Justia Education Law Opinion Summaries

Articles Posted in Supreme Court of Ohio
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The Supreme Court affirmed the judgment of the court of appeals dismissing this appeal of a decision of the Ohio State Board of Education, holding that the state board's final determination that a charter school must repay approximately $60 million in excess funding could not be appealed under Ohio Rev. Code Chapter 119.In 2016, the Ohio Department of Education determined that the state had overpaid the Electronic Classroom of Tomorrow (ECOT), formerly Ohio's largest charter school, approximately $60 million based on a review of the school's enrollment data. ECOT appealed under Ohio Rev. Code 3314.08(K)(2)(b), which allows a charter school to appeal such a decision to the board of education for an informal hearing. The state board confirmed the department of education's determination. At issue was whether ECOT could appeal the board of education's "final" decision where section 3314.08(K)(2)(d) provides that any decision made by the board on such an appeal is final. The Supreme Court concluded that ECOT had no right to appeal the decision under Ohio Rev. Code Chapter 119. View "Electronic Classroom of Tomorrow v. State Board of Education" on Justia Law

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The Supreme Court held that a resolution passed by the Madison Local School District Board of Education to authorize certain school district employees to carry a deadly weapon or dangerous ordnance on school property "for the welfare and safety of [its] students" did not comply with Ohio law.At issue was whether the training or experience that Ohio Rev. Code 109.78(D) required of a school employee, other than a security guard or special police officer, in which the employee goes armed while on duty, applied to teachers, administrators, and other school staff whom a board of education had authorized to carry a deadly weapon in a school safety zone. The trial court concluded that the training-or-experience requirement did not apply to teachers, administrators, and most other school employees. The court of appeals reversed, holding that the resolution violated section 109.78(D) to the extent it permitted school employees without the statutorily-required training or experience to carry a deadly weapon while on duty. The Supreme Court affirmed, holding that the resolution violated section 109.78(D). View "Gabbard v. Madison Local School District Board of Education" on Justia Law

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The Supreme Court granted a writ of mandamus ordering the Ohio Department of Education (ODE) to approve Relators' applications for Quality Community School Support (QCSS) grants and to pay them the amounts due under 2019 Am.Sub.H.B. No. 166 (H.B. 166), holding that Relators were entitled to the writ.Under the QCSS program, a community school that has met certain criteria would receive grant funding for the 2020-2021 and 2021-2011 fiscal years. Relators, twelve Horizon Science Academy community schools, had applied for QCSS grants, but ODE denied the applications, concluding that ODE was not "in good standing" as required by section 265.335 of H.B. 166. The ODE's determination was made on the grounds that the schools' operator was a foreign corporation not licensed with the Ohio secretary of state. The Supreme Court granted Relators' requested writ of mandamus, holding that ODE's interpretation of "in good standing" was incorrect. View "State ex rel. Horizon Science Academy of Lorain, Inc. v. Ohio Department of Education" on Justia Law

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The Supreme Court denied the writ of mandamus sought by Andrew Frank to compel the production of public records from the Clermont County prosecuting attorney, holding that Frank did not show that he was entitled to the writ.Frank filed this original action seeking four specific items, including a "packet of information" sent to the Ohio State University Office of Student Life/Student Conduct (OSU), damages, costs and attorney fees. The prosecutor provided the records that had been sent to OSU, thereby mooting the primary claim in Frank's mandamus complaint. In a subsequent merit brief, Frank asserted that a writ of mandamus was necessary to compel the prosecutor to produce any additional responsive records that may exist. The Supreme Court denied the writ, holding (1) Frank failed to show that the prosecutor was currently withholding responsible documents; and (2) the prosecutor did not breach any obligation under the Public Records Act, and therefore, Frank was not entitled to attorney fees, statutory damages, or court costs. View "State ex rel. Frank v. Clermont County Prosecutor" on Justia Law

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The Supreme Court affirmed the judgment of the court of appeals finding that Ohio Rev. Code 3319.321(B), a provision of the Ohio Student Privacy Act (OSPA), prohibits disclosure of records pertaining to a deceased former public-school student in response to a public-records request, holding that the OSPA unambiguously forbids disclosure of the requested records.Appellants each submitted a public-records request to the school district of Bellbrook-Sugarcreek Local Schools (the school district) requesting school records related to Connor Betts, who killed nine people in a mass shooting in Dayton. Betts was a graduate of a high school that was part of the school district. When the school district denied the requests Appellants filed this action for a writ of mandamus, arguing that they had a clear legal right to inspect Betts's records under Ohio Rev. Code 149.43(B). The court of appeals denied the writ. The Supreme Court affirmed, holding that section 3319.321(B) prohibits the disclosure of the records sought by Appellants. View "State ex rel. Cable News Network, Inc. v. Bellbrook-Sugarcreek Local Schools" on Justia Law

