Justia Education Law Opinion Summaries

Articles Posted in Supreme Court of Mississippi
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The case revolves around two Senate Bills—2780 and 3064—passed by the Mississippi Legislature in 2022. Senate Bill 2780 established the Independent Schools Infrastructure Grant Program (ISIGP), which allowed independent schools to apply for reimbursable grants for infrastructure projects funded by the Coronavirus State Fiscal Recovery Funds under the federal American Rescue Plan Act (ARPA). Senate Bill 3064 allocated $10 million from the Coronavirus State Fiscal Recovery Fund to ISIGP. Parents for Public Schools (PPS), a nonprofit organization advocating for public schools, filed a complaint alleging that ISIGP violated the Mississippi Constitution by appropriating public funds to private schools. PPS sought injunctive and declaratory relief, asserting associational standing on behalf of its members.The Chancery Court of Hinds County found that PPS had established associational standing. It also found that Senate Bills 2780 and 3064 violated the Mississippi Constitution by appropriating public funds to private schools. The court denied a motion to intervene by the Midsouth Association of Independent Schools (MAIS), which sought to challenge the constitutionality of the relevant section of the Mississippi Constitution under the First and Fourteenth Amendments.The Supreme Court of Mississippi, however, found that PPS lacked standing to bring the lawsuit. The court determined that PPS failed to demonstrate an adverse impact different from that of the general public. The court noted that the funds at issue were federal, not state, funds earmarked for specific infrastructure needs, and were not commingled with state funds. The court also found that PPS's challenge to general government spending was too attenuated to bestow standing. As a result, the court vacated the judgment of the Hinds County Chancery Court and rendered judgment dismissing PPS's complaint. View "Midsouth Association of Independent Schools v. Parents for Public Schools" on Justia Law

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The Supreme Court of Mississippi examined whether a school district was entitled to funds recovered by a county from the bankruptcy proceedings of a delinquent taxpayer. The taxes, if collected normally, would have been used to fund the school district. However, the county board of supervisors had anticipated the delinquency and adjusted the levy of ad valorem taxes to compensate, ensuring the school district did not experience a shortfall. The school district argued it was entitled to its original portion of the recovered bankruptcy funds, but the county claimed that this would result in a double recovery outside the statutory scheme for public school funding. The Supreme Court of Mississippi found in favor of the county, ruling that the recovery of delinquent taxes through bankruptcy proceedings is outside the statutory funding scheme for public school districts in Mississippi. The court found that the school district was not entitled to receive delinquent taxes recovered years later in bankruptcy proceedings and reversed and remanded the lower court's award to the school district. View "Clarke County, Mississippi v. Quitman School District" on Justia Law

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Jackson Federation of Teachers (JFT) filed a complaint against the Jackson Public School District (JPS), alleging alleged that certain JPS policies violated the free speech rights of its employees. The trial court: (1) denied JPS’s motion to dismiss for lack of standing; (2) denied JPS’s motion to dismiss for mootness; (3) found that JPS’s three policies were in violation of article 3, section 11, and article 3, section 13, of the Mississippi Constitution; and (4) issued a permanent injunction enjoining JPS from enforcing the policies. JPS timely appealed. Because JFT failed to establish standing, the Mississippi Supreme Court reversed the trial court’s decision and rendered judgment in favor of JPS. View "Jackson Public School District v. Jackson Federation of Teachers, et al." on Justia Law

