Justia Education Law Opinion SummariesArticles Posted in U.S. 5th Circuit Court of Appeals
Morgan, et al. v. Plano Indep. Sch. Dist.
Plaintiffs sued the school district over an alleged violation of First Amendment rights because plaintiffs' third-grade son was prevented from distributing a "candy cane ink pen" with a laminated card containing a religious message. The court concluded that it had jurisdiction because it was well-established under Texas law that the district's governmental immunity was not a mere defense to suit but rather was complete immunity from suit. And because governmental immunity from suit defeated a trial court's jurisdiction, whether a trial court had jurisdiction was a question of law subject to de novo review. Section 110.06 of the Texas Religious Freedom Restoration Act (TRFRA), Tex. Civ. Prac. & Rem. Code 110.001-110.012, required pre-suit notice in the form of certified mail, return receipt requested. The court concluded that the district's governmental immunity was not waived because it was undisputed that plaintiffs' demand letter did not comply with the jurisdictional pre-suit notice requirements. View "Morgan, et al. v. Plano Indep. Sch. Dist." on Justia Law
Wyatt v. Fletcher, et al.
Plaintiff, as next-friend to her minor daughter, brought suit under 42 U.S.C. 1983 against high school softball coaches, alleging that the coaches disclosed the daughter's sexual orientation during a disciplinary meeting with plaintiff, primarily claiming the disclosure to plaintiff constituted a Fourteenth Amendment invasion of the daughter's privacy. The court held that there was no clearly established law holding that a student in a public secondary school had a privacy right under the Fourteenth Amendment that precluded school officials from discussing with a parent the student's private matters, including matters relating to the sexual activity of the student. The court also held that such students have no clearly established Fourteenth Amendment right that barred a student-coach confrontation in a closed and locked room. Therefore, the court concluded that the coaches were entitled to qualified immunity that barred the federal claims against them. Accordingly, the court reversed and vacated in part and remanded for entry of judgment dismissing the federal claims against the coaches. View "Wyatt v. Fletcher, et al." on Justia Law
Raj v. LSU, et al
Plaintiff, a professor at LSU, appealed the district court's dismissal of his complaint for lack of subject matter jurisdiction and for failure to state a claim on which relief can be granted. Plaintiff alleged discrimination based on his race, religion, national origin, age, and gender. Although plaintiff asserted claims for injunctive and declaratory relief, he could not overcome sovereign immunity under Ex parte Young because he named only LSU, LSU Health, and the LSU Board as defendants. Therefore, the court found that sovereign immunity barred plaintiff's claims under the Age Discrimination in Employment Act, 29 U.S.C. 621 et seq., and 42 U.S.C. 1983 and 1985. Plaintiff's state law claims were also barred by sovereign immunity. With regard to plaintiff's remaining claims, the court recognized that plaintiff was not required to establish a prima facie case of discrimination at the pleading stage, but the court nonetheless concluded that plaintiff had failed to state a claim for which relief could be granted. Accordingly, the court affirmed the judgment. View "Raj v. LSU, et al" on Justia Law
Alief Indep. Sch. Dist v. C. C.
Defendants, parents of a minor child who filed an unsuccessful administrative complaint against the school district, asserted that the district court's denial of attorneys' fees to the school district in turn rendered defendants prevailing parties. The court affirmed, however, the district court's denial of attorneys' fees to defendants because defeating a request for attorneys' fees was not the type of success on the merits required to establish prevailing party status. View "Alief Indep. Sch. Dist v. C. C." on Justia Law
Stewart v. Waco Indep. Sch. Dist.
