Justia Education Law Opinion SummariesArticles Posted in U.S. 5th Circuit Court of Appeals
Morgan, et al. v. Plano Indep. Sch. Dist, et al.
Plaintiffs, four former elementary-school students, sued the school district because school officials have, at various times and in various ways, prevented them from evangelizing while at school. At issue was whether the school principals violated clearly established law when they restricted plaintiffs from distributing written religious materials while at school. The court held that the principals were entitled to qualified immunity because clearly established law did not put the constitutionality of their actions beyond debate. Accordingly, the court reversed the judgment of the district court and remanded with an instruction to dismiss plaintiffs' claims as to the principals in their individual capacities. View "Morgan, et al. v. Plano Indep. Sch. Dist, et al." on Justia Law
Alief Independent Sch. Dist v. C. C.
This case stemmed from a dispute regarding the individualized education program (IEP) of C.C., a child with a disability. At issue was whether a school district, after being declared in compliance with the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400-1490, in respect to a disabled child's entitlements, by an administrative hearing officer, could bring a civil action in court for attorneys' fees as a prevailing party against the child's parents on the grounds that their IDEA administrative complaint was brought for an "improper purpose, such as to harass, to cause unnecessary delay, or to needlessly increase the cost of litigation," although the parents had voluntarily dismissed their administrative complaint without prejudice. The court held that, under the plain meaning of the IDEA and its implementing regulations, the administrative proceeding through which the school district sought a declaratory ruling was a proceeding under section 1415. The court also held that the declaratory ruling favorably altered the school district's legal relationship with the parents. Therefore, the court reversed the district court's legal relationship dismissing the school district's civil action and remanded the case for determination of whether the parents' administrative complaint "was delay or to needlessly increase the cost of litigation," and if so, whether the district court should, within its discretion, award attorneys' fees to the school district. View "Alief Independent Sch. Dist v. C. C." on Justia Law
Swindle, et al. v. Livingston Parish, et al.
Plaintiffs brought this action for damages under 42 U.S.C. 1983 on behalf of their minor daughter, who allegedly was deprived of her constitutional rights when she was expelled from public school and refused alternative education benefits during the 2005-2006 academic school year by defendants. The district court granted summary judgment in favor of defendants dismissing all of plaintiffs' claims. The court affirmed the district court's summary judgment in principal part, but reversed summary judgment with respect to plaintiffs' claims that their daughter was deprived of her constitutional right to procedural due process when defendants denied her right under state law to continued public educational benefits through an alternative education program without some kind of notice and some kind of hearing. Accordingly, the court remanded the case to the district court for further proceedings. View "Swindle, et al. v. Livingston Parish, et al." on Justia Law
Doe, et al. v. Covington County Sch. Dist., et al.
Plaintiffs sued, inter alia, the Covington County School District, its Board of Education, its president, and other persons, in their official and individual capacities (collectively, Education Defendants), as well as other known and unknown persons, under 42 U.S.C. 1983 and 1985, alleging violations of Jane Doe's Fourteenth Amendment substantive due process rights and various state law violations where the Education Defendants were deliberately indifferent to nine-year-old Jane's safety when they forced her into the sole custody of an unauthorized adult who took her off of the school's grounds. At issue was what were the circumstances under which a compulsory-attendance, elementary public school had a "special relationship" with its nine-year-old students such that it had a constitutional "duty to protect" their personal security. The court held that plaintiffs have pleaded a facially plausible claim that the school violated Jane's substantive due process rights by virtue of its special relationship with her and its deliberate indifference to known threats to her safety. Accordingly, the court reversed the district court's grant of the Education Defendants' Federal Rule of Civil Procedure 12(b)(6) motion, affirmed that court's qualified immunity dismissal of plaintiffs' special relationship claims against those Education Defendants sued in their individual capacities, and remanded to the district court for further proceedings. View "Doe, et al. v. Covington County Sch. Dist., et al." on Justia Law
School Board of Avoyelles Prsh v. U. S. Dept. of Interior
These three closely related appeals arose out of two district court cases, each involving a different tract of land owned by the Avoyelles Parish School Board (School Board), where neither tract was accessible by public road and both shared borders with the Lake Ophelia Wildlife Refuge (Refuge), which was owned by the United States Department of Interior (Department). The School Board filed these suits against all adjoining landowners, including the Department, to fix the School Board's legal rights of passage to the respective enclosed lands. The district court fixed rights of passage that burdened Refuge lands and concluded that the Department could not impose certain desired restrictions on the School Board's actions on Refuge lands. On appeal, the court reversed both judgments in full and remanded for further proceedings. View "School Board of Avoyelles Prsh v. U. S. Dept. of Interior" on Justia Law
Sanches v. Carrollton-Farmers Branch Indep. Sch. Dist.
Plaintiff appealed summary judgment on her claims of sex discrimination and retaliation under 20 U.S.C. 1681(a) (Title IX) and 42 U.S.C. 1983. The court found that the case was nothing more than a dispute fueled by a disgruntled cheerleader mom, over whether her daughter should have made the cheerleading squad. The court affirmed summary judgment on the Title IX claim and held that the supposed harassment was not based on sex, it was not severe, pervasive or objectively unreasonable, and the district court was not deliberately indifferent to it. The court affirmed summary judgment on the Title IX retaliation claim and held that there was no support in the record for plaintiff's arguments. The court affirmed summary judgment on the section 1983 claim and held that any harassment was not based on sex, so there was no constitutional violation and there was no evidence that the district court was ever deliberately indifferent. The court affirmed summary judgment on the section 1983 retaliation claim and held that plaintiff failed to point to any evidence that the district court retaliated against her. View "Sanches v. Carrollton-Farmers Branch Indep. Sch. Dist." on Justia Law