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Jones County School District (JCSD) alleged Covington County School District (CCSD), the custodial district, failed to share sixteenth-section income as required by statute for a period of eighteen years or more. JCSD requested, among other things, an accounting going back to 1997. The chancellor ultimately ordered what JCSD called a “partial” accounting, lacking some requested details and going back only to 2003, when the two districts began exchanging lists of educable students as required by statute. JCSD then petitioned the Mississippi Supreme Court for permission to file an interlocutory appeal, which the Court granted. JCSD contended on appeal that certain statutes prescribing time periods relating to the distribution of sixteenth-section incomes were statutes of limitation, which the Mississippi Constitution prohibited from being enforced against political subdivisions of the State. This appeal also presented questions of statutory interpretation regarding how income from shared townships is to be managed. The Supreme Court concluded that the statute conditioning the annual payment of sixteenth-section funds on the exchanging of lists of educable children was a constitutional exercise of the Legislature’s authority to decide the method and procedure for allocating funds. The statute giving the noncustodial district one year to contest the sufficiency of the payments (in those years in which lists of educable students were exchanged) was likewise not a statute of limitations. The Court recognized there might still be a need for an accounting, as the custodial district is required to pay a pro-rata share of the interest derived from the principal fund associated with each of the sixteenth-section lands to the noncustodial district on an annual basis. "Maintenance of the principal fund is potentially subject to an action in equity for an accounting." The Court vacated the chancery court's accounting order and remanded for that court to consider a new claim for accounting, if JCSD pursues one, in light of the Supreme Court's holding here. View "Jones County School District v. Covington County School District, et al." on Justia Law

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Two Mississippi school districts disputed whether the disbursement of past revenues generated from sixteenth section land located in townships shared by the two school districts and received by one, should have been shared by the other. The Mississippi Supreme Court found that the applicable governing statutes placed the burden on the noncustodial school district to provide student lists to the custodial school district, and made it unlawful for the custodial school district to pay over “until the lists . . . have been made.” Because the one-year period delineated in Section 29-3-119(4) did not place a time limit on litigation but rather a time limit on when a noncustodial district could make a claim with a custodial district, it was not a statute of limitations. Commensurate with its duty to presume the validity of legislative enactments, the Supreme Court reversed the judgment of the trial court and render judgment in favor of the custodial district, Wayne County School District, because Quitman School District’s claims were outside the prescribed time limit in the statute. View "Wayne County School District v. Quitman School District" on Justia Law

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In September 2016, Christopher Strickland, Jr., a sophomore at Northwest Rankin High School, was at Choctaw Trails in Clinton, Mississippi, preparing to run a cross- country meet. Before the race, a wasp stung Christopher on the top of his head. According to Christopher, a lump began to form and his head felt tight, like it was swelling. Christopher told one of his coaches. According to affidavits submitted by the Rankin County School District (RCSD), two coaches and a registered nurse, who was there to watch her son race, examined Christopher’s head and found no evidence of a sting or adverse reaction. And Christopher assured them he was fine and wanted to run the race. But Christopher recalled only one coach examining him. And this coach told him to “man up” and run the race. Christopher ran the race. According to one of his coaches, she checked in on him at the mile marker. He responded that he was “okay, just hot.” According to Christopher, after the mile marker he began to feel dizzy. Then he fell, hitting his head. The same nurse attended to him. So did her husband, who was a neurologist. Christopher appeared to recover and rejoined his team after the race. But he later went to a doctor, who discovered injuries to his brain and spine. In January 2017, Christopher’s father, Christopher Strickland, Sr. (Strickland), sued RCSD on Christopher’s behalf. He alleged various breaches of duties in how RCSD employees acted both (1) after the wasp sting but before the race and (2) after Christopher’s fall. Specifically, Strickland alleged that, after the fall, RCSD employees failed to follow the district’s concussion protocol. The Mississippi Supreme Court surmised "much legal analysis has been aimed at whether the actions of two cross-country coaches were discretionary policy decisions entitled to immunity from suit under Mississippi Code Section 11-46-9(1)(d) (Rev. 2019)." But on certiorari review, the Court found this question to be moot: the alleged actions of the coaches do not establish any triable claim for negligence. For that reason, the Supreme Court affirmed the trial court’s grant of summary judgment to the Rankin County School District. View "Strickland v. Rankin County School District" on Justia Law