Plaintiff appealed from the district court's dismissal of her civil rights action against the District. Plaintiff sought review of her claim under section 504 of the Rehabilitation Act of 1973, 29 U.S.C. 794, for the District's alleged gross mismanagement of her Individualized Education Program (IEP) and failure to reasonably accommodate her disabilities. Because plaintiff plausibly stated that the District acted with gross misjudgment in failing to further modify her IEP, the court reversed and remanded for further proceedings. Because plaintiff appealed only the dismissal of her Rehabilitation Act claim, the court did not address the district court's rulings as to the other claims. View "Stewart v. Waco Indep. Sch. Dist." on Justia Law
R. P. v. Alamo Heights Indep Sch Dist
Plaintiff appealed the district court's grant of summary judgment to the school district, alleging that she was denied a free appropriate public education (FAPE) under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq. The court held that plaintiff satisfied the court's liberal notice of appeal requirements and therefore considered the appeal on the merits. The court found that the district court complied with the IDEA's procedural requirements and, moreover, if any defects existed, they did not rise to the level of denying plaintiff a lost educational opportunity. In regards to plaintiff's substantive claim, the court analyzed the Michael F. factors and concluded that plaintiff received a FAPE. Accordingly, the court affirmed the judgment. View "R. P. v. Alamo Heights Indep Sch Dist" on Justia Law
Klein Independent Sch. Dist. v. Hovem
Per Hovem (Per), a former student of Klein Independent School District (KISD), along with his parents, filed a claim under the Individuals with Disabilities Education Act (IDEA) for reimbursement of private school expenses incurred because KISD allegedly failed to provide Per with a free appropriate public education (FAPE) while Per was a KISD student. The special hearing officer and the district court found in favor of the Hovems. The Fifth Circuit Court reversed, holding (1) the provision of FAPE to a student qualified for special education must be judged by the overall educational benefits received, and not solely by the remediation of the student's disability; and (2) because this student's individualized education program enabled him to excel, with accommodations for his disability, in a mainstream high school curriculum, KISD complied procedurally and substantively with IDEA. View "Klein Independent Sch. Dist. v. Hovem" on Justia Law
Reed v. Florida Metro University, Inc., et al.
This case arose when plaintiff filed a putative class action in Texas state court alleging that defendants had violated certain provisions of the Texas Education Code by soliciting students in Texas without the appropriate certifications. Defendants subsequently appealed the district court's confirmation of an arbitral award that required them to submit to class arbitration. They contended that the district court, not the arbitrator, should have decided whether the parties' agreement provided for class arbitration, and that the district court should have vacated the arbitrator's class arbitration award. Because the parties agreed that the arbitrator should decide the class arbitration issue, the court concluded that the district court correctly referred that issue to the arbitrator. The district court erred, however, in confirming the award because the arbitrator exceeded his powers. Therefore, the court reversed and remanded for further proceedings. View "Reed v. Florida Metro University, Inc., et al." on Justia Law
Darrin Lewis, Sr. v. Ascension Parish School Board
In this equal protection case, plaintiff appealed from a grant of summary judgment in favor of the School Board. The district court rejected plaintiff's claim that the School Board's student assignment plan, formulated to address school population changes while "maintaining the district's unitary status," was impermissibly race-based and discriminatory against minority elementary, middle, and high school students zoned for East Ascension High School. At issue on appeal was whether child A had standing; prescription of plaintiff's claims based upon the 2002 feeder plan modification; and whether Option 2f violated the Fourteenth Amendment's equal protection clause. The court held that because it remanded on other grounds, the court vacated the district court's ruling on whether plaintiff had standing to pursue claims on behalf of child A and remanded for reconsideration by the district court in the first instance as to whether to permit plaintiff to cure his defective allegations of capacity. The court also held that the district court correctly held that the 2002 feeder plan modifications claims were time-barred. The court finally held that because factual questions existed as to whether Option 2f had both a racially discriminatory motive and a disparate impact, and the district court misapprehended the significance of the evidence before it, that court erred in awarding summary judgment under a rational basis test. Accordingly, further factual development was required. View "Darrin Lewis, Sr. v. Ascension Parish School Board" on Justia Law
Juarez v. Brownsville Indep. Sch. Dist., et al.
This case stemmed from allegations of improprieties at the Brownsville Independent School District (BISD), including allegations that appellants were manipulating the bidding process for the BISD's Stop Loss Insurance Coverage. Appellants, all members of the BISD Board of Trustees (Board), argued that the district court should have granted their motion for summary judgment because they were entitled to qualified immunity. The court found no error in the district court's holding that genuine issues of material fact existed with respect to whether appellants violated appellee's First Amendment rights. The court also held that the district court did not err when it denied summary judgment on appellants' qualified immunity defense. View "Juarez v. Brownsville Indep. Sch. Dist., et al." on Justia Law