Justia Education Law Opinion Summaries

Articles Posted in Supreme Court of Texas
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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

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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

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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

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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

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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

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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

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The Texas Whistleblower Act (WBA) does not apply to open-enrollment charter schools operated by a tax-exempt entity.Petitioner operated an open-enrollment charter school that provided tuition-free public education to students on multiple campuses. Respondent, a teacher for the school, sued the school for violating the WBA by retaliating against her. The trial court denied the school’s plea to the jurisdiction asserting immunity from suit. The court of appeals affirmed. The Supreme Court reversed, holding that because the WBA contains no specific statement that it applies to open-enrollment charter schools, see section 12.1058(c) of the Texas Charter Schools Act, it does not apply to open-enrollment charter schools. View "Neighborhood Centers Inc. v. Walker" on Justia Law

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At issue was whether a private university that operates a state-authorized police department is a “governmental unit” for purposes of Tex. Civ. Prac. & Rem. Code 51.014(a)(8), which provides for an interlocutory appeal from an order that “grants or denies a plea to the jurisdiction by a governmental unit.” The private university in this case was the University of the Incarnate Word (UIW), and the case arose from an UIW officer’s use of deadly force following a traffic stop. The parents of the UIW student killed in the incident sued UIW for their son’s death. UIW raised governmental immunity as a defense and asked the trial court to dismiss the suit in a plea to the jurisdiction. The trial court denied the plea. UIW took an interlocutory appeal under section 51.014(a)(8). The court of appeals dismissed the appeal. The Supreme Court reversed, holding that UIW is a governmental unit for purposes of law enforcement and is therefore entitled to pursue an interlocutory appeal under section 51.014(a)(8). View "University of the Incarnate Word v. Redus" on Justia Law

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Wallace Hall, a regent for The University of Texas System, filed suit against William McRaven in his official capacity as the System’s Chancellor, for McRaven’s refusal to grant Hall complete access to records containing student-admissions information. Hall sought a declaratory judgment that McRaven acted ultra vires in refusing to provide the unredacted information. The trial court granted McRaven’s plea to the jurisdiction and dismissed the case with prejudice, concluding that McRaven’s conduct was not ultra vires and that sovereign immunity required dismissal. The court of appeals affirmed. The Supreme Court affirmed, holding that McRaven did not exceed his authority, and therefore, Hall’s case was properly dismissed. View "Hall v. McRaven" on Justia Law

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Michael and Laura McIntyre, along with their children that were homeschooled, were criminally charged with contributing to truancy and failure to attend school. The McIntyres sued the District and its attendance officer, alleging that Defendants violated the McIntyres’ rights under both the Texas Constitution and United States Constitution. The District filed pleas, exceptions, and motions arguing that the McIntyres failed to exhaust their administrative remedies. The attendance officer invoked qualified immunity. The trial court denied relief. The court of appeals reversed in part and (1) dismissed the McIntyres’ state-law claims against the District and its attendance officer for the McIntyres’ failure to “exhaust their administrative remedies, and (2) dismissed the federal-law claims against the attendance officer based on qualified immunity. The Supreme Court (1) affirmed the judgment of the court of appeals to the extent it dismissed Plaintiffs’ claims based on qualified immunity; but (2) reversed the judgment insofar as it dismissed the McIntyres’ claims for failure to exhaust administrative remedies, holding the Texas Education Code does not require administrative appeals when a person is allegedly aggrieved by violations of laws other than the state’s school laws, such as the state and federal Constitutions. View "McIntyre v. El Paso Indep. Sch. Dist." on Justia Law