Justia Education Law Opinion Summaries

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

In January 2022, plaintiffs A.S. and her husband B.S. brought a claim under the Child Sexual Abuse Accountability Act (CSAAA or “Act”) against a former high school athletic coach and a school district, alleging that the coach sexually abused A.S. between 2001 and 2005 when she was a minor. At the time plaintiffs filed suit, any previously available claims for this alleged abuse was time-barred. The issue this case presented for the Colorado Supreme Court’s review was whether the CSAAA was unconstitutionally retrospective to the extent it created a new cause of action for conduct that predated the Act, and for which any previously available claims would be time-barred. The Supreme Court concluded that because the CSAAA created a new cause of action for child sexual abuse, the Act created a new obligation and attached a new disability with respect to past transactions or considerations to the extent it permitted victims to bring claims for which any available cause of action would have been time-barred. Therefore, the CSAAA amounted to unconstitutional retrospective legislation as applied to the plaintiffs’ claim under the Act. Accordingly, the Court affirmed the district court’s order granting defendants’ motions to dismiss. View "Aurora Public Schools v. A.S. & B.S." on Justia Law

The Supreme Court reversed the order of the circuit court granting a temporary restraining order (TRO) in favor of Plaintiffs in their lawsuit challenging the validity of the emergency clause in Act 237 of 2023 (the LEARNS Act), holding that the circuit court erred in granting Plaintiffs' motion for injunctive relief.After the LEARNS Act was signed into law Plaintiffs sought a TRO, asserting that they would suffer irreparable harm if Defendants continued to implement the Act despite an invalid emergency clause relating to the creation of transformation contracts. The circuit court granted the TRO until a scheduled hearing. The Supreme Court reversed and vacated the TRO, holding that Plaintiffs failed to meet their burden of providing irreparable harm. View "Ark. Dep't of Education v. Jackson" on Justia Law

In this putative class action where Students sought a refund of money from the University of Kentucky after the University switched all on-campus classes to an online format for the remainder of the spring 2020 semester, the Supreme Court affirmed the judgment of the court of appeals affirming the trial court's ruling that governmental immunity was waived and that a breach of contract claim may proceed for adjudication on the merits, holding that the Student Financial Obligation and accompanying documents were a written contract under Ky. Rev. Stat. 45A.245(1) such that governmental immunity was waived and the underlying breach of contract claims may proceed. View "University of Ky. v. Regard" on Justia Law