Justia Education Law Opinion Summaries

The Alaska Legislature passed a bill in 2018 that appropriated money for public education spending for both FY2019, and FY2020. The second appropriation had a 2019 effective date. Governor Mike Dunleavy took office in December 2018, and disputed the constitutionality of the second year’s appropriation — and the general practice known as forward funding — asserting that it violated the annual appropriations model established by the Alaska Constitution. The Alaska Legislative Council, acting on behalf of the legislature, sued the governor, seeking a declaratory judgment that the governor violated his constitutional duties by failing to execute the appropriations and an injunction requiring him to do so. On cross-motions for summary judgment, the superior court decided that the appropriations were consistent with the legislature’s duty to fund public education, that they did not violate any specific constitutional provision, and that the governor’s refusal to disburse funds pursuant to the appropriations violated his duty to faithfully execute the laws. The court awarded attorney’s fees to the Legislative Council and the advocacy group as prevailing parties. The governor appeals the court’s grant of summary judgment and the award of attorney’s fees to the advocacy group. The Alaska Supreme Court concluded the superior court erred in its holding, and because neither the Legislative Council nor the advocacy group was prevailing party, the superior court’s attorney’s fees awards were vacated. View "Dunleavy, et al. v. Alaska Legislative Council, et al." on Justia Law

The Supreme Court dismissed this appeal from a district court's order denying injunctive relief, holding that this Court lacked jurisdiction to hear the appeal.Plaintiffs were ten students at Creighton University who brought this petition seeking to enjoin Creighton from administratively withdrawing students who did not comply with its COVID-19 vaccine policy. After a hearing, the district court denied the petitions, concluding that Plaintiffs failed to show irreparable harm or a likelihood of success on the merits. Plaintiffs appealed. The Supreme Court dismissed the appeal, holding that the court's denial of a temporary injunction was not a final order, and therefore, this Court lacked jurisdiction over the appeal. View "Ramaekers v. Creighton University" on Justia Law

On appeal, the St. Martin Parish School Board (the “School Board”) challenges the district court’s (1) exercise of remedial jurisdiction over the case, (2) denial of its motion for unitary status, and (3) imposition of additional equitable relief. The Fifth Circuit concluded that hat the district court properly retained remedial jurisdiction over the action; the court otherwised affirmed in part and reversed in part.The court explained that the district court did not clearly err in determining that the School Board failed to achieve unitary status in student assignment, faculty assignment, and the quality of education. The denial of unitary status was, therefore, not clearly erroneous. However, the court found that the district court abused its discretion in closing Catahoula Elementary School. The record demonstrates that progress has been made and progress can continue through the implementation of other reasonable, feasible, and workable remedies. Accordingly, the court reversed the closing of Catahoula Elementary School and remanded for consideration of other methods of addressing that concern. View "Borel v. Sch Bd Saint Martin Parish" on Justia Law

The First Circuit affirmed the order of the federal district court rejecting a challenge to the ruling by a Maine Department of Education hearing officer that the Falmouth School District violated the Individuals with Disabilities Act (IDEA), holding that the district court's challenged rulings were not in error.The hearing officer in this case concluded that Falmouth was required to reimburse the Does for the cost of their son's tuition at a private school because their son had been denied a free appropriate public education during the time periods in question. Falmouth brought this action under the IDEA, challenging the hearing officer's rulings. The Does answered and brought counterclaims against Falmouth under the Rehabilitation Act and Americans With Disabilities Act. The district court granted judgment to the Does and then dismissed the counterclaims. The First Circuit affirmed, holding that the district court did not err or abuse its discretion in the proceedings below. View "Falmouth School Dep't v. Doe" on Justia Law

The Seventh Circuit affirmed the judgment of the district court denying Plaintiff's request for a preliminary injunction to stop the University of Southern Indiana from imposing a three-semester suspension on the grounds that the university violated Title IX of the Education Amendments of 1972 by discriminating against him on the basis of his sex, holding that Plaintiff was not entitled to a preliminary injunction.The university's Title IX committee in this case found by a preponderance of the evidence that Plaintiff, a student of the university, had sexually assaulted another student and imposed a three-semester suspension. Plaintiff subsequently brought a complaint alleging discrimination. The district court denied Plaintiff's motion for a preliminary injunction. The Seventh Circuit affirmed, holding that the district court did not abuse its discretion in denying relief because Plaintiff did not show a likelihood of success on the merits that would support a preliminary injunction. View "Doe v. University of Southern Indiana" on Justia Law

