Justia Education Law Opinion Summaries

The Supreme Court reversed the judgment of the Appellate Court reversing the judgment of the trial court after concluding that expert testimony was necessary to establish the standard of care in this negligence action, holding that, under the facts of this case, expert testimony was not necessary.Plaintiffs, a minor child, by and through her mother, alleged that the City of Waterbury and the Waterbury Board of Education were negligent for injuries sustained by the child during recess at a Waterbury public school. The trial court rendered judgment in favor of Plaintiffs. The Appellate Court reversed, concluding that the trial court improperly found in the absence of expert testimony that Defendants breached their duty of care to the child on the basis that there was an inadequate number of adults on the playground to supervise the students at the time the child was injured. The Supreme Court reversed, holding that the fact finder here did not need to apply scientific or specialized knowledge to determine whether Defendants adequately supervised the children in this case. View "Osborn v. Waterbury" on Justia Law

The Supreme Court affirmed the decision of the circuit court reversing the decision of the state agency that oversees law-enforcement training refusing a state university's application seeking authorization to establish and operate a new law enforcement training academy for senior university students majoring in criminal justice studies, holding that the circuit court did not err.In denying the university's application to create a new law enforcement training academy the state agency concluded that the university's proposed academy was not necessary. The circuit court reversed the state agency's decision and ordered that the agency approve the university's application, finding that the agency's decision was arbitrary, capricious, and unsupported by law. The Supreme Court affirmed, holding that the agency's decision to deny the university's application to establish and operate an entry-level law enforcement training academy was arbitrary, capricious, and not supported by any statutory authority. View "Division of Justice & Community Service v. Fairmont State University" on Justia Law

The First Circuit reversed the judgment of the district court granting a preliminary injunction prohibiting the Trustees of Boston College (BC) from imposing a suspension of one year on John Doe, a student, who was found to have engaged in the sexual assault of a female student, holding that the district court erred in finding a probability of success as to Doe's claim under Massachusetts contract law.The suspension decision in this case was the outcome of a disciplinary complaint filed against Doe, and the suspension decision was the outcome of the procedures set forth in BC's student sexual misconduct policy. In issuing the preliminary injunction the district court found Doe had shown a probability of success on the merits of the state law claim of violation of a contractual obligation of basic fairness. The First Circuit vacated the injunction, holding (1) to the extent the district court was attempting to base its ruling on a prediction of future developments in Massachusetts contract law, the court erred; and (2) where current Massachusetts law does not require the college discipline process Doe argues must be a part of a contractual obligation of basic fairness the court erred in granting the injunction. View "Doe v. Trustees of Boston College" on Justia Law

Amanda M. (“Parent”), the mother of Nathan M., a child with autism, challenged an Individualized Education Program (“IEP”) developed with Harrison School District No. 2 (“the District”) that proposed removing Nathan from Alpine Autism Center (a private, autism-only facility) and placing him in Otero Elementary School (a public school). Nathan’s mother contended the school district did not comply with numerous procedural requirements in developing the IEP and that the IEP itself failed to offer Nathan a “free appropriate public education” as required by the Act. The Tenth Circuit determined that because the IEP at issue governed a schoolyear that has passed, and because the various IEP deficiencies alleged by Parent were not capable of repetition yet evading review, the case was moot. View "Nathan M. v. Harrison School District No. 2" on Justia Law

The question of whether all speech over the microphone was government speech is a heavily fact-intensive one that looks at the history of the government's use of the medium for communicative purposes, the implication of government endorsement of messages carried over that medium, and the degree of government control over those messages. After FHSAA denied access to a loudspeaker for a proposed religious speech before a high school football game, Cambridge Christian filed suit alleging claims arising under the Free Speech and Free Exercise Clauses of the United States and Florida Constitutions. The district court dismissed the complaint for failure to state a claim.The Eleventh Circuit held that Cambridge Christian's claims for relief under the Free Speech and Free Exercise Clauses have been adequately and plausibly pled. In this case, the history factor weighed against finding government speech and the control factor was indeterminate. Therefore, based on the limited record, the court found that it was plausible that the multitude of messages delivered over the loudspeaker should be viewed as private, not government, speech. While the court agreed with the district court that the loudspeaker was a nonpublic forum, the court held that Cambridge Christian has plausibly alleged that it was arbitrarily and haphazardly denied access to the forum in violation of the First Amendment. The court also could not say that in denying communal prayer over the loudspeaker, the FHSAA did not infringe on Cambridge Christian's free exercise of religion. Accordingly, the court reversed the district court's decision in part.The court affirmed the district court's decision holding that Cambridge Christian failed to plead a substantial burden under the Florida Religious Free Restoration Act (FRFRA) because it has not alleged that the FHSAA forbade it from engaging in conduct that its religion mandates. The court also affirmed the district court's decision insofar as it rejected Cambridge Christian's request for declaratory relief under the Establishment Clauses. View "Cambridge Christian School, Inc. v. Florida High School Athletic Assoc., Inc." on Justia Law

