Justia Education Law Opinion Summaries

This case arose from the tragic death of Maxwell Gruver after a fraternity hazing event at Louisiana State University (LSU). Maxwell's parents filed suit against LSU for violations of Title IX and state law, alleging that the university discriminated against male students by policing hazing in fraternities more leniently than hazing in sororities.In Pederson v. La. State Univ., 213 F.3d 858, 876 (5th Cir. 2000), the Fifth Circuit held that state recipients of Title IX funding waive their Eleventh Amendment immunity against suits alleging sex discrimination. The court held that the Supreme Court's opinion in National Federation of Independent Business v. Sebelius, 567 U.S. 519 (2012), does not constitute a change in law when it comes to the analysis that Pederson and other cases used in finding waivers of sovereign immunity from states' acceptance of federal funds. Therefore, the court held that LSU has waived Eleventh Amendment immunity by accepting federal funds and affirmed the district court's denial of the university's motion to dismiss. View "Gruver v. Louisiana Board of Supervisors" on Justia Law

The Supreme Court held that Sussex County, Kent County, and New Castle County use assessment methodologies when preparing their assessment rolls used by school districts in levying local taxes that fail to comply with three legal requirements.Plaintiffs were the NAACP Delaware State Conference of Branches (the NAACP-DE), the Delawareans for Educational Opportunity (the DEO) and the City of Wilmington. The NAACP-DE and the DEO argued that Delaware's public schools failed to provide an adequate education for students from low-income households, students whose first language is not English, and students with disabilities. When school districts levy local taxes, they are required to use the assessment rolls prepared by Delaware's three counties. The NAACP-DE and the DEO argued that when preparing their assessment rolls, the counties failed to comply with 9 Del. C. 8306(a) (the True Value Statute) and Del. Const. art. VIII, 1 (the Uniformity Clause). The City of Wilmington argued that New Castle County also violated its obligations under 22 Del. C. 1101-1104 (the Assessment Roll Statutes). The Supreme Court held (1) Plaintiffs had standing to assert their claims; and (2) all three counties used assessment methodologies that violate the True Value Statute and the Uniformity Clause and that New Castle County violated its obligations under the Assessment Roll Statutes. View "In re Delaware Public Schools Litigation" on Justia Law

MHS, a private, non-denominational school, hired the Darringtons as full-time houseparents for student housing. The Union represents full-time MHS houseparents. The collective bargaining agreement arbitration provision covers “any dispute arising out of [its] terms and conditions,” including the “discipline or discharge” of Union members. A grievance includes “any dispute alleging discrimination against any [Union members].” The Union, on behalf of itself and any allegedly aggrieved Union members, waived any right to a private lawsuit alleging employment discrimination regarding matters encompassed within the grievance procedure. If aggrieved Union members are unsatisfied with the resolution of their disputes after discussions with MHS officials, “the Union [may seek] further consideration” by submitting the grievance to arbitration on their behalf.The Darringtons filed unsuccessful reports with the local state agency for children and youth services, concerning MHS's mandatory religious programming. They then filed charges of discrimination with the EEOC and the Pennsylvania Human Relations Commission alleging discrimination based on religion. Two months later, MHS fired the Darringtons, who filed additional charges. After receiving right-to-sue letters, the Darringtons filed a complaint, alleging discrimination and retaliation, Title VII, 42 U.S.C. 2000e. The district court denied MHS’s motion to compel arbitration. The Third Circuit reversed. The CBA clearly and unmistakably waives a judicial forum for the statutory discrimination claims. View "Darrington v. Milton Hershey School" on Justia Law

The Supreme Court held that the juvenile court may exercise jurisdiction in a formal wardship proceeding on the basis of the minor having four or more truancies within one school year under Cal. Welf & Inst. Code 601(b) if a fourth truancy report has been issued to the appropriate school official, even if the minor has not been previously referred to a school attendance review board (SARB) or a similar truancy mediation program.The district court filed a wardship petition against A.N., a high school student, in the juvenile court, alleging that A.N. was a habitual truant and that she was within the jurisdiction of the juvenile court. After a hearing, the juvenile court sustained the wardship petition. A.N. appealed, arguing that the juvenile court lacked jurisdiction because, at the time the petition was filed, she had not yet appeared before a SARB and because she and her parents had not received a fourth truancy report. The court of appeals affirmed. The Supreme Court affirmed, holding that because A.N.’s school had sent at least four truancy reports to the superintendent of the school district before the wardship petition was filed, the juvenile court possessed jurisdiction over A.N. View "In re A.N." on Justia Law

