed to establish as a matter of law that the camp was a “field trip or excursion” under section 35330, as the program was part of the required science curriculum rather than a recreational or observational departure. The court also found the district did not meet its burden under section 44808 to show that no district employee should have been providing immediate and direct supervision, especially in light of allegations that the district knew of risks posed by the county employee. The appellate court reversed the summary judgment in favor of the district. View "Doe v. Mount Pleasant Elementary School District" on Justia Law

In 2021, a plaintiff filed a complaint against a public school district, alleging that she was repeatedly sexually assaulted by a teacher while attending middle and high school. The complaint asserted that the teacher’s abusive conduct was widely known within the school and that the district either knew or should have known about the abuse but failed to act, allowing the teacher to remain employed. The plaintiff brought claims for negligence and negligent hiring, retention, and supervision, relying on statutory provisions that exempt certain childhood sexual assault claims from the usual requirement to present a claim to the public entity before filing suit.The Superior Court of Los Angeles County reviewed the case after the school district moved for judgment on the pleadings. The district argued that the plaintiff’s claims were only possible due to Assembly Bill 218 (AB 218), which retroactively eliminated the claims presentation requirement for childhood sexual assault claims against public entities. The district contended that AB 218 violated the gift clause of the California Constitution by imposing liability for past acts where no enforceable claim previously existed. The trial court agreed, finding that AB 218 retroactively created liability and constituted an unconstitutional gift of public funds, and dismissed the complaint with prejudice.The California Court of Appeal, Second Appellate District, Division One, reviewed the trial court’s decision de novo. The appellate court held that AB 218 does not violate the gift clause because it did not create new substantive liability; rather, it removed a procedural barrier to enforcing pre-existing liability for negligence and negligent hiring, retention, and supervision. The court reversed the trial court’s order and remanded with directions to deny the school district’s motion for judgment on the pleadings. View "O.B. v. L.A. Unified School Dist." on Justia Law

Kenya Taylor hired Los Angeles Unified School District (LAUSD) employee Tyler Martin-Brand to babysit her six-year-old son, Dayvon, during the winter break in 2019. Tragically, Martin-Brand killed Dayvon. Taylor sued LAUSD, alleging negligent hiring and supervision of Martin-Brand. A jury found in favor of Taylor, awarding her $30 million in damages. LAUSD appealed the trial court's denial of its motion for judgment notwithstanding the verdict (JNOV) and the judgment itself.The Superior Court of Los Angeles County denied LAUSD's motions for JNOV and a new trial, asserting that LAUSD was immune from liability under Education Code section 44808. The jury had found LAUSD negligent in hiring and supervising Martin-Brand, attributing 90% of the fault to LAUSD and 10% to Taylor.The Court of Appeal of the State of California, Second Appellate District, Division Three, reviewed the case. The court concluded that LAUSD was immune from liability for Dayvon’s off-campus death under Education Code section 44808, which limits school district liability for student injuries occurring off school property unless the district has specifically undertaken responsibility for the student. The court found that Dayvon’s death did not occur during any school-sponsored activity or under LAUSD’s supervision. Consequently, the court reversed the trial court's order and judgment, directing the trial court to enter judgment in favor of LAUSD. View "Taylor v. Los Angeles Unified School Dist." on Justia Law

The Oakland Education Association (OEA) represents certain employees of the Oakland Unified School District (District). Following a dispute over school closures approved by the District, OEA members conducted a one-day strike. OEA filed an unfair practice charge with the Public Employment Relations Board (PERB), claiming the District committed unfair practices under the Educational Employment Relations Act (EERA). The District filed a competing charge, claiming OEA’s strike was an unfair practice under EERA.PERB issued separate complaints for the competing charges and bifurcated the hearings. In its first decision, PERB found the District violated EERA. In its second decision, PERB held that OEA’s strike was legal because it was provoked by the District’s unfair practices and OEA had negotiated in good faith. The District did not challenge the first decision but contested the second, arguing that OEA’s strike was illegal and violated constitutional rights.The California Court of Appeal, First Appellate District, reviewed the case. The court held that public school employees may engage in unfair practice strikes under EERA. It concluded that PERB did not clearly err in finding that such strikes are allowed and that OEA’s one-day strike did not violate the rights to education, due process, or equal protection. The court also found that neither EERA nor the due process clause prohibits pre-impasse unfair practice strikes conducted before PERB determines an unfair practice has occurred. However, the court noted that PERB erred by excluding evidence of educational harm but deemed this error harmless. The court affirmed PERB’s decision. View "Oakland Unified School Dist. v. Public Employment Relations Board" on Justia Law

