Justia Education Law Opinion Summaries

Articles Posted in Massachusetts Supreme Judicial Court
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The Supreme Judicial Court vacated the decision of the Land Court judge determining that the primary purpose of Plaintiff's proposed residential program for adolescent males could not be characterized as "educational" under the Dover Amendment, Mass. Gen. Laws ch. 40A, 3, second paragraph, and therefore was not exempt from certain zoning restrictions, holding that the proposed facility and its curriculum fell within the "broad and comprehensive" meaning of "educational purposes" under the Dover Amendment. Plaintiff, The McLean Hospital Corporation, sought to develop a residential life skills program for fifteen to twenty-one year old males who exhibit extreme emotional dysregulation to allow the adolescents to lead useful, productive lives. The building commissioner determined that the proposed use was educational and that Plaintiff could proceed under the Dover Amendment and its local analog, section 6.1(i) of the town of Lincoln's bylaw. The town's zoning board of appeals reversed, determining that the program was medical or therapeutic, as opposed to education. The Land Court judge upheld the determination. The Supreme Judicial Court remanded the matter for entry of a judgment in favor of Plaintiff, holding that the fact that the curriculum of the facility is not conventional does not negate the fact that the predominant purpose of the program is educational. View "McLean Hospital Corp. v. Town of Lincoln" on Justia Law

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The Supreme Judicial Court affirmed Defendant's convictions and the order denying his motion for a new trial and further declined to reduce the verdict of murder in the first degree to a lesser degree of guilt or to set aside the convictions under Mass. Gen. Laws ch. 278, 33E, holding that there was no prejudicial error in the proceedings below. Defendant was convicted of murder in the first degree on the theories of deliberate premeditation, extreme atrocity or cruelty, and felony-murder. The Supreme Judicial Court affirmed Defendant's convictions and the order denying his motion for a new trial, holding (1) the district court did not err in denying Defendant's motion to suppress his statements to police; (2) the trial judge did not err by declining to give a humane practice instruction sua sponte or by declining to provide the jury with complete instructions on joint venture; (3) the trial judge did not err in excluding certain hearsay evidence; and (4) the judge did not err in denying Defendant an evidentiary hearing on his motion for a new trial. View "Commonwealth v. Amaral" on Justia Law

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Plaintiffs, five students who attend public schools in the city of Boston, failed to state a claim for relief in their complaint alleging that the charter school cap under Mass. Gen. Laws ch. 71, 89(i) violates the education clause and the equal protection provisions of the Massachusetts Constitution because Plaintiffs were not able to attend public charter schools of their choosing. Plaintiffs sued the Secretary of Education, the chair and members of the board of secondary and elementary education, and the Commissioner of Education seeking declaratory and injunctive relief. Defendants filed a motion to dismiss. The motion judge granted the motion, concluding that Plaintiffs failed to state a claim under either the education clause or the equal protection provisions of the Massachusetts Declaration of Rights. The Supreme Judicial Court affirmed, holding (1) Plaintiffs failed to allege facts suggesting not only that they had been deprived of an adequate education but that Defendants failed to fulfill their constitutionally prescribed duty to educate; and (2) there was no plausible set of facts that Plaintiffs could prove to support a conclusion that the charter school cap did not have a rational basis. View "Doe No. 1 v. Secretary of Education" on Justia Law

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Under the children requiring assistance (CRA) statute, a child “willfully fails to attend school” if the child’s repeated failure to attend school arises from reasons portending delinquent behavior. In this case, the Millis public schools filed a habitual truancy CRA alleging that M.P. was a child requiring assistance on the grounds that she was habitually truant. M.P. failed continually to attend school due to a combination of physical and mental disabilities, including a severe bladder condition and autism. After a hearing, the juvenile court adjudicated M.P. a child requiring assistance. The Supreme Judicial Court vacated the judgment and remanded the matter to the juvenile court for entry of an order dismissing the CRA petition, holding that the evidence in the record did not support a finding beyond a reasonable doubt that M.P. “willfully fail[ed] to attend school.” View "Millis Public Schools v. M.P." on Justia Law

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The Supreme Judicial Court affirmed Appellant’s convictions for two counts of murder in the first degree on the theories of felony murder, deliberate premeditation, and extreme atrocity or cruelty and the order denying his motion for a new trial and declined to set aside the verdicts or reduce the degree of guilt under Mass. Gen. Laws ch. 278, 33E. Defendant was convicted as a joint venturer. His coventurer was tried separately and convicted of the victims’ murders. The Supreme Judicial Court held that there was no error warranting dismissal of the indictments or reversal of the convictions. View "Commonwealth v. Rakes" on Justia Law

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A police officer, responding to a report of an unauthorized person at Milton High School, searched the defendant's backpack and discovered a firearm, money, and marijuana. The defendant unsuccessfully moved to suppress the evidence, arguing that the police officer lacked a constitutionally permissible basis for the pat-frisk and the subsequent search. He was convicted of carrying a firearm without a license, G.L. c. 269, 10(a); carrying a dangerous weapon on school grounds, 269, 10(j); possession of a firearm without a firearm identification card, 269, 10(h); disturbing a school, 272, 40; and possession of a class D substance with intent to distribute, 94C, 32C. The Massachusetts Supreme Judicial Court vacated, stating that when a police officer conducts a pat-frisk, the applicable standard for assessing its constitutionality is reasonable articulable suspicion under Terry v. Ohio and that an officer's conduct in a school setting is governed by the traditional Fourth Amendment standard. Applying the Terry standard to this case, the officer lacked reasonable articulable suspicion that the defendant had committed a crime and the circumstances of the encounter did not warrant a reasonable belief that the defendant was armed and dangerous. Nor was the search permissible under any exception to the warrant requirement. View "Commonwealth v. Villagran" on Justia Law

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Plaintiff, a high school student, was suspended from school for conduct that took place outside of school grounds. The suspension - which was mistakenly ordered on the ground that Plaintiff had been charged with a felony - lasted an entire semester, and Plaintiff was unable to graduate with her class. Plaintiff commenced this action asserting that her suspension was unlawful. The judge allowed Defendants’ motion to dismiss on the ground that Plaintiff failed to exhaust her administrative remedies under Mass. Gen. Laws ch. 72, 37H1/2 before filing her complaint. The Supreme Judicial Court reversed, holding that because the tort recovery a student may seek under Mass. Gen. Laws ch. 76, 16 provides a separate and distinct remedy from that available under section 37H1/2, Plaintiff was not obligated to exhaust the statute’s administrative remedies before pursuing a tort claim under Mass. Gen. Laws ch. 76, 16. View "Goodwin v. Lee Public Schools" on Justia Law

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At issue in this case was whether settlement agreements between a public school and the parents of a public school student who requires special education are public records subject to disclosure. Plaintiff requested from Defendant school district copies of such agreements where Defendant “limited its contribution to education funding or attached conditions for it for out of district placements” for certain school years. The school district denied the request. The superior court declared that the agreements were public records and were not exempt from disclosure. The Supreme Judicial Court vacated the judgment of the superior court and remanded, holding (1) the settlement agreements regarding placement of students in out-of-district private educational institutions are not “public records” under Mass. Gen. Laws ch. 4, 7; but (2) the settlement agreements may be redacted to remove personally identifiable information, after which they become subject to disclosure under Mass. Gen. Laws ch. 66, 10, the Massachusetts public records law. View "Champa v. Weston Public Schools" on Justia Law