Justia Education Law Opinion Summaries

Parents "Madeline P." and "Rex P." challenged a school district's actions regarding their child's educational program under the Individuals with Disabilities Education Act (IDEA). A hearing officer found an IDEA violation but awarded less compensatory education services for the child than the parents requested. On appeal, the superior court affirmed the IDEA violation finding and the compensatory education award. The parents appealed, arguing that more compensatory education services should have been awarded; the school district cross-appealed, arguing that no compensatory education services should have been awarded. The Supreme Court affirmed the superior court's findings regarding the school district's violation of the IDEA's procedural and substantive requirements and the compensatory education award. View "Madeline P. v. Anchorage School District" on Justia Law

Plaintiff sued defendant, alleging that defendant had unlawfully discriminated against her in violation of the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq. Plaintiff, a medical student who was diagnosed with dyslexia and a mild processing-speed disorder, contended on remand that the district court erred by failing to apply the 2008 amendments to the ADA and in relying on her prior academic achievement in assessing whether she suffered from a disability under the ADA. The court held that because plaintiff failed to show legal or clear factual error by the district court, the judgment was affirmed. View "Singh v. GW Univ. School of Medicine, et al." on Justia Law

The Supreme Court granted a writ application to determine whether a school board had tort liability for expelling a high school student after a fifth-sized bottle of whiskey fell from the student's backpack and broke on the classroom floor. The student claimed he was denied due process in the disciplinary proceedings that resulted in his expulsion. The district court agreed and awarded the student $50,000. Upon review of the trial court record, the Supreme Court found that the student presented no evidence whatsoever of being denied due process at the school board hearing. Finding the student failed to carry his burden of proof to show a denial of due process by the school board, the Court reversed the judgment of the district court. View "Christy v. McCalla" on Justia Law

Plaintiff, who had a history of depression and bipolar disorder, filed a complaint against the Board when she was terminated from her position when she failed to complete at least six semester hours of professional development training to renew her certificate. At issue was whether a disabled teacher was a "qualified individual with a disability" under the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq. The court held that because plaintiff did not allege that the Board's legal authorization requirement was itself discriminatory, her failure to satisfy such requirement rendered her unqualified and the Board was not required to accommodate her disability. Accordingly, the judgment was affirmed. View "Johnson v. Board of Trustees of the Boundary County Sch., et al." on Justia Law

Unable to maintain a satisfactory academic record in a state dental school, plaintiff was dismissed. He unsuccessfully petitioned school committees and administrators to overturn the decision, then filed a complaint alleging First Amendment, equal protection, and procedural due process violations. The district court dismissed. The Seventh Circuit affirmed, holding that petitioner received ample process. He had ample notice, having been on academic probation, he was given several opportunities to remediate, and was allowed to appeal.View "Hlavacek v. Boyle" on Justia Law

The District of Columbia appealed the denial of its motion to vacate a preliminary injunction pursuant to Rule 60(b)(5) of the Federal Rules of Civil Procedure. The injunction was issued in 1995 in response to a class action complaint alleging that the District of Columbia was violating the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq., by failing to timely pay private providers of special education services and thereby jeopardizing students' special education placements. The district court denied the motion on two grounds: (1) dissolving the injunction and subsequent payment orders "would be disruptive to the status quo" and "counter-productive to the goal" of settling the case "in short order," and (2) the District of Columbia had "overstated both the relevance and the significance" of the Supreme Court's recent decision in Horne v. Flores. The court held that the district court failed to address changed circumstances, as Flores instructed, and reversed and remanded the case to the district court to determine whether, in view of changed circumstances, the District of Columbia's Rule 60(b)(5) motion should be granted. View "Petties, et al. v. District of Columbia, et al." on Justia Law

Relator, Angela Dawson, requested a writ of mandamus to compel Respondent, a local school district, to provide her with access to (1) itemized invoices of law firms providing services to the district in matters pertaining to Dawson and her children, and (2) communications from the school district's insurance carrier identifying the district's legal representative and describing the liability and exposure of the district and insurance company related to a case filed against the district by Dawson on behalf of one of her children. The Supreme Court denied the writ, holding that the requested records were exempt from disclosure under the Public Records Act because the school district met its burden of establishing the applicability of the attorney-client privilege to the requested records. View "State ex rel. Dawson v. Bloom-Carroll Local Sch. Dist." on Justia Law

The Supreme Court granted review to determine whether a public school district was obligated to fund a kindergarten program offered by a cyber charter school for a four-year-old student when the district exercised its discretion not to offer such a program in its public schools. In 2006, the Secretary of Education notified Appellant Slippery Rock Area School District that funds had been deducted from the district's state subsidy and made payable to Appellee Pennsylvania Cyber Charter School. The Secretary deducted funds because Slippery Rock failed to pay Cyber School for numerous students residing in the district who were attending Cyber School. Slippery Rock objected to the withholding of $1,716.63 for a four-year-old female student enrolled in Cyber School’s kindergarten program. Slippery Rock averred that while it operates a discretionary kindergarten program for five-year-old children, the student at issue did not meet the age requirements for admission into the district’s kindergarten program, Slippery Rock argued that it was not obligated to "assume the costs or obligation of this individual’s enrollment into [Cyber School]." The Secretary concluded that Slippery Rock could not deny payment to Cyber School simply because Slippery Rock did not have a four-year-old kindergarten program. Subsequently the Secretary granted Cyber School's motion to dismiss Slippery Rock's objection. The Commonwealth Court affirmed the Secretary, but the Supreme Court reversed the Commonwealth Court and the Secretary: "[t]o hold that Slippery Rock is obligated to fund educational opportunities for students not yet eligible to attend the district’s public schools would allow those students who enroll in Cyber School to receive greater benefits than a similarly-situated student who chooses to attend the public school." View "Slippery Rock Area Sch. Dist. v. Pa. Cyber Charter Sch." on Justia Law

A jury awarded compensatory and punitive damages under 42 U.S.C. 1983 and 20 U.S.C. 1681 for failure by defendant,a middle school principal, to prevent sexual abuse of several female students by their band teacher. The band teacher pled guilty to multiple counts of aggravated kidnapping and aggravated criminal sexual abuse. The Seventh Circuit affirmed the awards. The awards of compensatory damages reflected consideration of the harm to each individual plaintiff; the award of punitive damages was justified in light of defendant's failure to act. View "G.G. v. Grindle" on Justia Law

Plaintiff, a teacher with professional teacher status, was dismissed by the superintendent of the school district for multiple instances of conduct unbecoming a teacher. On appeal, plaintiff argued that G.L.c. 71, section 42, which compelled arbitration of a wrongful dismissal claim made by a public school teacher with professional teacher status, violated art. 30 of the Massachusetts Declaration of Rights because it impermissibly delegated to a private individual (an arbitrator) a judicial function and denied meaningful judicial review. The court concluded that this statute's provision authorizing arbitration of a principal or superintendent's dismissal decision did not interfere with core judicial functions and that the scope of judicial review set forth in the statute did provide for meaning judicial review such that there was no art. 30 violation. Plaintiff also contended that, pursuant to G.L.c. 150C, section 11, the arbitration award should be vacated because the arbitrator acted in excess of her authority, engaged in misconduct, and exhibited bias against him. The court concluded that the judge properly concluded that the arbitrator did not exceed her authority or act in manifest disregard for the law. The court also rejected plaintiff's claims that the arbitrator engaged in misconduct and exhibited bias. Accordingly, the judgment was affirmed. View "Atwater v. Commissioner of Education" on Justia Law