A student, E.I., attended El Segundo Middle School during the 2017-2018 school year and experienced bullying from classmates, particularly Skylar. Despite E.I. and her parents repeatedly reporting the bullying to school officials, including the principal and counselor, the school failed to take effective action. The bullying included verbal harassment, social media abuse, and physical aggression, which led E.I. to self-harm and develop PTSD and depression. The school’s anti-bullying policies were not adequately followed by the staff.The case was initially reviewed by the Superior Court of Los Angeles County, where a jury found the El Segundo Unified School District negligent and awarded E.I. $1 million in damages. The District moved for a new trial and for judgment notwithstanding the verdict, both of which were denied by the court.The California Court of Appeal, Second Appellate District, reviewed the case. The District argued several points on appeal, including errors in allowing reliance on certain Education Code provisions, claims of immunity under Government Code section 820.2, insufficient evidence of causation, improper consideration of a negligent training and supervision theory, admission of expert testimony, and attorney misconduct during closing arguments. The appellate court found that many of the District’s arguments were either waived or lacked merit. The court held that the District was not immune from liability under Government Code section 820.2, as the actions in question were operational rather than policy decisions. The court also found substantial evidence supporting the jury’s causation finding and determined that any potential errors were not prejudicial. Consequently, the appellate court affirmed the judgment in favor of E.I. View "E.I. v. El Segundo Unified School Dist." on Justia Law

The case involves the Temecula Valley Educators Association and individual students, teachers, and parents from the Temecula Valley Unified School District (collectively, Plaintiffs) who sued the District and five members of the District’s school board (collectively, Defendants). Plaintiffs sought declaratory and injunctive relief to prevent the implementation of “Resolution No. 2022–23/21” (the Resolution), which prohibits the use of Critical Race Theory (CRT) or similar frameworks in teaching topics related to race. The Resolution lists specific elements and doctrines of CRT that are banned. Plaintiffs argued that the Resolution is unconstitutionally vague and sought a preliminary injunction to halt its enforcement.The Superior Court of Riverside County denied Plaintiffs’ motion for a preliminary injunction, finding that the Resolution was sufficiently clear and that Plaintiffs did not show a likelihood of success on the merits. The court also concluded that the balance of harms favored denying the injunction, as enjoining a government action would cause irreparable injury.The California Court of Appeal, Fourth Appellate District, Division Three, reviewed the case. The appellate court found that the Resolution is unconstitutionally vague because it employs ambiguous language, lacks definitions, is unclear in scope, and contains no enforcement guidelines. The court noted that the Resolution’s language leaves teachers uncertain about what is prohibited, leading to self-censorship and fear of arbitrary enforcement. The court also found that the trial court abused its discretion by not considering the significant harm Plaintiffs would face without an injunction and by incorrectly concluding that the Resolution did not violate Plaintiffs’ constitutional rights.The appellate court reversed the trial court’s order denying the preliminary injunction as to the Resolution and remanded for the issuance of a preliminary injunction. The court dismissed the appeal related to the Board’s “Policy 5020.01” as moot, given that the relevant portions of the Policy had been rescinded following changes in the law. View "Mae M. v. Komrosky" on Justia Law

