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 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

A 13-year-old student, K.M., was found in possession of a folding knife on school grounds. The incident occurred when a campus supervisor took K.M. to the principal's office after a report of him vaping in the school bathroom. K.M. consented to a search of his backpack, which revealed two vape pens and a folding knife with two rusted blades. Later, the principal received a report that K.M. had threatened another student with the knife earlier in the day. Consequently, a police officer issued K.M. a citation for brandishing a knife and for possession of a knife on school grounds.The prosecution filed a wardship petition alleging that K.M. brought a weapon onto school property and brandished the knife. The juvenile court held a contested jurisdictional hearing, where the principal and the police officer testified. The court found K.M. guilty of the first count, designating the offense a felony, and dismissed the second count due to insufficient evidence. The court did not check the box indicating that it had found clear proof that K.M. knew his action was wrong. At a subsequent dispositional hearing, K.M.'s counsel argued that K.M. did not know he was breaking any rules when he had the knife at school because his father told him the knife was legal. The court declared K.M. a ward of the court and placed him on probation for six months.In the Court of Appeal of the State of California First Appellate District Division Three, K.M. argued that the prosecution did not prove, and the evidence does not support an implied finding, that he appreciated the wrongfulness of his conduct at the time of the incident. The court agreed with K.M., stating that there was no clear and convincing evidence that K.M. understood the wrongfulness of possessing a knife on school grounds. The court found insufficient evidence to support the juvenile court's implied finding that K.M. understood the wrongfulness of bringing a knife onto school property at the time of the incident. Therefore, the judgment was reversed and the matter was remanded for further proceedings. View "In re K.M." 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 proposed hospital was alleged to exceed local building height and bulk restrictions. The Parnassus Neighborhood Coalition (the Coalition), a group of property owners residing near the proposed hospital, sued to halt the construction, claiming it was a “threatened nuisance per se.” The Regents argued that as a state entity, they were immune from complying with local building and zoning regulations when engaging in a governmental activity such as constructing university buildings.The trial court disagreed with the Regents, concluding that their immunity depended on whether the proposed construction constituted a governmental or proprietary activity, a question of fact that could not be resolved on a demurrer. 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 concluded 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. The court held that the Regents are exempt from the local regulations at issue, and the demurrer should have been sustained. The court issued the writ of mandate, directing the trial court to vacate its order denying the Regents’ demurrer and to enter a new order sustaining the demurrer. View "The Regents of the University of California v. Superior Court" on Justia Law

The case involves two former faculty members at the University of California, Los Angeles (UCLA), who were accused of serious misconduct. An independent law firm was hired to investigate the allegations, and the resulting report concluded that the professors had engaged in improper activities. The professors resigned their positions as part of a settlement agreement, with no findings of misconduct or admissions of liability. A former UCLA employee requested the report under the California Public Records Act (CPRA), and the professors objected, leading to a series of legal actions known as "reverse-CPRA" actions.The Superior Court of Los Angeles County denied the professors' petitions to withhold the report, concluding that the public interest in disclosure outweighed the professors' privacy interests. The court found that the allegations of misconduct were serious and substantial, and that the public had a strong interest in knowing how the university handled such complaints. The professors appealed this decision.While the appeal was pending, the Los Angeles Times made its own CPRA request for related documents, including the investigation report and the settlement agreements. The professors sought a preliminary injunction to prevent the release of these documents, but the trial court denied their request. The court found that the professors were unlikely to succeed on the merits of their claim, as the analysis for the disclosure of these documents was the same as for the investigation report. The professors appealed this decision as well.The Court of Appeal of the State of California, Second Appellate District, affirmed the trial court's decision. The appellate court agreed with the trial court's analysis and found no reason to delay a decision on a matter concerning public transparency. The court concluded that the professors had not established a likelihood of success on the merits of their claim and were therefore not entitled to injunctive relief. View "Doe v. The Regents of the University of California" on Justia Law

The case involves two students, Chad Ayach and Joseph Nofal, who were expelled from the University of California Riverside (UC Riverside) following an administrative hearing. The university's Student Conduct and Academic Integrity Programs office (SCAIP) initiated an investigation into the Phi Gamma Delta fraternity (PGD) after receiving a report expressing concern for the health of a member of the fraternity's pledge class. During the investigation, it was revealed that the fraternity engaged in activities that appeared to meet UC Riverside's definitions of hazing. Ayach and Nofal, who held leadership roles in the fraternity, were subsequently expelled.The Superior Court of Los Angeles County reviewed the case after Ayach and Nofal filed a petition for writ of mandate challenging their expulsions. They argued that the university's administrative hearings did not afford them due process because the charging documents and evidence presented used pseudonyms to identify witnesses, and they were purportedly denied the opportunity to confront or cross-examine these witnesses at the hearing. The court denied the petition, and Ayach and Nofal appealed.The Court of Appeal of the State of California, Second Appellate District, Division One, affirmed the lower court's decision. The appellate court concluded that the administrative proceedings afforded Ayach and Nofal the process they were due, given the nature of the charges and their response. The court found that the hearings before the committee provided Ayach and Nofal with a full opportunity to present their defenses, which is what due process requires. The court also noted that the credibility of the witnesses was not central to the disciplinary decision, and therefore, the lack of cross-examination, lack of witness confrontation, and the use of pseudonyms in the description of witness statements did not prejudice Ayach's and Nofal's ability to present a meaningful defense. View "Ayach v. The Regents of the University of California" on Justia Law

