Justia Education Law Opinion Summaries

After sustaining a knee injury during a mandatory eighth-grade physical education class’s touch football unit, Plaintiff sued, among others, defendants Burbank Unified School District (the District) and his physical education teacher. A jury returned verdicts in Plaintiff’s favor against Defendants, finding that the District breached a mandatory duty under the Education Code, the teacher was negligent, and Plaintiff suffered resulting harm. Defendants appealed from the judgment, contending: there was insufficient evidence that the District’s breach of a mandatory duty proximately caused Plaintiff’s injury; the special verdict form was fatally defective because it failed to specify whether the District’s breach of a mandatory duty or the teacher’s negligence was a substantial factor in causing Plaintiff’s injuries; the trial court erred by failing to instruct the jury on the primary assumption of risk doctrine; and the court erred by not allowing the jury to apportion fault to the student who ran into Plaintiff (the Student), thus precluding Defendants from reducing liability for noneconomic damages.   The Second Appellate District reversed and remanded for the trial court to enter judgment in favor of the District and to hold a new trial limited to the issue of apportionment of fault between the teacher and student. The court explained that the Student’s act of intentionally running into Plaintiff was a substantial causative factor in Plaintiff’s injury and the teacher, therefore, should have been entitled to seek allocation of fault pursuant to Civil Code section 1431.2.11 Because the trial court failed to instruct the jury on comparative fault principles, the court remanded for retrial on the apportionment of fault. View "Nigel B. v. Burbank Unified Sch. Dist." on Justia Law

In consolidated appeals, Plaintiff challenged the district court’s award of summary judgment to defendant Liberty University, Inc. (“Liberty”) on Palmer’s claim of age discrimination, pursued under provisions of the Age Discrimination in Employment Act (the “ADEA”)  (the “Statutory Ruling”). On the other hand, Liberty, by cross-appeal, challenged an earlier award of summary judgment that was made to Plaintiff, in which the court ruled that Plaintiff was not a “minister” for purposes of the First Amendment’s so-called “ministerial exception” (the “Constitutional Ruling”).   The Fourth Circuit affirmed the Statutory Ruling, dismissed Liberty’s cross-appeal, and vacated the Constitutional Ruling. The court explained that it agreed with the district court that Plaintiff failed to produce sufficient evidence of age-based discrimination to overcome Liberty’s summary judgment motion on that issue. Accordingly, the court was satisfied to affirm the Statutory Ruling in favor of Liberty. Moreover, in light of that disposition — and pursuant to the constitutional avoidance doctrine — the court refrained from resolving whether Plaintiff was a minister for purposes of the First Amendment’s ministerial exception. As a result, the court wrote it was obliged to dismiss Liberty’s cross-appeal and vacate the Constitutional Ruling. View "Eva Palmer v. Liberty University, Incorporated" on Justia Law

The Higher Education Act governs federal financial aid, 20 U.S.C. 1070(a), and authorizes the Secretary of Education to cancel or reduce loans held by some public servants and borrowers who have died, become permanently and totally disabled, are bankrupt, or whose schools falsely certify them, close down, or fail to pay lenders. Under the Higher Education Relief Opportunities for Students Act (HEROES Act), the Secretary “may waive or modify" any statutory or regulatory provision applicable to the loan programs as the Secretary deems "necessary in connection with a war or other military operation or national emergency.” As the COVID–19 pandemic was ending, the Secretary invoked the HEROES Act to issue “waivers and modifications” reducing or eliminating most borrowers' federal student debt. States challenged the plan. The Eighth Circuit issued a nationwide preliminary injunction.The Supreme Court found that the plan exceeded the Secretary’s authority, first holding that at least Missouri had standing. The plan would cost the state's nonprofit government corporation about $44 million a year in fees.The HEROES Act allows the Secretary to “waive or modify” existing statutory or regulatory provisions but does not allow the Secretary to rewrite the Education Act to the extent of canceling $430 billion of student loan principal. The Secretary may make modest adjustments to existing provisions, not transform them. The Act includes narrowly-delineated situations that qualify a borrower for loan discharge; the Secretary has extended such discharge to nearly every borrower. The plan constitutes “effectively" a "whole new regime.” The question is not whether something should be done; it is who has the authority to do it. The basic and consequential tradeoffs inherent in mass debt cancellation are ones that Congress would likely have intended for itself. View "Biden v. Nebraska" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the decision of the trial court appeals denying the Texas Tech University School of Medicine's combined plea to the jurisdiction and summary judgment motion in the underlying unlawful discrimination action, holding that morbid obesity does not qualify as an impairment under the Texas Commission on Human Rights Act (TCHRA) without evidence that it is caused by an underlying physiological disorder or condition.After Plaintiff was dismissed from Texas Tech's medical residency program she brought this complaint alleging that the University dismissed her because of her morbid obesity, which she argued constituted unlawful discrimination under the TCHRA. The University filed a combined plea to the jurisdiction and summary judgment motion, arguing that it was protected under sovereign immunity. The trial court denied the plea and motion, and the court of appeals affirmed. The Supreme Court reversed, holding (1) morbid obesity qualifies as an impairment under the Labor Code only when caused by a physiological disorder or condition; and (2) Plaintiff could not establish that the University regarded her as having an impairment, and Plaintiff failed to show a disability as defined in the Labor Code. View "Tex. Tech University Health Sciences Center - El Paso v. Niehay" on Justia Law