The Supreme Court affirmed the judgment of the court of appeals concluding that officials of The University of North Carolina at Chapel Hill (University) are required to release, as public records, disciplinary records of its students who have been found to have violated the University's sexual assault policy, holding that the University did not have discretion to withhold the information sought.Plaintiffs, news organizations, brought this action for alleged violations of the North Carolina Public Records Act. Defendants argued that they were prohibited from complying with the Public Records Act in light of applicable provisions of the federal Family Educational Rights and Privacy Act (FERPA). The trial court determined that Defendants were not required to produce the student records requested by Plaintiffs, concluding that the doctrines of field preemption and conflict preemption operated to implicitly preempt, by force of federal law, any required disclosure by the Public Records Act of the requested records. The court of appeals reversed. The Supreme Court affirmed, holding (1) the information sought in this case was authorized by and specified in the FERPA as subject to release; and (2) therefore, as an agency of the state, the University must comply with the Public Records Act and allow Plaintiff access to the information. View "DTH Media Corp. v. Folt" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree murder and criminal discharge of a firearm, holding that Defendant's claims of trial error and challenge to his sentence were unavailing.Specifically, the Supreme Court held (1) the district court did not err in failing to give Defendant's requested jury instruction on unintentional but reckless second-degree murder as a lesser included offense of first-degree premeditated murder; (2) the district court did not err by allowing the State to introduce two out-of-court statements; (3) the district court did not err in allowing into evidence eight autopsy photos, a video, and two photos investigators took of Defendant at the time of questioning; and (4) the district court did not abuse its discretion in denying Defendant's motion for a departure sentence. View "State v. Randle" on Justia Law

The Supreme Judicial Court affirmed the order of the superior court granting Plaintiff's motion for a preliminary injunction seeking immediate reinstatement to school after she was suspended for 152 school days for possessing a small amount of marijuana and two makeshift pipes in her locker at a public high school, holding that the motion judge did not err in concluding that Plaintiff was likely to succeed on the merits of her claim.When Plaintiff appealed from her suspension to the superintendent, the district's school safety director acting as the superintendent's designee shorted the suspension to 112 school days. Plaintiff filed a complaint alleging that, by delegating the appeal to the school safety director, Defendants failed to comply with the procedure for appealing from the expulsion set forth in Mass. Gen. Laws ch. 71, 37H(d). Plaintiff also filed an emergency motion for a preliminary injunction. The motion judge granted the preliminary injunction and reinstated Plaintiff to her high school. The Supreme Judicial Court affirmed, holding that because the principal initially imposed a suspension of 152 school days, Plaintiff was entitled under section 37H to appeal from her exclusion directly to the superintendent, not a designee of the superintendent. View "Doe v. Worcester Public Schools" on Justia Law

The Eighth Circuit affirmed the district court's grant of the school district's motion to dismiss in part and motion for summary judgment in an action brought under section 504 of the Rehabilitation Act, the Individuals with Disabilities Education Act (IDEA), and Title II of the Americans with Disabilities Act.The court held that the district court did not err in dismissing plaintiffs' request for attorneys' fees as time barred by the 90-day statute of limitations in Arkansas Code section 6-41-216(g), Arkansas's statutory framework for IDEA compliance. The court explained that the claim for attorneys' fees is ancillary to judicial review of the administrative decision. The court also held that the district court did not err by granting summary judgment to the school district where there is no genuine issue of material fact about whether the school district acted in bad faith or with gross misjudgment with respect to plaintiffs' claim that their son was the victim of peer and teacher bullying. View "Richardson v. Omaha School District" on Justia Law

Marion Carter sued the Pulaski County Special School District for race discrimination under Arkansas state and federal laws. Carter taught at the Joe T. Robinson High School in the School District. She also coached the cheer and dance teams. In 2017, the school's principal recommended to the District Superintendent that Carter's cheer and dance duties not be renewed for the 2017-2018 school year, and that she be offered a teaching contract only. The principal cited: (1) lack of student participation in cheer and dance in the previous two years; (2) inappropriate cheer routines at sporting events; and (2) inappropriate behavior of cheerleaders during out-of-town travel. After a hearing, the District's School Board accepted the recommendation not to renew Carter's cheer and dance contract. The District filled the cheer position with an African-American woman, and eliminated all dance teams district-wide. The Eighth Circuit concurred with the district court's grant of summary judgment to the District on all claims. The Court found Carter's allegations were insufficient to defeat summary judgment. View "Carter v. Pulaski CO Special School Dist" on Justia Law

Students at several of Detroit’s worst-performing public schools were subject to poor conditions within their classrooms, missing or unqualified teachers, physically dangerous facilities, and inadequate books and materials. In 2016, the plaintiffs filed suit under 42 U.S.C. 1983, claiming that these conditions deprive them of a basic minimum education that provides a chance at foundational literacy, in violation of the due process and equal protection clauses. They sought recognition of a fundamental right to a basic education. They argued that the schools they are forced to attend are schools in name only, so the state cannot justify the restriction on their liberty imposed by compulsory attendance. They sued state officials, rather than local entities, based on the state’s general supervision of all public education and the state’s specific interventions in Detroit’s public schools. The state argued that it recently returned control to local officials. The district court found that the state defendants were the proper parties to sue but dismissed the complaint on the merits.The Sixth Circuit reversed in part. Though the plaintiffs failed to adequately plead their equal protection and compulsory attendance claims, the court reinstated claims that they have been denied a basic minimum education, and have been deprived of access to literacy. Application of the principles in the Supreme Court’s education cases to a substantive due process framework demonstrates that a basic minimum education should be recognized as a fundamental right. View "Gary B. v. Whitmer" on Justia Law