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The Supreme Court denied the writ of mandamus sought by Andrew Frank to compel Ohio State University (OSU) to provide documents that Frank's attorney had requested in a public-records request, holding that OSU responded promptly and fully to the attorney's request and that Frank was not entitled to a writ of mandamus.The records in question were student records containing "personally identifiable information." The parties disputed whether the Family Education Rights and Privacy Act, 20 U.S.C. 1232g, applied to the requested records. The Supreme Court denied the writ of mandamus without reaching the issue, holding that OSU responded promptly and fully to the attorney's request and, therefore, Frank was not entitled to a writ of mandamus. View "State ex rel. Frank v. Ohio State University" on Justia Law

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The Supreme Court held that 2015 Am.Sub.H.B. No. 70 (H.B. 70) does not usurp the power of city school boards in violation of Ohio Const. art. VI, 3, and the bill received sufficient consideration for purposes of Ohio Const. art. II, 15(C).The purpose of H.B. 70 was to enact new sections within Ohio Rev. Code Chapter 3302 to authorize community schools and school districts to create community learning centers at schools where academic performance was low. After the bill was signed into law, Appellants moved for a declaratory judgment and permanent injunction, arguing that H.B. 70 was unconstitutional, as was the General Assembly's legislative process in enacting it. The trial court denied the motion for preliminary injunction and declaratory judgment, and the court of appeals affirmed. The Supreme Court affirmed, holding that the enactment of H.B. 70 violated neither the three-consideration rule articulated in Article II, Section 15(C) nor the right of voters to decide the number of members and the organization of the district board of education, as guaranteed by Article VI, Section 3. View "Youngstown City School District Board of Education v. State" on Justia Law

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The Supreme Court denied a writ of prohibition sought by the Ohio High School Athletic Association (OHSAA) to prohibit Judge Robert Ruehlman from taking further action in a lawsuit filed against it in the Hamilton County Court of Common Pleas, holding that Judge Ruehlman did not patently and unambiguously lack jurisdiction.After the OHSAA adopted new rules governing postseason competitions Judge Ruehlman granted a temporary restraining order enjoining the application of the rules in cases where the high school enrolled a student who attended seventh and eighth grades at one of its traditional Catholic Feeder Schools. The OHSAA then filed this action to prevent Judge Ruehlman from taking further action in the case and to order him to vacate the temporary restraining order. The Supreme Court denied the writ, holding that the subject matter of this dispute fell within the jurisdiction granted by the Ohio Constitution and Revised Code to the Hamilton County Court of Common Pleas and that Judge Ruehlman properly exercised the subject-matter jurisdiction of the Hamilton County Court of Common Pleas. View "Ohio High School Athletic Ass'n v. Ruehlman" on Justia Law

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The Supreme Court denied the writ of mandamus sought by Relator to compel Kent State University to comply with her records request under Ohio Rev. Code 149.43, holding that Relator was not entitled to additional records beyond those that she had already received pursuant to her request.After Kent State responded to Relator’s records request, Relator filed this mandamus complaint. Following the complaint, Kent State provided additional records. The Supreme Court denied relief, holding that Kent State did not fail to uphold its duties under section 149.43. The Court granted Relator an award of statutory damages in the amount of $1,000 and granted Relator’s request for reasonable attorney fees but denied her request for court costs. View "State ex rel. Kesterson v. Kent State University" on Justia Law

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The Supreme Court denied the writ of mandamus sought by Relator seeking to compel Kent State University with certain records regarding student-athletes under the Public Records Act, Ohio Rev. Code 149.43, holding that Relator failed to show by clear and convincing evidence that Kent State failed fully to respond to her records request.Kent State provided several hundred pages of records in response to Relator’s records request. Relator later filed her mandamus complaint alleging that Kent State failed fully to respond to her request. The Supreme Court denied relief, holding (1) despite Kent State’s failure fro comply with Relator’s request within a reasonable period of time, Kent State’s eventual production of all the requested records rendered Relator’s mandamus claim moot; and (2) Relator was entitled to $1,000 in statutory damages and reasonable attorney fees but was not entitled to an award of court costs. View "State ex rel. Kesterson v. Kent State University" on Justia Law