S.S. was a student in the Cobb County School District. S.S.’s parents challenged the adequacy of the individualized educational plans. S.S.’s parents fought the school district for two years and eventually filed an administrative complaint requesting a due process hearing under the Act with the Georgia Office of State Administrative Hearings. In the administrative complaint, S.S. alleged that the school district failed to provide her with a free and appropriate public education under the Act. The school district moved for summary determination of the administrative complaint. S.S. challenged the administrative law judge’s decision in the Northern District of Georgia.The district court denied the school district’s motion for summary judgment and remanded to the administrative law judge for a due process hearing. The school district appealed the district court’s remand order.   The DC Circuit concluded that remand orders from district courts to administrative agencies for further proceedings under the Act are not final and appealable under section 1291. And because the district court’s remand order was not final and appealable, the court wrote it lacks appellate jurisdiction to review it. Accordingly, the court dismissed the school district’s appeal. View "S.S. v. Cobb County School District" on Justia Law

The First Circuit dismissed this appeal from the dismissal of a 42 U.S.C. 1983 suit filed by Plaintiffs, two college students, against Defendants, their former universities and university officials, asserting constitutional challenges to the universities' COVID-19 vaccination policies, holding that Plaintiffs' claims are moot.The policies at issue required all students either to be vaccinated or to obtain an exemption to be allowed onto campus. Plaintiffs sought declaratory and injunctive relief seeking exemptions from the policies. The district court denied relief and granted Defendants' motion to dismiss. The First Circuit dismissed Plaintiffs' ensuing appeal, holding that where one student had graduated and the other student was no longer enrolled, Plaintiffs' claims were moot. View "Harris v. University of Massachusetts, Lowell" on Justia Law

The First Circuit affirmed the order of the district court granting summary judgment dismissing Plaintiff's federal claims against Brown University and reversed the grant of summary judgment as to Plaintiff's state law claim for intentional infliction of emotional distress, holding that there were triable issues precluding summary judgment.Jane Doe, a white woman, filed a complaint against Plaintiff, an African-American man who was then a freshman at Brown University, alleging sexual misconduct. After a multi-year process leading to Plaintiff's suspension from school and his suicide attempt. A year before he graduated, Plaintiff brought this action in Rhode Island state court alleging that Brown discriminated against him and intentionally inflicted emotional distress upon him. The district court granted summary judgment for Brown. The First Circuit reversed in part, holding that Plaintiff presented evidence that would allow a jury reasonably to conclude that Brown should be held liable for the tortious conduct of its officials in intentionally causing Plaintiff severe emotional distress under Rhode Island common law. View "Doe v. Brown University" on Justia Law

The Supreme Court held that liability under the Unruh Civil Rights Act, Cal. Civ. Code 51, was not available in this case, where Plaintiff alleged that he was sexually assaulted by fellow students and a school district staff member at his high school.Plaintiff, through his guardian, sued the West Contra Costa Unified School District asserting various claims arising out of his high school experiences, including allegations that the District had violated the Act. The District demurred to the Act cause of action on the ground that the District was not a "business establishment" within the meaning of the Act. The trial court sustained the demurrer. Thereafter, Plaintiff filed an original petition for writ of mandate, which the court of appeal denied. The Supreme Court affirmed, holding that the Act, as currently written, cannot reasonably be interpreted to encompass public school districts in situations such as the one this case presented. View "Brennon B. v. Superior Court" on Justia Law

The Supreme Court affirmed the orders entered by the Fourth and Eighteenth Judicial District Courts denying their requests for preliminary injunctions to enjoin the masking requirements of Defendants, school districts in Missoula and Gallatin Counties, that were adopted in response to the continuing COVID-19 pandemic, holding that the district courts did not err.Plaintiffs filed complaints and motions for preliminary injunctions shortly after Defendants' adoption of the masking policies for the 2021-2022 school year, seeking to enjoin the masking requirements based upon constitutional privacy, individual dignity, and parental rights. Both district courts denied the motions. The Supreme Court affirmed, holding that the district courts did not manifestly abuse their discretion by denying the preliminary injunctions. View "Stand Up Montana v. Missoula County Public Schools" on Justia Law