D.T.’s parents, concerned that their son, who has autism, was not getting an appropriate education in the Tennessee schools, removed him from public school and placed him in a private therapy program, where he improved. They were convicted of truancy. To avoid further prosecution. they enrolled D.T. in a state-approved private school and a private therapy program. To have the option of removing him from school again in the future, they sought a preliminary injunction to keep the state from charging them with truancy. They argued they had the right to remove D.T. from school because federal disability law preempts state educational requirements. The district court found that D.T.’s parents had not yet suffered an immediate and irreparable injury. The Third Circuit affirmed the denial of relief. The hypothetical threat of prosecution is not an “immediate,” “irreparable” injury that warrants the “extraordinary remedy” of a preliminary injunction. View "D.T. v. Sumner County Schools" on Justia Law

The Supreme Court affirmed the judgment of the district court declining to modify a restriction on alienability of paintings painted by artist Grant Wood and donated in 1976 to Coe College in Cedar Rapids, holding that the 1976 gift was restricted.A foundation donated the paintings to the college, and the gift letter stated that "this would be their permanent home, hanging on the walls of Stewart Memorial Library." While the college traditionally treated the paintings on its books as an unrestricted gift that could be sold or otherwise alienated, in 2016, an auditor determined the paintings should be treated as a restricted gift. The college subsequently filed a petition seeking a judicial interpretation of the gift's terms. The district court ruled that there existed a restriction on the alienability of the paintings and declined to modify the restriction. The Supreme Court affirmed, holding (1) the language in the gift letter did restrict the gift; (2) the Uniform Prudent Management of Institutional Funds Act does not apply; and (3) it was premature to consider the application of the common law doctrine of cy pres because there was no showing the gift restrictions cannot be carried out at present. View "In re Application of Coe College for Interpretation of Purported Gift Restrictions v. Coe College" on Justia Law

Parents, students, taxpayers, and community organizations filed suit alleging that the school district adopted and implemented a district-wide disciplinary program that was biased toward minority students, students who speak limited English, and others similarly situated. This case arose from information released to the public regarding suspensions, transfers, and other disciplinary proceedings in the school district that allegedly demonstrated that racial bias affected how the school district disciplined minority students, and actions taken by the school district to actively hide this fact from the public.The Court of Appeal affirmed the trial court's dismissal of most of plaintiffs' claims against the state level defendants, either because the claims did not state a cause of action or such claims may be brought against the local level defendants but not the state level defendants. The court held, however, that plaintiffs have stated a cause of action for disparate impact under California's equal protection clause and they have properly petitioned for a writ of mandate based on the state level defendants' ministerial duty to monitor the practices of local school districts for violations of federal law. Therefore, the court held that the trial court wrongly sustained the state-level defendants' demurrer on those claims, along with plaintiffs' request for declaratory relief on the same issues. The court also held that plaintiffs' complaint contained sufficient allegations to demonstrate associational standing for one of the community organizations to pursue these claims against the state level defendants. View "Collins v. Thurmond" on Justia Law

After M.L. was dismissed from the cheerleading squad when her coaches discovered her Twitter posts contained profanity and sexual innuendo, her mother filed suit against defendants under 42 U.S.C. 1983, alleging violation of M.L.'s rights to free speech, due process, and equal protection. The district court held that the individual defendants were entitled to qualified immunity and dismissed M.L.'s complaint for failure to state a claim.The Fifth Circuit affirmed, holding that no clearly established law placed the constitutionality of defendants' conduct beyond debate at the time of M.L.'s dismissal from the team. The court held that nothing in its precedent allows a school to discipline nonthreatening off campus speech simply because an administrator considers it offensive, harassing, or disruptive; it is indisputable that non-threatening student expression is entitled to First Amendment protection, even though the extent of that protection may be diminished if the speech is composed by a student on campus, or purposefully brought onto a school campus; and as a general rule, speech that the speaker does not intend to reach the school community remains outside the reach of school officials. In this case, the court held that no clearly established law placed M.L.'s right's beyond debate at the time of the sanction, particularly given the unique extracurricular context. The court also affirmed the district court's dismissal of the claims for municipal liability, vagueness, and overbreadth, because M.L. failed to plead facts that would entitle her to relief. View "Longoria v. San Benito Independent Consolidated School District" on Justia Law

The Supreme Court affirmed the opinion of the court of appeals insofar as it vacated the trial court's judgment convicting Defendant of tampering of physical evidence but reversed insofar as the court reversed Defendant's other convictions, holding that there was insufficient evidence to convict Defendant of tampering with physical evidence.Defendant, while in the presence of a police officer, dropped or tossed physical evidence of a possessory crime. Defendant was subsequently convicted of first-degree possession of a controlled substance, possession of drug paraphernalia, and tampering with physical evidence. The court of appeals reversed, holding that there was insufficient evidence to support all three crimes. The Supreme Court reversed in part, holding that the trial court (1) did not err in denying Defendant's motion for a directed verdict on the possession charges; but (2) erred in denying Defendant's motion for a directed verdict with respect to the tampering with physical evidence charge. View "Commonwealth v. James" on Justia Law