Justia Education Law Opinion Summaries
Articles Posted in Maryland Court of Appeals
Gambrill v. Bd. of Education of Dorchester County
The Court of Appeals reversed the judgment of the court of special appeals affirming the decision of the circuit court granting summary judgment in favor of Defendants in this case involving violent peer conflicts between adolescents in middle school, holding that the circuit court erred.Plaintiffs filed a five-count complaint against several school defendants and the Board of Education for Dorchester County, alleging violations of their daughter's state constitutional right to due process and other causes of action stemming from their daughter's bullying by other students. The circuit court granted summary judgment for Defendants, and the court of special appeals affirmed. The Court of Appeals reversed, holding (1) the Act does not preempt CJ § 5-518, and Plaintiffs' negligence claims against the individual school employees were not preempted by federal law; (2) the educational malpractice doctrine does not apply to Plaintiffs' negligent supervision claims; and (3) material disputes of fact precluded the entry of summary judgment. View "Gambrill v. Bd. of Education of Dorchester County" on Justia Law
Neal v. Baltimore City Board of School Commissioners
In this appeal concerning whether a school board was liable for a judgment against its employee when the board was dismissed from the case prior to trial the Court of Appeals held that, under Md. Cts. & Jud. Proc. 5-518, even if a board is entitled to substantive dismissal from a case the plaintiffs are required to maintain the board as a party or request that the board be brought back into the case to indemnify an employee.As a matter of trial strategy in a case against the Baltimore City Board of School Commissioners, counsel for Plaintiffs decided to not appeal the dismissal, via summary judgment, of the Board from the case and to avoid joinder of the Board under after the conclusion of the trial. After the trial, Plaintiffs filed motions to enforce the judgments, arguing that the Board was obligated to satisfy the judgments pursuant to section 5-518. The circuit court granted Plaintiffs' motions. The court of special appeals reversed. The Court of Appeals affirmed, holding that, in order to force a county school board to indemnify a judgment against a county board employee, the mandatory joinder requirement under section 5-518 requires that a county board be joined as a party throughout the entire litigation. View "Neal v. Baltimore City Board of School Commissioners" on Justia Law
Frederick Classical Charter School, Inc. v. Frederick County Board of Education
Petitioner, a charter school located in Frederick, Maryland, and Respondent, the Frederick County Board of Education (Local Board), disputed whether the Local Board’s annual funding allocation to Petitioner in its first year of operation satisfied Md. Code Ann. Educ. 9-109. Specifically, Petitioner argued that the Local Board’s decision to withhold a proportional share of transportation funds was incorrect. The State Board of Education disagreed and upheld the Local Board’s decision to withhold transportation funding from Petitioner’s annual funding allocation. The circuit court and court of special appeals upheld the State Board’s decision. The Court of Appeals reversed and remanded, holding that the State Board’s decision to deny transportation funds to Petitioner was arbitrary and capricious and an abuse of discretion. View "Frederick Classical Charter School, Inc. v. Frederick County Board of Education" on Justia Law
Pace v. State
The mother of a kindergarten student, who suffered a serious allergic reaction after consuming peanut butter given to her under her school's free lunch program, brought suit against the State and its agents (collectively, Defendants), alleging that the State's obligations under the National School Lunch Act (NSLA) imposed upon Defendants a statutory duty of care to ensure that children with food allergies are not served lunches containing allergens. The trial court granted the State Defendants' motion to dismiss, concluding that the NSLA simply establishes a subsidized lunch program to benefit children at participating schools and does not impose a specific statutory duty of care towards children with food allergies. The court of special appeals affirmed. The Supreme Court affirmed, holding that the NSLA does not impose a statutory duty on the State Defendants to exercise a greater degree of care for students with food allergies than the general level of care the State Defendants exercise for all students in public schools. Because Petitioner could not maintain a suit in negligence, the complaint was properly dismissed. View "Pace v. State" on Justia Law