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Dr. Sandra Leal appealed a circuit court's grant of summary judgment to the University of Southern Mississippi (USM) and the Board of Trustees of the State Institutions of Higher Learning (IHL). Leal brought suit against USM and the IHL for breach of contract and disability discrimination. Dr. Sandra Leal was a junior faculty member at USM. After spending several years at USM, Leal applied for tenure and promotion in 2012, but, at the recommendation of faculty members, she deferred her application for one year. In September of 2013, she resubmitted her application and materials. On October 4, 2013, her department voted not to recommend her application. Leal was notified of this on October 7, 2013. Each review of her application cited an insufficient number of publications as the primary reason for not recommending Leal’s application. Following these reviews, in March of 2014, Leal wrote to USM’s then-provost. Leal had suffered from rheumatoid arthritis throughout her time at USM, but, for the first time, she claimed it as a disability. She requested an additional year to remedy her insufficient number of publications. Both the provost and USM’s president recommended that Leal’s application be denied. Leal was notified of these determinations on March 24, 2014, and April 30, 2014, respectively. Leal sought review of her application by the IHL, and the IHL considered her request and ultimately rejected her application too. Because Leal has failed to demonstrate any genuine issue of material fact and failed to demonstrate that USM and the IHL were not entitled to judgment as a matter of law, the Mississippi Supreme Court affirmed summary judgment. View "Leal v. University of So. Miss." on Justia Law

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Poplarville School District and Pearl River County sought to undo the July 1, 2018 consolidation of the Lumberton Public School District and the Lamar County School District. In 2016, the Mississippi Legislature adopted Senate Bill 2500, which, after being signed into law, was codified as Mississippi Code Section 37-7-104.5, the purpose of which was to administratively dissolve, consolidate, and split the Lumberton Public School District at the Lamar and Pearl River County line. The statute created the Commission on the Administrative Consolidation of the Lumberton Public Schools to work in conjunction with the Mississippi State Board of Education to accomplish the consolidation goal. However, Poplarville School District contended that instead of following the directive of Section 37-7-104.5, the Commission dissolved the Lumberton School District and consolidated all of it, to include the students who reside in Pearl River County, into the Lamar County School District. The Mississippi Supreme Court determined the Pearl River County Board of Supervisors was a “person aggrieved” for purposes of Section 37-7-115, publication was not necessary pursuant to Section 37-7-115, and Section 37-7-115 was an exclusive remedy. Furthermore, the Court held the chancery court did not err by finding that the appeal was untimely filed pursuant to Section 37-7-115, and affirmed the chancery court's decision. View "Pearl River County Board of Supervisors v. Mississippi State Board of Education" on Justia Law

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Walter Jones appeals the order of the Circuit Court of Madison County affirming his removal as trustee of the Canton Public School District (CPSD) by the Board of Aldermen (the Board) of the City of Canton (the City). Jones argued the Board lacked the authority to remove him as a public official. Finding that the Board’s actions were prohibited by the Mississippi Constitution, the Mississippi Supreme Court agreed: because the Board’s authority was based on a city ordinance inconsistent with the Mississippi Constitution and because the Board’s action violated Jones’s right to due process, the Supreme Court reversed the circuit court’s decision to affirm the Board’s removal of Jones as school-board trustee. View "Jones v. City of Canton, Mississippi" on Justia Law

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In chancery court, Plaintiffs challenged the two sources of funding for charter schools provided for under the Mississippi Charter Schools Act of 2013. Plaintiffs contended the Act was unconstitutional under Article 8, Sections 206 and 208, of the Mississippi Constitution. Also, one of the charter-school intervenors maintained that Plaintiffs lacked standing to bring the suit. The chancellor held that the Plaintiffs did have standing to sue and that they did not prove that either source of funding was unconstitutional. Before the Mississippi Supreme Court, Plaintiffs concentrated their argument under Article 8, Section 206, of the Mississippi Constitution, alleging that a charter school’s ad valorem funding was unconstitutional. They did not appeal the chancellor’s ruling concerning per-pupil funds. The Jackson Public School District (JPS) maintained that the chancellor erred in denying its motion to be dismissed from the suit. After review, the Supreme Court affirmed the chancery court, agreeing Plaintiffs had standing to sue, and that they did not meet their burden to demonstrate that Section 37-28-55 was unconstitutional. The Court found JPS’s arguments concerning its motion to dismiss were waived on appeal for failure to raise the issue in a cross-appeal. View "Araujo v. Bryant" on Justia Law