Justia Education Law Opinion Summaries

Robin Ayling appealed a judgment dismissing her claims against Mary Ann Sens, M.D., UND School of Medicine employees, and the Grand Forks County State’s Attorney and Board of Commissioners relating to her son’s death. Ayling’s son, Blake, was a student at UND. He was last seen alive at an on-campus party at approximately 1:30 a.m. on March 24, 2012. He was found dead in the rail yard south of UND’s campus at approximately 6:30 a.m. to 7:00 a.m. on March 24, 2012. Dr. Sens performed the autopsy on the same day. She determined Blake was intoxicated, he had a 0.278 blood-alcohol concentration at the time of death, he died from blood loss, and his death was accidental. After learning of the autopsy results, Ayling questioned the blood-alcohol concentration because Blake reportedly did not show signs of intoxication at the party or before the party. Ayling met with Dr. Sens in April 2013, and Sens explained the autopsy report and defended her conclusions. On December 27, 2013, Ayling spoke with a forensic toxicologist who questioned Dr. Sens’ methods in performing the autopsy. The toxicologist believed Blake's urine and vitreous humor should have been tested for alcohol to corroborate the blood test. Ayling sued Dr. Sens, UND School of Medicine employees, and Grand Forks County employees in February 2017, alleging Sens failed to competently perform a medical autopsy as a part of the investigation of Blake's death. Ayling alleged the other Defendants failed to properly supervise Dr. Sens. The district court concluded Ayling’s claims against the Defendants were untimely. After reviewing the record, the North Dakota Supreme Court agreed with the district court that Ayling’s voluminous discovery requests did not relate to the statute of limitations issue and would not have created an issue of material fact supporting denial of the summary judgment motion. The court’s discovery decisions were not an abuse of discretion. View "Ayling v. Sens, et al." on Justia Law

Wanko, a naturalized U.S. citizen from Cameroon, began studying dentistry at IU in 2014 and failed two courses. IU allowed Wanko to remediate RP and retake STI. To pass the RP remediation, a student had to score at least 80% on the exam. Wanko scored 71%. IU notified Wanko she would have to repeat the whole first‐year curriculum. She was the only student in her class held back. Wanko failed to complete her repeat of STI. IU dismissed her. Wanko’s GPA was 1.965. Wanko sued (Civil Rights Act, 42 U.S.C. 2000d), claiming that similarly situated, non‐black students were promoted when she was not. In discovery, IU produced spreadsheets showing the GPA, grades, race, and gender of each student in Wanko’s class, identifying each by number. IU cited the Family Educational Rights and Privacy Act’s safeguards concerning the release of student information, 20 U.S.C. 1232g. IU’s spreadsheets showed only two students had failed both RP and STI in the 2014–2015 school year: Wanko and another black female, who successfully remediated RP, had a GPA above 2.0, and was allowed to proceed to the second‐year curriculum. Wanko moved to compel the production of actual student records, claiming the spreadsheets were unreliable. The district court overruled Wanko’s objection to the magistrate’s denial of the motion and granted IU summary judgment. The Seventh Circuit affirmed. The spreadsheets showed no student, let alone one outside of a protected class, was similarly situated to Wanko. View "Wanko v. Board of Trustees of Indiana University" on Justia Law

The Eighth Circuit affirmed the district court's dismissal of plaintiff's Missouri state-law claims for breach of contract, breach of the implied covenant of good faith and fair dealing, and fraudulent misrepresentation against St. Louis University. Plaintiff's claims stemmed from his unsuccessful attempts to receive a Ph.D from the university in mechanical and aerospace engineering in four years.The court held that the educational malpractice doctrine barred all of plaintiff's claims. In this case, all of the statements plaintiff relied on in the student catalog and handbook were aspirational in nature. The court also held that the district court did not abuse its discretion by denying plaintiff leave to amend his complaint when he did not submit a proposed amendment or include anything in his motion to indicate what an amended complaint would contain. View "Soueidan v. St. Louis University" on Justia Law

The Supreme Court held that through Senate Bill 16's (S.B. 16) additional funding of the State's "Montoy safe harbor plan," the State substantially complied with this Court's mandate from Gannon v. State, 420 P.3d 477 (Kan. 2018) (Gannon VI).In Gannon VI, the Supreme Court held that the State had resolved nearly all of the issues in this school finance appeal but that the State had not met Kan. Const. Art. 6, 6(b)'s adequacy requirement. The Supreme Court retained jurisdiction and stayed the issuance of its mandate in order to give the State ample opportunity to make the necessary financial adjustments and reach constitutional compliance. The State subsequently passed S.B. 16, which the Governor signed into law on April 6, 2019. The Supreme Court held that the State substantially complied with the Court's Gannon VI mandate through S.B. 16's financial adjustments to the safe harbor plan. The Court retained jurisdiction to ensure continued implementation of the scheduled funding. View "Gannon v. State" on Justia Law