The Supreme Court reversed the decision of the court of appeals that all of the documents underlying an external investigation into allegations of undue influence in a public university's admissions process were protected by the attorney-client privilege and were thus exempt from disclosure under the Texas Public Information Act, holding that the university's attorney-client privilege as to specific documents was waived.Specifically, the Supreme Court held (1) the investigator acted as a lawyer's representative in conducting the investigation; (2) the subject documents fell within the attorney-client privilege; (3) the university did not waive the privilege by disclosing to the investigator some of the documents; and (4) the publication of the investigator's final report waived the university's attorney-client privilege as to documents that the final report directly quoted from or otherwise disclosed a significant part of. View "University of Tex. System v. Franklin Center for Gov't & Public Integrity" on Justia Law

In March 2020, O’Brien was censured and suspended for one year from his employment as a professor at the University of California, Berkeley, for violating the Faculty Code of Conduct while attending an overseas conference in 2012 by directing unwanted sexualized conduct at a junior colleague attending the conference, a graduate student at Massachusetts Institute of Technology. Although another student referred to the incident in a 2014 discussion with the administration, it was not until 2017 that the alleged victim made a report.O’Brien challenged the disciplinary decision, raising procedural, substantive, and due process objections. The trial court and court of appeal rejected O’Brien’s petition. The University’s rule requiring it to initiate disciplinary action within three years of receiving a report of misconduct does not bar discipline here. The earlier complaint by a different student only briefly touching on the alleged incident between O’Brien and an unidentified female MIT student was not a report of the wrongdoing for which he was disciplined. Substantial evidence supports a finding by the University and the trial court that the MIT student was a “colleague” of O’Brien’s, as the Faculty Code of Conduct uses that term. The disciplinary proceeding was fair and the committee’s findings supported the ultimate result. View "O'Brien v. The Regents of the University of California" on Justia Law

In the Harvard College admissions process, “race is a determinative tip for” a significant percentage “of all admitted African American and Hispanic applicants.” University of North Carolina (UNC) also considers the applicant’s race. SFFA challenged both systems.The Supreme Court held that both programs violate the Equal Protection Clause of the Fourteenth Amendment. The Court first held that SFFA complies with the standing requirements for organizational plaintiffs as a voluntary membership organization with identifiable members who support its mission and whom SFFA represents in good faith.Tracing the history of Fourteenth Amendment precedent, the Court acknowledged its "role in that ignoble history,” and subsequent efforts to eliminate racial discrimination. The core purpose of the Equal Protection Clause is to eliminate all governmentally-imposed discrimination based on race. Any exceptions must survive strict scrutiny. which asks whether the racial classification is used to advance compelling governmental interests and whether the use of race is narrowly tailored--necessary to achieve that interest. Previous holdings permitted race-based college admissions only in compliance with strict scrutiny and acknowledged that, eventually, they must end.The admissions programs at issue are not sufficiently measurable to permit strict scrutiny. The identified "compelling" interests include training future leaders, acquiring new knowledge based on diverse outlooks, promoting a robust marketplace of ideas, and preparing engaged and productive citizens. The question of whether a particular mix of minority students produces those results is standardless. The systems fail to articulate a meaningful connection between the means they employ and those goals; they use racial categories that are overbroad, arbitrary or undefined, or underinclusive.The systems also use race as a “negative” and employ stereotypes. College admissions are zero-sum. A benefit provided to some applicants is necessarily at the expense of others. The systems employ “the offensive and demeaning assumption" that students of a particular race think alike. The systems lack a “logical endpoint. View "Students for Fair Admissions, Inc. v. President and Fellows of Harvard College" on Justia Law

