Justia Education Law Opinion Summaries

At issue before the Pennsylvania Supreme Court in this case centered on a determination of Appellant Manheim Township School District (“School District”) that one of its students, Appellee J.S., made terroristic threats to another student through social media – outside of the school day and off school property – substantially disrupting the school environment, and leading to his expulsion. The Supreme Court granted review to consider whether the School District denied J.S. due process during the expulsion process and to consider the proper standard by which to determine whether J.S. engaged in threatening speech unprotected under the First Amendment of the United States Constitution, or created a substantial disruption of the school environment. The Court determined J.S. did not engage in unprotected speech, and did not cause a substantial disruption to the school environment. Therefore, the Court concluded that the School District improperly expelled J.S., and affirmed the order of the Commonwealth Court. View "J.S., et al. v. Manheim Twp. SD" on Justia Law

Plaintiffs-appellants, Paula and Christopher LeRoy lost their 15-year-old son, Kennedy LeRoy, to suicide two days after finishing his sophomore year at Ayala High School in Chino. The LeRoys sued the Chino Valley Unified School District, Ayala’s principal, Diana Yarboi, and its assistant principal, Carlo Purther (collectively, Respondents). The LeRoys alleged Respondents were liable for Kennedy’s suicide because of their inadequate response to his complaints of bullying by his classmates. The trial court granted summary judgment for Respondents, and the LeRoys timely appealed. After review, the Court of Appeal concluded Respondents were statutorily immune from liability and therefore affirmed the judgment. View "Leroy v. Yarboi" on Justia Law

Plaintiff Christopher McVeigh sought a declaration that defendant, the Vermont School Boards Association (VSBA), was the functional equivalent of a public agency for purposes of the Vermont Public Records Act (PRA), and therefore had to comply with plaintiff’s request for copies of its records. The civil division concluded that the VSBA was not a public agency subject to the PRA and granted summary judgment in favor of the VSBA. Finding no reversible error in that judgment, the Vermont Supreme Court affirmed. View "McVeigh v. Vermont School Boards Association" on Justia Law

“Jane Doe,” age 19, filed suit. She alleged in detail multiple acts of sexual harassment and sexual abuse, including rape, against her during several months when she was a student at a Fairfax County, Virginia middle school, and the school’s inaction to end the offensive conduct when it was ongoing. She claimed violations of Title IX of the Education Amendments of 1972 and other laws. She alleged that the defendants undoubtedly knew her identity from the extensive details included in the 40-page complaint. Nonetheless, the defendants filed motions to dismiss, arguing that the plaintiff’s failure to provide her true name had deprived the court of subject-matter jurisdiction and that this jurisdictional flaw could no longer be remedied because the statute of limitations for the federal claims had lapsed days after Doe filed her complaint. The plaintiff then disclosed her true name to the court and requested that she be allowed to proceed under a pseudonym.The district court denied the defendants’ motions, and, because the sensitive nature of the allegations warranted “the utmost level of privacy,” it allowed the action to proceed pseudonymously. The Fourth Circuit affirmed. While the plaintiff had not adhered to FRCP 10(a), which requires that the title of a complaint include the names of all parties, that failure was immaterial to the court’s subject-matter jurisdiction. View "B.R. v. F.C.S.B." on Justia Law

The plaintiff sued a school district for negligently supervising the fourth-grade teacher who molested her in 2010-2011. Before trial, the court admitted evidence that the woman had been sexually abused by someone else in 2013, reasoning that the evidence fell outside of the scope of Evidence Code sections 1106 and 7831 which regulate the admission of “the plaintiff’s sexual conduct” and that its probative value to contradict the plaintiff’s anticipated testimony attributing all of her emotional distress to the teacher’s molestation was not substantially outweighed by the danger of undue prejudice.The court of appeal dissolved a stay of proceedings and directed the trial court to either assess any prejudice flowing from the empaneled jury’s exposure to the mentioning of the 2013 incident during opening statements or begin the trial with a new jury. The term “plaintiff’s sexual conduct” in sections 1106 and 783 (and Code of Civil Procedure section 2017.220) encompasses sexual abuse to which a plaintiff has been involuntarily subjected as well as the plaintiff’s voluntary sexual conduct. Section 783 requires a trial court, after following certain procedures, to engage in a section 352 analysis identical to the one the trial court undertook. The trial court did not abuse its discretion in finding that the probative value of the subsequent sexual abuse was not outweighed by the danger of undue prejudice. View "Doe v. Superior Court" on Justia Law

