Justia Education Law Opinion Summaries

Plaintiffs brought this action for damages under 42 U.S.C. 1983 on behalf of their minor daughter, who allegedly was deprived of her constitutional rights when she was expelled from public school and refused alternative education benefits during the 2005-2006 academic school year by defendants. The district court granted summary judgment in favor of defendants dismissing all of plaintiffs' claims. The court affirmed the district court's summary judgment in principal part, but reversed summary judgment with respect to plaintiffs' claims that their daughter was deprived of her constitutional right to procedural due process when defendants denied her right under state law to continued public educational benefits through an alternative education program without some kind of notice and some kind of hearing. Accordingly, the court remanded the case to the district court for further proceedings. View "Swindle, et al. v. Livingston Parish, et al." on Justia Law

Plaintiff, a minor with dyslexia, by and through her mother and Guardian Ad Litem, appealed from the district court's order affirming the Administrative Hearing Officer's conclusion that the Hawaii Department of Education (DOE) properly found plaintiff ineligible for services under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq. The court held that the DOE procedurally violated the IDEA by applying regulations that required exclusive reliance on the "severe discrepancy model" at plaintiff's final eligibility meeting. This violation deprived plaintiff of a significant educational opportunity because it resulted in an erroneous eligibility determination. Accordingly, the court reversed the district court's order affirming the Hearing Officer's decision and remanded for further proceedings. View "Michael P., et al. v. Dept. of Education, State of Hawaii" on Justia Law

Plaintiffs, a group of children who attended public schools in several South Dakota school districts and their parents and natural guardians, asked for a declaratory ruling that the state's present system of funding education was unconstitutional because it did not provide all children with an adequate and quality education. At issue was (1) S.D. Const. art. 8, 1 & 15, which requires the Legislature to establish and maintain a general and uniform system of public schools and provide funding to secure a thorough and efficient system of common schools throughout the state and (2) whether the legislative scheme for funding education met the constitutional requirements. The circuit court issued a judgment in favor of defendants, holding that the resources, curriculum, and facilities currently provided to students were constitutionally sufficient. The Supreme Court affirmed, holding that the current educational funding system failed to correlate with adequate student achievement to the point of declaring the system unconstitutional. View "Davis v. State " on Justia Law

Plaintiffs Ginger James and Deborah Tennison brought suit under 42 U.S.C.1983 alleging Defendant Prue Public Schools’ (the District) termination of their employment violated their First and Fourteenth Amendment rights. They appealed a summary judgment that rejected their claims, in which the district court determined (1) their pre-termination hearing satisfied their due-process rights, and (2) they failed to show their speech was a motivating factor for the termination. The School Board became concerned about the District’s finances. It initiated a financial investigation by retaining a financial consultant and terminated the treasurer’s employment. Without recommending any particular positions to be cut, Jones further opined there would have to be some reduction in personnel and it appeared the District had too many administrators. Eliminating the positions of an elementary and a high-school principal, it decided, would have the least impact on the students and was in the District’s best interest. Accordingly, the Board voted to eliminate the positions due to lack of funds and to dismiss Plaintiffs. Upon review, the Supreme Court found that the issues Plaintiffs raised in their appeal did not create a genuine issue of material fact regarding a denial of due process. Furthermore, they did not establish the occurrence and/or the content of the speech sufficiently for the district court to hold in their favor. Accordingly, the Court affirmed the district court’s decision. View "James v. Independent Sch. Dist. I-050" on Justia Law

While away for a competition in a school-supported event, students caused damage to a motel where they were lodging. The motel's property insurer paid to repair the damage then exercised its right of subrogation pursuant to its insurance contract with the motel to seek to recover compensation for those responsible for the loss. The insurer filed a complaint against the school district, alleging it was liable for breach of contract based on its failure to protect and safeguard the property from damage during the period of occupancy and to refrain from activities that would damage the property. The superior court granted the school district's motion for summary judgment. The Supreme Court affirmed, holding that because the school district did not undertake to be responsible to pay damages in a subrogation action, the insurer's action against the school board was barred. View "Middlesex Mutual Assurance Co. v. Me. Sch. Admin. Dist." on Justia Law