The Supreme Court held that absolute immunity attaches to statements made in judicial or quasi-judicial proceedings and that while Jane Doe was not entitled to absolute immunity, a qualified privilege is appropriate for alleged victims of sexual assault presented in the context of this case.In disciplinary proceedings conducted at Yale University by the University-Wide Committee on Sexual Misconduct (UWC) Doe accused Plaintiff of sexual assault, resulting in Plaintiff's expulsion from Yale and criminal charges being brought against him. Plaintiff was acquitted. At issue in this appeal was whether Doe, who enjoyed absolute immunity in a subsequent civil action challenging her testimony given during Plaintiff's criminal proceeding, should likewise be afforded absolute immunity from suit for her statements made during the UWC proceeding. The Supreme Court held (1) absolute immunity attaches to statements in judicial or quasi-judicial proceedings; (2) the USC's proceeding did not meet the conditions necessary to be considered quasi-judicial, and therefore, Doe was not entitled to absolute immunity; but (3) due to the public interest in encouraging the proper reporting of sexual assaults a qualified privilege is appropriate for alleged victims of sexual assault at institutions of higher education. View "Khan v. Yale University" on Justia Law

Plaintiff sued the Austin Independent School District (“AISD”) on behalf of her minor son, A.H., alleging that AISD violated Section 504 of the Rehabilitation Act of 1973, the Americans with Disabilities Act (“ADA”), and 42 U.S.C. Section 1983by employing an individual assigned to help A.H. accommodate his disabilities, but who instead verbally harassed him and threw a trash can at him, hitting him and causing injury. After the incident, the parties settled all of A.H.’s Individuals with Disabilities Education Act (“IDEA”) claims outside of court but agreed that Plaintiff still had the right to file a separate action containing A.H.’s claims arising under Section 504, the ADA, and Section 1983. Heston then brought these claims in a suit filed in 2018. The district court dismissed the suit without prejudice for Plaintiff’s failure to exhaust the Individuals with Disabilities Education Act’s (“IDEA”) administrative remedies.   The Fifth Circuit vacated the district court’s judgment and remanded it to the district court for further consideration in light of Luna Perez v. Sturgis Pub. Schs., 143 S. Ct. 859 (2023). Since Plaintiff appealed and the Parties’ briefed the case, the Supreme Court decided Luna Perez, concluding that the IDEA does not require administrative exhaustion “where a plaintiff brings a suit under another federal law for compensatory damages.” This constitutes a “modification in controlling legal principles . . . rendering a previous determination inconsistent with the prevailing doctrine.” View "Heston v. Austin Indep" on Justia Law

Appellants in these tandem appeals are each a parent of a disabled child. Arguing that his or her child was entitled to benefits under the Individuals with Disabilities Education Act (“IDEA”), 20 U.S.C. Section 1415(i), each parent brought an administrative action against his or her local education agency and prevailed. Subsequently, each parent brought a federal action for attorneys’ fees pursuant to 20 U.S.C. Section 1415(i)(3)(B). In each case, the district court awarded less attorneys’ fees than the parent requested, and the parents appealed.   The Second Circuit reversed the district court’s denial of travel-related fees in No. 21-1961 and remanded for further proceedings. The court otherwise affirmed the judgments of the district courts. The court found that it was persuaded that there was no abuse of discretion in the district court’s calculation of reasonable attorneys’ fees in each case. Further, the court wrote that the district courts that declined to award prejudgment interest did not abuse their discretion because “delays in payment” may be remedied by “application of current rather than historic hourly rates.” However, the court held that the district court abused its discretion when it denied any travel-related fees to M.D.’s counsel. A district court may permissibly adjust excessive travel costs. But the district court could not “eliminate all of the hours submitted by [CLF] as travel time” by denying travel-related fees altogether. View "H.C. v. NYC DOE, et al." on Justia Law