The Los Angeles College Faculty Guild, AFT Local 1521, sought to reverse the trial court’s denial of its motion to compel arbitration of three grievances against the Los Angeles Community College District. The grievances involved safety-related construction projects at Los Angeles City College, the termination of a faculty member at Pierce College, and the miscalculation of retirement benefits for a faculty member at Los Angeles Trade-Technical College.The Superior Court of Los Angeles County partially granted the motion to compel arbitration for the grievance related to backpay for the retirement benefits issue but denied the motion for the other grievances. The court found that the grievances were beyond the scope of the collective bargaining agreement and were preempted by the Education Code and other statutory requirements.The Court of Appeal of the State of California, Second Appellate District, Division Eight, affirmed the trial court’s decision. The appellate court held that the grievances related to construction projects and employment termination were not arbitrable because they were preempted by the Education Code and the Construction Bonds Act. The court also found that the grievance related to retirement benefits was partially arbitrable only concerning the backpay issue, as the Public Employees’ Retirement Law governed the reporting of service credits to CalPERS, and the arbitrator could not order injunctive relief beyond the scope of the collective bargaining agreement.The appellate court concluded that the Guild failed to demonstrate that the grievances were within the scope of representation as enumerated by the Educational Employment Relations Act and affirmed the trial court’s mixed ruling. View "L.A. College Faculty Guild v. L.A. Community College District" on Justia Law

In 2021, the Napa Foundation for Options in Education (Napa Foundation) filed a petition with the Napa Valley Unified School District (School District) to establish the Mayacamas Charter Middle School. The School District Board of Education denied the petition, and the Napa Foundation then submitted the petition to the Napa County Board of Education (County Board), which also denied it. The Napa Foundation appealed to the State Board of Education (State Board), which reversed the denials. The School District and the California School Boards Association’s Educational Legal Alliance (Educational Legal Alliance) filed petitions for writs of mandate to set aside the State Board’s decision.The trial court granted the writ petitions, finding that the State Board abused its discretion. The court concluded that the District Board did not provide a fair and impartial hearing process and that the County Board’s decision was supported by substantial evidence, including the fiscal impact of the proposed charter school on the School District.The California Court of Appeal, Third Appellate District, reviewed the case. The court found that the State Board’s determination that the District Board failed to provide a fair and impartial hearing was not supported by substantial evidence. The court also found that the County Board’s written factual findings, which detailed the negative fiscal impact of the proposed charter school, were supported by substantial evidence. The court concluded that the State Board’s decision to reverse the County Board’s denial was arbitrary, capricious, and entirely lacking in evidentiary support.The Court of Appeal affirmed the trial court’s judgments, upholding the denials of the charter school petition by the District Board and the County Board. The court emphasized that the State Board failed to properly apply the abuse of discretion standard in its review of the lower boards’ decisions. View "Napa Valley Unified School Dist. v. State Bd. of Education" on Justia Law

In September 2016, a high school student, almost 16 years old, was involved in a fistfight during an art class. The teacher, who weighed 375 pounds and had a back condition, intervened to stop the fight. While pulling one of the boys away, the teacher lost his balance and fell onto the plaintiff, breaking the plaintiff’s leg. The plaintiff sued the teacher and the school district for negligence, arguing that the teacher should not have intervened due to his physical condition and that the school district failed to train its teachers on safely handling physical altercations.The Superior Court of Los Angeles County held a 15-day trial, during which the jury viewed a video of the incident multiple times. The jury concluded that neither the teacher nor the school district was negligent and found that the plaintiff and the other boy were each 50 percent responsible for the harm. The plaintiff’s motion for judgment notwithstanding the verdict (JNOV) and a new trial was denied.The California Court of Appeal, Second Appellate District, reviewed the case. The court found substantial evidence supporting the jury’s verdict that neither the teacher nor the school district was negligent. The court also upheld the trial court’s exclusion of the plaintiff’s expert witness on the grounds that the expert was not qualified to opine on classroom management and discipline. Additionally, the court found no error in the trial court’s refusal to give the plaintiff’s requested special jury instructions, as the standard instructions on negligence were deemed sufficient. The judgment and the order denying the plaintiff’s motion for JNOV and a new trial were affirmed. View "I.C. v. Compton Unified School Dist." on Justia Law