Justia Education Law Opinion Summaries

The Supreme Court affirmed the judgment of the trial court dismissing the appeal brought by the Board of Education of the City of New Haven after a human rights referee concluded that the Board had discriminated against a student on the basis of his disabilities and awarding damages of $25,000, holding that the Board was not entitled to relief on its claims of error.Specifically, the Supreme Court held (1) the trial court did not err in determining that the Commission on Human Rights and Opportunities had subject matter jurisdiction to adjudicate the student's claim that the Board had violated the Americans with Disabilities Act, 42 U.S.C. 12101 et seq.; (2) the trial court properly concluded that the Commission had subject matter jurisdiction over the student's claims when his father failed to exhaust his administrative remedies pursuant to the Individuals with Disabilities Education Act, 20 U.S.C. 1400 et seq.; and (3) the Board's third claim was not reviewable on appeal. View "Board of Education v. Commission on Human Rights & Opportunities" on Justia Law

The First Circuit affirmed the rulings of the district court in this civil action brought under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq., holding that none of the parties were entitled to relief on their claims brought on appeal and cross-appeal.Plaintiffs filed an administrative complaint alleging that the Newton Public Schools violated the IDEA by failing to provide their son David with a free appropriate public education, 20 U.S.C. 1412(a)(1). The Massachusetts Bureau of Special Education Appeals rejected the complaint. Thereafter, Plaintiffs brought this complaint. The district court granted judgment for Plaintiffs and ordered Newton to reimburse them for expenses they had incurred in placing their son at a private residential school in Connecticut. Defendants appealed, challenging the court's decision to exclude boarding- and travel-related expenses from the order of reimbursement. The First Circuit affirmed, holding that none of the parties were entitled to relief on their allegations of error. View "Doe v. Newton Public Schools" on Justia Law

The Supreme Judicial Court affirmed the decision of the Massachusetts Interscholastic Athletic Association (MIAA) declaring a high school senior ineligible to play a fifth year of interscholastic football and basketball and denying his request for an exception, holding that the MIAA's determination was not arbitrary and capricious.Plaintiff, a high school senior who had repeated his junior year and had played a total of four prior years on the interscholastic teams of his high schools, and his school brought this action requesting injunctive relief enjoining the MIAA from enforcing its decision declaring Plaintiff ineligible to participate in interscholastic high school sports for a fifth academic year. The superior court allowed the motion for preliminary injunction, concluding that the MIAA acted arbitrarily and capriciously in rejecting Plaintiff's application for a waiver. The Supreme Judicial Court vacated the order and remanded the matter to the superior court, holding (1) a reviewing court should examine a challenge to an MIAA eligibility determination only to determine whether the decision was arbitrary and capricious; and (2) the MIAA's decision in this case was not arbitrary and capricious. View "Abner A. v. Mass. Interscholastic Athletic Ass'n" on Justia Law

The Fellowship of Christian Athletes (“FCA”) requires students serving in leadership roles to abide by a Statement of Faith, which includes the belief that sexual relations should be limited within the context of a marriage between a man and a woman. The San Jose Unified School District (the “School District”) revoked FCA’s status as an official student club at its high schools, claiming that FCA’s religious pledge requirement violated the School District’s non-discrimination policy.   The Ninth Circuit reversed the district court’s denial of a motion for a preliminary injunction sought by a derecognized student club, the Fellowship of Christian Athletes, and directed the district court to enter an order reinstating the Fellowship as a student club within the San Jose Unified School District.   The panel first held that FCA National had direct organizational standing and Pioneer High School FCA had representational organizational standing to seek prospective injunctive relief. The School District’s denial of Associated Student Body (“ASB”) recognition hampered FCA National’s ability to further student engagement with the Christian faith and required it to expend significant time and resources to assist its student members.   Addressing the merits, the panel first held that Plaintiffs’ motion for a preliminary injunction sought to maintain the status quo that existed before the School District’s novel scrutiny of FCA—a prohibitory injunction—so the district court erred in applying the heightened standard for mandatory injunctions. The panel held that Plaintiffs would likely prevail on the merits of its selective enforcement claim under the Free Exercise Clause. View "FELLOWSHIP OF CHRISTIAN ATHLET V. SAN JOSE UNIFIED SCHOOL DISTRI" on Justia Law

The Court of Appeals reversed the judgment of the court of special appeals affirming the decision of the circuit court granting summary judgment in favor of Defendants in this case involving violent peer conflicts between adolescents in middle school, holding that the circuit court erred.Plaintiffs filed a five-count complaint against several school defendants and the Board of Education for Dorchester County, alleging violations of their daughter's state constitutional right to due process and other causes of action stemming from their daughter's bullying by other students. The circuit court granted summary judgment for Defendants, and the court of special appeals affirmed. The Court of Appeals reversed, holding (1) the Act does not preempt CJ § 5-518, and Plaintiffs' negligence claims against the individual school employees were not preempted by federal law; (2) the educational malpractice doctrine does not apply to Plaintiffs' negligent supervision claims; and (3) material disputes of fact precluded the entry of summary judgment. View "Gambrill v. Bd. of Education of Dorchester County" on Justia Law