The Second Circuit held that the district court properly deferred to the decision of the New York State Review Officer (SRO), which concluded that student W.E. was not denied a free and appropriate public education (FAPE) for the eighth grade school year and that Northwood School was not an appropriate unilateral private school placement for the ninth grade school year. Accordingly, the court affirmed the district court's November 2016 judgment and order in part.To the extent that the district court failed to accord appropriate deference to the SRO's conclusion that Northwood did not provide W.E. specially designed instruction so as to constitute an appropriate private school placement for the tenth grade school year, the court reversed in part the district court's opinion and vacated the award of tuition reimbursement to plaintiffs for that school year. The court also affirmed a July 2017 opinion and order granting the district court's grant of summary judgment and vacating the award of compensatory education for the eighth grade year. View "W.A.v. Hendrick Hudson Central School District" on Justia Law

The Fifth Circuit affirmed the district court's dismissal of plaintiff's complaint, based on subject matter jurisdiction, against the University, UT High School, and various school officials, alleging claims of racketeering and "gaslighting." Plaintiff alleged that UT High School's various policies and practices regarding grading and ranking knocked him out of the running for various scholarships and admissions into prestigious colleges, and that officials conspired to do so in order to gaslight, or cause psychological harm, to him. The court held that defendants were entitled to qualified immunity under the Eleventh Amendment, because UT High School is an instrumentality of the State of Texas that enjoys sovereign immunity. Plaintiff's claims against the remaining defendants were abandoned. View "Sissom v. University of Texas High School" on Justia Law

Following a disciplinary proceeding, Meloney Harbour’s minor son, T.D.H., was suspended from school and placed in an alternative school. The chancery court initially reversed and rendered the decision of the Tupelo Public School District Board of Trustees after finding that the deprivation of an attorney at the initial disciplinary hearing, as well as the failure to state the applicable standard of proof, violated T.D.H.’s due process rights. After a Mississippi Rule of Civil Procedure 59(a) motion, the chancery court amended its judgment to remand the case instead of rendering it. Harbour then filed a Mississippi Rule of Civil Procedure 60(b) motion and, for the first time, challenged the constitutionality of Mississippi Code Section 37-9-71. Harbour contended the statute contained an unconstitutional standard of proof: substantial evidence rather than clear and convincing evidence. Harbour did not notice the attorney general of the constitutional challenge to the statute. Finding that Harbour failed to meet her burden under Rule 60(b), the chancery court denied the motion. Harbour then appealed that ruling. Finding no reversible error, the Mississippi Supreme Court affirmed the chancery court’s denial of the Rule 60(b) motion. View "Harbour v. Tupelo Public School District" on Justia Law

The Eighth Circuit affirmed the district court's judgment in favor of the school district in an action originally alleging that plaintiff's daughter, a young student with autism and significant intellectual deficits, was not provided a free appropriate public education (FAPE) under the Individuals with Disabilities Education Act (IDEA). Plaintiff also brought additional claims for constitutional violations under 42 U.S.C. 1983, disability discrimination and retaliation under section 504 of the Rehabilitation Act, disability discrimination under Title II of the Americans with Disabilities Act (ADA), and violations of Arkansas law.The court found no clear error in the district court's factual findings and gave due weight to the hearing officer's credibility determinations, concluding that the child was not denied a FAPE. The court also held that the district court did not abuse its discretion in denying plaintiff's motions for extensions of time and her motion to accept her summary judgment response out of time. The court also held that some of plaintiff's claims were barred for failure to exhaust and that her retaliation claim based on a violation of the IDEA also failed. View "Albright v. Mountain Home School District" on Justia Law

The Ninth Circuit affirmed the district court's dismissal of a complaint brought by three male student athletes, alleging that the University discriminated against them on the basis of their sex in violation of Title IX and violated their due process rights in connection with the University's sexual misconduct proceedings.The panel held that Federal Rule of Civil Procedure 8(a), not the evidentiary presumption set forth in McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973), provides the appropriate standard for reviewing, at the pleading stage, a motion to dismiss in a Title IX case. In this case, plaintiffs failed to provide sufficient, nonconclusory allegations plausibly linking the disciplinary action to discrimination on the basis of sex. The panel also held that plaintiffs' due process claims failed because they received constitutional due process through the University's disciplinary proceedings. The panel assumed, without deciding, that the student athletes have property and liberty interests in their education, scholarships, and reputation as alleged in the complaint. The panel nonetheless held that they received notice and a meaningful opportunity to be heard. View "Austin v. University of Oregon" on Justia Law

The Supreme Court reversed the judgment of the circuit court dismissing a school board's disciplinary proceedings against S.C., a high school student, with prejudice, holding that the circuit court misapplied the governing legal standards and misinterpreted the factual record of the disciplinary proceedings.The Fairfax County School Board disciplined S.C. for nonconsensual, sexual touching of three students at school. The circuit court dismissed the disciplinary proceedings, finding that the school board's decision was arbitrary, in violation of S.C.'s due process rights. The Supreme Court reversed, holding that, applying the "intensely practical" principles of due process applicable to school disciplinary proceedings, nothing in the record suggested that the school board acted arbitrarily in violation of S.C.'s due process rights. View "Fairfax County School Board v. S.C." on Justia Law