Justia Education Law Opinion Summaries

The Supreme Court reversed the judgment of the court of appeals affirming the decision of the trial court appeals denying the Texas Tech University School of Medicine's combined plea to the jurisdiction and summary judgment motion in the underlying unlawful discrimination action, holding that morbid obesity does not qualify as an impairment under the Texas Commission on Human Rights Act (TCHRA) without evidence that it is caused by an underlying physiological disorder or condition.After Plaintiff was dismissed from Texas Tech's medical residency program she brought this complaint alleging that the University dismissed her because of her morbid obesity, which she argued constituted unlawful discrimination under the TCHRA. The University filed a combined plea to the jurisdiction and summary judgment motion, arguing that it was protected under sovereign immunity. The trial court denied the plea and motion, and the court of appeals affirmed. The Supreme Court reversed, holding (1) morbid obesity qualifies as an impairment under the Labor Code only when caused by a physiological disorder or condition; and (2) Plaintiff could not establish that the University regarded her as having an impairment, and Plaintiff failed to show a disability as defined in the Labor Code. View "Tex. Tech University Health Sciences Center - El Paso v. Niehay" on Justia Law

The Supreme Court reversed the decision of the court of appeals that all of the documents underlying an external investigation into allegations of undue influence in a public university's admissions process were protected by the attorney-client privilege and were thus exempt from disclosure under the Texas Public Information Act, holding that the university's attorney-client privilege as to specific documents was waived.Specifically, the Supreme Court held (1) the investigator acted as a lawyer's representative in conducting the investigation; (2) the subject documents fell within the attorney-client privilege; (3) the university did not waive the privilege by disclosing to the investigator some of the documents; and (4) the publication of the investigator's final report waived the university's attorney-client privilege as to documents that the final report directly quoted from or otherwise disclosed a significant part of. View "University of Tex. System v. Franklin Center for Gov't & Public Integrity" on Justia Law

The Supreme Court reversed the judgments of the court of appeals in two ultra vires suits affirming the judgments of the trial courts denying Defendants' jurisdictional pleas as to the pertinent claims and affirmed the judgment of the court of appeals that the due process claims in one case may continue, holding that remand was required.At issue in these two consolidated cases was whether state university officials have the statutory authority to revoke a former student's degree after concluding that the former student engaged in academic misconduct while pursuing that degree. In both cases, the court of appeals concluded that such authority did not exist and thus affirmed the trial courts' denials of the university officials' plea to the jurisdiction on sovereign immunity grounds. The Supreme Court reversed in part, holding (1) the university officials' statutory authority encompassed the authority to determine that a student did not meet the conditions for the award of degrees; and (2) one student's allegation that the disciplinary proceeding she underwent violated her due-process rights was allowed to proceed. View "Hartzell v. S.O." on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the decision of the trial court to grant a temporary injunction in favor of the Houston Independent School District prohibiting the Texas Education Agency Commissioner and his appointed conservator from continuing to supervise the school district pending a final trial, holding that the District was not entitled to injunctive relief.While law permits the Commissioner to assist in improving a school district's performance through a variety of remedial measures, in question in this case was under what circumstances the Commissioner may supervise the Houston Independent School District (the District). Based on the results of an accreditation investigation, the Commissioner notified the District that it planned to appoint a board of managers for the District. The District filed petition seeking a temporary injunction barring the Commissioner from taking regulatory actions against it because the Education Code did not authorize the planned remedial measures. The trial court granted the petition, and the court of appeals affirmed. The Supreme Court reversed and directed the trial court to consider the Commissioner's plea to the jurisdiction, holding that the District's claims did not support a temporary injunction against the Commissioner and his conservator. View "Texas Education Agency v. Houston Independent School District" on Justia Law

The Supreme Court affirmed in part and reversed in part the decision of the court of appeals concluding that the Commissioner of Education had jurisdiction over a group of teachers' grievances and that some of the grievances were untimely and others were timely, holding that the grievances were timely filed.Teachers at Dallas Independent School District (DISD) objected to the district's method of evaluating teacher performance and filed grievances. DISD denied the grievances as untimely. The Teachers appealed to the Commissioner, who concluded that the untimely presentation of the grievances to the school board deprived him of jurisdiction. The district court affirmed. The court of appeals affirmed in part and reversed in part. The Supreme Court affirmed in part and reversed in part, holding (1) the Commissioner had jurisdiction to hear the appeal of the Teachers' grievance; (2) the Teachers' grievance was timely filed with DISD, and therefore, the portion of the court of appeals' judgment upholding the dismissal of portions of the grievance as untimely was erroneous; and (3) the portion of the court of appeals' opinion reversing the dismissal of part of the grievance is affirmed. View "Davis v. Morath" on Justia Law