Plaintiff, a person of color and of mixed heritage, reported to school administrators that she was harassed by her peers on the basis of her race and national origin during her sixth-grade year in the Austin Independent School District. Plaintiff alleged that she was told to "go back where [she] came from" and that, in some cases, the harassment involved physical shoving. There were also incidents in which Plaintiff responded physically to verbal threats and name-calling, resulting in the school requesting she be transferred. Through her parents, Plaintiff sued the District for failure to address the harassment under 42 U.S.C. Sec. 1983 and Title VI of the Civil Rights Act of 1964.The trial court dismissed Plaintiff's 1983 claim under Rule 12(b)(6) and ultimately granted summary judgment in favor of the district on Plaintiff's Title VI claim.While the Fifth Circuit took issue with some of the district court's findings, the Fifth Circuit concluded that the district court ultimately reached the correct result. Thus, the court affirmed the dismissal of Plaintiff's 1983 claim and the court's grant of summary judgment on the Title VI claim. View "Menzia v. Austin Indep School Dist" on Justia Law

The First Circuit vacated the judgment of the district court denying Plaintiff's motion for leave to proceed under a pseudonym, holding that the district court did not apply the appropriate standard for adjudicating such motions.Plaintiff filed suit against Massachusetts Institute of Technology (MIT) alleging breach of contract, promissory estoppel, and denial of basic fairness related to the investigation of Plaintiff for sexual harassment while he was a student at MIT. In his complaint, Plaintiff challenged the findings of the Committee on Discipline and the ensuing sanction of expulsion. On the same day he filed suit Plaintiff filed an ex parte motion to proceed by pseudonym. The district court denied the motion in a minute order. The First Circuit vacated the order, holding that the district court did not apply the appropriate standard for adjudicating motions for leave to proceed under pseudonyms, requiring remand. View "Doe v. Mass. Institute of Technology" on Justia Law

One of the California Board of Registered Nursing (the Board) regulations stated: “An approved nursing program shall not make a substantive change without prior board authorization,” which included changes such as a change in location, a change in ownership, an addition of a new campus or location, and, for certain nursing programs, a significant change in the agreement between the nursing program and the institution of higher education with which it is affiliated. Here, the Board determined that West Coast University, Inc. (West Coast) made a substantive change under the regulation when it increased its annual student enrollment from 500 to 850 over a five-year period. After West Coast sought a writ of mandate, the trial court denied each of West Coast’s claims and entered judgment in favor of the Board and its executive officer. The Court of Appeal concluded the Board could consider the change in enrollment to be a substantive change under the regulation. View "West Coast University, Inc. v. Board of Registered Nursing" on Justia Law

In a putative class action, Plaintiffs alleged that Defendants violated the Individuals with Disabilities Education Act and the Fourteenth Amendment, and they sought declaratory and injunctive relief. The Ninth Circuit affirmed in part and vacated in part the district court’s dismissal of claims brought by a group of students and parents who alleged that every school district in California failed to adequately accommodate special needs students after California public schools transitioned to remote instruction in March 2020 in response to the COVID-19 pandemic.   The panel held that Plaintiffs lacked standing to sue school districts in which they were not enrolled and the State Special Schools, which they did not attend because they did not allege that those Defendants injured them personally. The panel held that even if the “juridical link” doctrine, provides an exception to the rule that a named plaintiff who has not been harmed by a defendant is generally an inadequate and atypical class representative for purposes of Fed. R. Civ. P. 23, ever applies outside of the Rule 23 context, it would not apply here.   The panel held that the California public schools’ return to in-person instruction mooted Plaintiffs’ claims against the California Department of Education and the State Superintendent of Public Education, as well as their claims against other defendants seeking injunctions requiring a return to in-person instruction or reassessment and services until students return to in-person instruction. The panel vacated the district court’s judgment dismissing on the merits the claims that Plaintiffs lacked standing to bring and remanded with instruction to dismiss those claims for lack of subject-matter jurisdiction. View "DANIELLE MARTINEZ V. GAVIN NEWSOM" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing the judgment of the trial court affirming the findings of the Commission on State Mandates rejecting the claims brought by Plaintiffs, several community college districts seeking reimbursement for regulations they must satisfy to avoid the possibility of having their state aid withheld, holding that the court of appeals erred.Plaintiffs filed a claim arguing that reimbursement was required under Cal. Const. art. XIII B because (1) the regulations imposed a legal duty to satisfy the conditions described (legal compulsion), or (2) the regulations compelled compliance as a practical matter (practical compulsion). The Commission rejected the claims, and the trial court affirmed. The court of appeals reversed. The Supreme Court reversed, holding that because the court of appeal chose not to address whether the districts established practical compulsion, remand was required to allow the court to evaluate that issue. View "Coast Community College District v. Commission on State Mandates" on Justia Law