Justia Education Law Opinion Summaries

Articles Posted in Rhode Island Supreme Court
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The Supreme Court granted Jessica Marie Purcell's action in quo warranto seeking a determination that Clay Johnson be removed from the Chariho Regional School Committee and ordering the Town Council of the Town of Richmond to appoint Purcell to the School Committee and denied Johnson's action in quo warranto seeking a determination that he rightfully retain his membership on the School Committee, holding that Purcell was entitled to relief.On January 19, 2023, the Town Council voted to appoint Johnson to the town's vacant seat on the School Committee to serve the remainder of Gary Ligouri's term following his resignation. Purcell brought this action seeking an order removing Johnson from the Committee and requiring the Council to appoint Purcell, as prescribed by the Town's Home Rule Charter. In response, the Town and Johnson filed an emergency quo warranto petition claiming right and title to the public office pursuant to the Chariho Act. See P.L. 1958, ch. 55, as amended by P.L. 1986, ch. 286. The Supreme Court denied and dismissed Johnson's petition and granted Purcell's petition, holding that Purcell was legally entitled to the office of Chariho Regional School Committee member. View "Purcell v. Johnson" on Justia Law

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The Supreme Court affirmed the judgment of the superior court denying Defendant's motions for judgment as a matter of law and for a new trial and from the judgment in favor of Plaintiffs in this case arising from an assault by one student on another in a high school's hallway, holding that there was no error.Plaintiffs, the assaulted student and his parents, filed an amended complaint alleging that Foster-Glocester Regional School District owed a duty to the student to provide him with a safe learning environment and that the school district failed to do so. A jury found that the school district was negligent and that such negligence was a proximate cause of all three of Plaintiffs' injuries. The Supreme Court affirmed, holding that this Court will not disturb the trial justice's decisions denying the school district's motion for judgment as a matter of law and motion for a new trial. View "Dextraze v. Bernard" on Justia Law

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The Supreme Court affirmed the order of the superior court dismissing Plaintiff’s complaint for declaratory relief asserting that he had a right to access to records in the possession of the Rhode Island Department of Elementary and Secondary Education (RIDE) pursuant to the Access to Public Records Act (APRA). The motion justice found that the requested documents were not public records subject to disclosure under APRA. The Supreme Court agreed, holding that the records requested by Plaintiff were not public records for the purposes of APRA, and therefore, the motion justice properly disposed of Plaintiff’s complaint on RIDE’s motion to dismiss. View "Pontarelli v. R.I. Department of Elementary & Secondary Education" on Justia Law

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At issue in this case was the correct statutory interpretation of the manner in which state education aid funds received by the Bristol Warren Regional School District (the district) should be calculated and apportioned to the towns of Bristol and Warren. The superior court granted Warren’s petition for writ of mandamus, injunctive relief, and a complaint for summary judgment. The Supreme Court affirmed, holding that the superior court (1) did not err when it failed to bar Warren’s claims pursuant to the doctrine of res judicata; (2) did not err by declining to dismiss the action because other school districts had not been joined; (3) did not err when it did not give full deference to the Rhode Island Department of Education’s interpretation of the statutory framework concerning the proper manner of calculating and allocating state aid to regional school districts; and (4) did not misinterpret the governing statutory scheme or ignore the statutory definition of “community” as it applies to funding the district. View "Town of Warren v. Bristol Warren Regional School District" on Justia Law

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Plaintiff, an attorney employed as a hearing officer for the Rhode Island Department of Elementary and Secondary Education (RIDE), filed a complaint alleging that RIDE and the Rhode Island Board Counsel on Elementary and Secondary Education (collectively, Defendants) violated the Open Meetings Act (OMA) by failing to provide adequate notice of a September 2014 council meeting and by failing to provide any notice of meetings held by the Compensation Review Committee (CRC). The superior court entered summary judgment in favor of Defendants. The Supreme Court reversed in part and affirmed in part, holding (1) Defendants violated the OMA by failing to provide adequate notice of the September 2014 meeting; and (2) the CRC is not a public body and, therefore, is not subject to the OMA. View "Pontarelli v. Rhode Island Board Council on Elementary and Secondary Education" on Justia Law

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In a financial dispute between two charter schools and a local school district about how the local share of the charter school tuition reimbursement should be computed, the commissioner of elementary and secondary education directed that enrollment during the reference year, or 2008, be used to calculate the district's share. The board of regents reversed, interpreting the Charter Public School Act of Rhode Island to mean that the district must pay sums due to charter schools using as a computational basis the current fiscal year, or 2010. The Supreme Court upheld the board's decision, holding that the statute is subject to more than one reasonable interpretation, and the board's determination was not clearly erroneous. The Court also found that the board did not err when it affirmed the commissioner's decision to sever the district's asserted defense of unclean hands and treat it as a counterclaim.