The case revolves around a lawsuit filed by an adult, John Doe D.Y., alleging childhood sexual assault while in elementary school. The plaintiff used fictitious names for all defendants and did not serve any at the time of filing, as required by section 340.1 of the Code of Civil Procedure. The case was assigned to Judge Katherine A. Bacal. In October 2023, the superior court allowed the plaintiff to serve and name Doe defendants under section 340.1. In November 2023, the plaintiff named Doe 1 as Defendant and Petitioner San Diego Unified School District. The District was served with the complaint in December 2023.The District made its first appearance in January 2024, seeking an automatic extension of time to demur and filed a peremptory challenge under section 170.6 against the judge. The superior court denied the challenge as "untimely" without further explanation. The District then filed a petition for a writ of mandate, arguing that it had timely filed the challenge within 15 days of its first appearance.The Court of Appeal, Fourth Appellate District Division One, State of California, concluded that the superior court's review of the certificates under section 340.1 did not constitute a "determination of contested fact issues relating to the merits" under section 170.6(a)(2), and thus did not preclude a subsequent peremptory challenge. The court found that the superior court had erred in ruling the District's peremptory challenge as untimely. The court issued a peremptory writ of mandate directing the superior court to vacate its order denying the District's peremptory challenge, and to enter an order granting the challenge and reassigning the case to a different judge. View "San Diego Unified School Dist. v. Super. Ct." on Justia Law

John Sandy Campbell, a Resource Specialist Teacher at Chavez Social Justice Humanitas Academy from 2015 to 2017, was dismissed from her employment with the Los Angeles Unified School District due to excessive absences and other issues. The Commission on Professional Competence upheld her dismissal, and Campbell challenged this decision by filing a petition for writ of mandate in the superior court. The superior court, exercising its independent judgment, denied Campbell’s petition and upheld her dismissal.The proceedings to adjudicate Campbell’s dismissal were extensive, with the administrative hearing spanning 11 days. Campbell contended that the superior court erred in affirming her dismissal because the Commission miscited and applied the wrong statutory subdivisions at her dismissal hearing, and the court failed to apply “new” precedent when determining Campbell’s fitness to teach. The superior court recognized that the Commission cited incorrect subdivisions of section 44932 in its legal conclusions but noted that the Commission accurately listed, by name, the correct section 44932 causes for Campbell’s dismissal in these legal conclusions.The Court of Appeal of the State of California Second Appellate District Division Eight affirmed the superior court's decision. The appellate court found that Campbell had not demonstrated error in the lower court's decision. The court also rejected Campbell's insufficiency challenge due to her failure to present all the relevant evidence. Furthermore, the court found Campbell's argument that the superior court erred by not applying a more recent case law unconvincing. The court concluded that Campbell failed to overcome the presumption that the result was correct and affirmed the judgment, awarding costs to the District. View "Campbell v. Los Angeles Unified School District" on Justia Law

The case involves two public school districts, Cajon Valley Union School District (CVUSD) and Grossmont Union High School District (GUHSD), located within the boundaries of the former El Cajon Redevelopment Agency (RDA) in San Diego County. In 1988, the districts entered into “pass-through” agreements with the RDA, which agreed to provide the districts a portion of its annual property tax increment revenue up to a specified dollar cap. After the RDA was dissolved in 2012, the San Diego County Auditor-Controller continued to make payments according to the agreements. The districts sought a writ of mandate to compel the Auditor-Controller to make statutorily defined pass-through payments to them after the caps in their respective agreements were reached. The Auditor-Controller responded that she would not make further pass-through payments to the districts once their respective caps were reached.The trial court denied the requested relief. The court found that under the plain and unambiguous language of the statute, when the RDA adopted an amendment lifting the time limit to establish loans, advances, and indebtedness, it triggered a statutory obligation to pay one or the other of two things to affected taxing entities, depending on whether the RDA had entered into a pass-through agreement with any particular entity before January 1, 1994, that required pass-through payments to that entity. If such an agreement did exist, the RDA would need to make the contractually defined pass-through payments. If such an agreement did not exist, the RDA would need to make statutorily defined pass-through payments. The court concluded that the statute does not require other payments and it would not read such a requirement into the plain language of the statute.The Court of Appeal of the State of California Third Appellate District affirmed the judgment of the trial court. The appellate court agreed with the trial court's interpretation of the statute and found that the districts were not entitled to receive statutorily defined pass-through payments once the payment caps in the agreements were reached. View "Cajon Valley Union School District v. Drager" on Justia Law