For budget reasons, St. Cloud State University shut down six of its sports teams, including women's tennis and Nordic Skiing teams. Female student-athletes brought a Title IX discrimination action. 20 U.S.C. 1681(a). The district court preliminarily enjoined cutting the women's teams, concluding the University failed to comply with Title IX requirements in its allocation of athletic participation opportunities and treatment and benefits for student-athletes.The Eighth Circuit reversed in part and remanded. The court upheld findings that the University uses a tier system for dividing particular teams, offering different levels of support to each tier. The University violated Title IX by not providing equitable participation opportunities for men and women. The district court erred, however, by requiring the University to provide equitable treatment and benefits “among the tiers of support,” and by mandating steps toward eliminating the unequal distribution of “participation opportunities among the tiers” rather than analyzing the institution's programs as a whole. View "Portz v. St. Cloud State University" on Justia Law

The First Circuit affirmed the judgment of the district court approving an amended settlement agreement in this landmark Title IX case brought by a group of women student-athletes against Brown University claiming gender discrimination with respect to the funding and operation of a variety of varsity athletic programs, holding that there was no error.After a bench trial, the district court found that Brown had violated Title IX. After the First Circuit remanded the case for further proceedings, the parties consummated a settlement, which remained in effect for more than two decades. In 2020, Brown unilaterally decided to eliminate certain varsity sports and to upgrade sailing to varsity status, open to men and women. The parties then revisited the matters embodied in the court-approved settlement and jointly moved for approval of a revised settlement. The district court approved the amended settlement agreement. The First Circuit affirmed, holding that the district court properly concluded that the amended settlement agreement was fair and adequate. View "Cohen v. Walsh" on Justia Law

Mandawala attended a medical sonography program at Baptist School. After failing to graduate, Mandawala sued, alleging that he failed because the school did not staff its clinics adequately. He later added claims under education and privacy laws and that the school had failed him out of racial animus. The state judge dismissed Mandawala’s amended petition.Mandawala then sued in federal court, alleging racial and sex discrimination, fraudulent misrepresentation, breach of contract, conversion, defamation, intentional infliction of emotional distress, and violations of the First and Twenty-Sixth Amendments. He also claimed that the school’s attorney conspired with the state judge to deny him his civil rights and his right to a fair trial. Mandawala later attempted to add defendants. The district court dismissed with prejudice nearly all the claims; only Mandawala’s sex discrimination and breach-of-contract claims against Baptist School survived. The court ordered the parties to mediate. Mandawala unsuccessfully sought a writ of mandamus, demanding the replacement of the district judge. Mandawala then filed an unsuccessful recusal motion and told the court that he would not participate in mediation. The district court stayed the caseThe Third Circuit affirmed, finding no evidence of bias on the part of the district judge and noting several false statements and procedural errors made by Mandawala. The district court carefully examined Mandawala’s civil rights claims and correctly decided that they merited dismissal with prejudice. View "Mandawala v. NE Baptist Hospital" on Justia Law

School districts sought a judgment declaring that the Governor and the State of Illinois, have a constitutional obligation to provide them with the funding necessary to meet or achieve the learning standards established by the Illinois State Board of Education. Plaintiffs asked the court to enter judgment for the necessary amounts and for the court to “[r]etain jurisdiction to enforce such schedule of payments.”The appellate court and Illinois Supreme Court affirmed the dismissal of the suit. The plaintiffs abandoned their claims against the State; the Governor is not a proper defendant because he does not have authority to grant the relief requested by the plaintiffs. The plaintiffs acknowledged that an appropriation of public funds may come only from the General Assembly. This case does not involve an actual controversy between the parties as required to grant declaratory relief. View "Cahokia Unit School District No. 187 v. Pritzker" on Justia Law

In 2017, an arbitrator found that Western Illinois University violated its collective bargaining agreement with respect to layoffs. In 2018, the arbitrator entered a supplemental award, finding that the University failed to comply with the earlier award. The Illinois Educational Labor Relations Board then found that the University committed an unfair labor practice in violation of the Illinois Educational Labor Relations Act, 115 ILCS 5/14(a)(1), (8), by failing to comply with the two arbitration awards. The Act requires that public education employers arbitrate disputes arising under a collective bargaining agreement. Refusal to comply with the provisions of a binding arbitration award is an “unfair labor practice” under the Act. The appellate court vacated the Board’s decision.The Illinois Supreme Court agreed. An arbitrator in the public educational labor relations context exceeds his authority by reviewing a party’s compliance with his own award in contravention of the Act, which vests exclusive primary jurisdiction over arbitration awards with the Board. The Board may not limit the evidence it will consider in an unfair labor practice proceeding under the Act to the evidence before the arbitrator. Under the Act, arbitrators retain limited jurisdiction of the awards for the sole purpose of resolving remedial issues that may arise from the award itself. View "Western Illinois University v. Illinois Educational Labor Relations Board" on Justia Law