The Supreme Court reversed the judgment of the court of appeals with respect to Plaintiff's constitutional claims, holding that a state university's dismissal of a student for poor academic performance does not implicate a liberty or property interest protected by the Texas Constitution's guarantee of due course of law.Plaintiff was dismissed from Texas Southern University's Thurgood Marshall School of Law after one year due to his failure to maintain the required grade point average. Plaintiff brought this suit against the School, alleging breach of contract and deprivation of his property and liberty without due course of law. The trial court granted the School's plea to the jurisdiction invoking sovereign immunity. The court of appeals reversed in part, concluding that Plaintiff's procedural and substantive due course of law claims were viable. The Supreme Court reversed in part and rendered judgment dismissing the case, holding that an academic dismissal from higher education does not implicate a protected liberty interest. View "Texas Southern University v. Villarreal" on Justia Law

The Supreme Court held that open-enrollment charter schools and their charter-holders have governmental immunity from suit and liability to the same extent as public schools and that, in this case, the open-enrollment charter school district had immunity from suit.The Burnham Wood Charter School District, which operates open-enrollment charter schools in El Paso, repudiated a lease with Amex Properties, LLC to lease certain property. Amex sued the district for anticipatory breach of the lease. The district filed a plea to the jurisdiction contending that it was immune from suit to the same extent as public school districts and that no waiver of immunity existed for Amex's claim. The trial court denied the district's jurisdictional plea, and the court of appeals affirmed. The Supreme Court reversed and dismissed the suit for want of jurisdiction, holding (1) open-enrollment charter schools have governmental immunity to the same extent as public schools; (2) Tex. Local Gov't Code 271 waives governmental immunity for breach of contract claims brought under the chapter; and (3) the lease in this case was not properly executed under section 271.151, and therefore, Amex's breach of contract claim was not waived under section 271.152. View "El Paso Education Initiative, Inc. v. Amex Properties, LLC" on Justia Law

In this complaint alleging ultra vires claims against Mike Morath, in his official capacity as the Commissioner of the Texas Education Agency, the Supreme Court granted Respondents' motion to dismiss this appeal as moot, dismissed the case as moot, and vacated both the judgment and opinion of the court of appeals without respect to the merits, holding that the case must be dismissed as moot.Morath filed a plea to the jurisdiction, alleging that Respondents' claims could not proceed for several reasons. The trial court denied the plea to the jurisdiction, and the court of appeals affirmed. Morath petitioned for review. After Morath filed his merits brief, Respondents decided to stop pursuing their claims and filed a "notice of nonsuit without prejudice." Respondents then moved to dismiss the appeal as moot. Morath opposed the motion to dismiss, arguing that a non-suit was ineffective and, alternatively, that this appeal involved a matter of public concern. The Supreme Court dismissed the appeal, holding that that this case is now moot, and in the absence of jurisdiction this case must be dismissed. View "Morath v. Lewis" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the judgment of the trial court reversing the decision of the Commissioner of Education upholding the decision of the North East Independent School District board to end Respondent's continuing teaching contract, holding that the record supported the board's and Commissioner's decisions.At issue was whether state and federal laws requiring school districts to record grades and evaluate student progress provide standards of conduct for the teaching provision such that the teacher's failure to comply with district policies implementing those laws supports termination for "good cause." The Commissioner agreed that Respondent's conduct was "good cause per se" for termination. The trial court reversed. The court of appeals affirmed, concluding that "good cause per se" has no basis in Tex. Educ. Code 21.156(a)'s good cause definition. The Supreme Court revered, holding (1) Respondent preserved her complaint for judicial review; (2) the Commissioner erred in employing the "good cause per se" test, which has no basis in the Education Code's plain text; and (3) evidence of a failure to meet a district policy that implements state law supports a good cause determination. View "North East Independent School District v. Riou" on Justia Law

The court of appeals properly vacated the temporary injunctions granted by the district court forestalling the Commissioner of Education’s revocation of two open-enrollment charter schools’ charters and dismissed the schools’ suit seeking judicial review of the Commissioner’s revocation on the grounds that sovereign immunity barred the schools’ claims.In their petitions for judicial review, the two open-enrollment schools challenged the validity of the Commissioner’s decision to revoke their respective charters, raising both constitutional and ultra vires complaints. The district court issued two orders temporarily enjoining the Commissioner from proceeding with the revocations. The court of appeals vacated the temporary injunctions and dismissed the schools’ underlying claims, concluding that all claims were barred by sovereign immunity. The Supreme Court affirmed, holding that the enabling statutes precluded judicial review of the Commissioner’s executive decisions at issue here, and no basis otherwise existed to invoke the district court’s inherent authority. View "Honors Academy, Inc. v. Texas Education Agency" on Justia Law