Ten special education students and their parents and guardians (Appellants) sued Clover Park School District for intentional torts, outrage, negligence and unlawful discrimination under state law. Clover Park moved for summary judgment to dismiss, arguing that Appellants had not exhausted the administrative remedies available under the state Individuals with Disabilities Education Act (IDEA). The trial court granted Clover Park’s motion. Upon review, the Supreme Court reversed the trial court and remanded the case, holding that IDEA’s administrative exhaustion requirement does not apply to state-law claims nor does Washington State law require exhaustion before filing such claims. View "Dowler v. Clover Park Sch. Dist. No. 400" on Justia Law

A Caucasian high school football player (H) accidentally hit an African-American team member (D) with his car, causing D to suffer a sprained ankle. H got out and apologized. D threatened to kill him. The principal had instructed staff to be lenient with African-Americans because too many were serving suspensions. Although the Code of Conduct prohibits threats, the school did not discipline D. D's parents threatened suit. The principal admitted suspending H for 10 days to "cover" himself and the school. H's witness statements were not provided to panelists in advance. H's attorney was limited to passing notes and not allowed to present witnesses. Employees were informed that they would lose their jobs if they attended the hearing. The board sustained the charge of reckless endangerment and suspension, so that it went on H's record. An appeal was denied. Before his suspension, college recruiters had approached H and a congressman had offered an appointment, the first step to attend a military academy. H alleges he lost those opportunities. The district court dismissed 42 U.S.C. 1983 claims for substantive due process violations, failure to train, and negligence; claims by H's parents; claims against individuals in their official capacities; claims against the board of education and the public school system. The Sixth Circuit affirmed denial of the motion to dismiss procedural due process and equal protection claims based on the conduct of three defendants and that those defendants are not protected by qualified immunity.View "Heyne v. Metro. Nashville Pub. Schs." on Justia Law

A six-year-old boy, with profound hearing impairment, was furnished with transportation to and from school as part of his individualized education program. The school district contracts with a private company for bus service. The boy alleged sexual abuse by a bus driver. The family sued under 42 U.S.C. 1983 and Title IX of the Education Amendments of 1972, 20 U.S.C. 1681-1688. The district court ruled in favor of the defendants. The First Circuit affirmed. The Section 1983 claim was properly rejected because transportation to and from school is not an exclusive state function; defendants did not act under color of state law. The Title IX claim failed because it is not clear that the "appropriate person," with the authority to take disciplinary action against the bus driver, actually knew about the alleged harassment and exhibited deliberate indifference toward it.View "Santiago v. Commonwealth of PR" on Justia Law

A former public high school student alleged that his history teacher violated his rights under the Establishment Clause by making comments during class that were hostile to religion in general, and to Christianity in particular. At issue was whether the teacher was entitled to qualified immunity. The court affirmed the district court's conclusion that the teacher was entitled to qualified immunity. The court also held that because it was readily apparent that the law was not clearly established at the time of the events in question, and because the court could resolve the appeal on that basis alone, the court declined to pass upon the constitutionality of the teacher's challenged statements. View "C.F. v. Capistrano Unified Sch. Dist, et al." on Justia Law

The family owned property and lived in Newburyport, but enrolled their son in school in Stamford, Connecticut during the 2008-2009 school year. His mother rented an apartment in Connecticut and on weekends returned to a Newburyport. The family gave up the Newburyport residence and moved to Connecticut in fall, 2009. The First Circuit vacated rulings in favor of the school district under the Individuals with Disabilities Education Act, 20 U.S.C. 1400-1482, which requires an education authority to provide an Individualized Education Plan for the benefit of any child with a disability. The district court misread the claims as moot. The claims are fairly read as saying that a procedural inadequacy, untimeliness, compromised plaintiffs' son's right to a guaranteed education. Newburyport had no obligation to draft a 2009 IEP for a nonresident, but the parents sought tuition reimbursement for the 2008-09 school year. View "Doe v. Newburyport MA Public Sch." on Justia Law