Justia Education Law Opinion Summaries

Plaintiff commenced this lawsuit after he was terminated from his employment at Arkansas State University, asserting procedural due process claims under 42 U.S.C. 1983 against the Vice-Chancellor and Director-of-Instruction in their official and individual capacities. Plaintiff alleged that the officials provided constitutionally inadequate pretermination process and sought damages and injunctive relief. The court concluded that reasonable school officials would not have known that the officials' conduct violated plaintiff's clearly established due-process rights and therefore reversed the district court's denial of qualified immunity. View "Sutton v. Bailey, et al" on Justia Law

Plaintiffs, a fifth grade student and his mother, commenced this action against the St. Louis Board of Education and two nurses, asserting Fourth Amendment and substantive due process claims under 42 U.S.C. 1983 and state law claims for negligence and negligent supervision. The student was administered an H1-N1 shot by a school nurse despite telling the nurse, and presenting a signed parental form confirming, that his mother did not consent to the vaccination. The court held that the district court correctly noted that a local government entity, such as the Board, could not be sued under section 1983 respondeat superior theory of liability; plaintiffs' failure to train claims against the Board were properly dismissed for either failure to plead a plausible claim or failure to state a claim; and claims against Nurse Clark were dismissed because the nurse was acting within her official capacity and had immunity from suit. View "B.A.B., et al v. The Board of Education, et al" on Justia Law

The school district issued 180-day suspensions to twin brothers, the Wilsons, for disruption caused by a website the Wilsons created. The Wilsons filed suit against the school district alleging, among other things, that the school district violated their rights to free speech. At issue was the order granting the Wilsons' motion for a preliminary injunction. The court did not find that the district court made inadequate factual findings; rather, the court concluded that the district court's findings did not support the relief granted. The court held that the Wilsons were unlikely to succeed on the merits under the relevant caselaw. The court also concluded that the district court's findings did not establish sufficient irreparable harm to the Wilsons to justify a preliminary injunction. View "S.J.W., et al v. Lee's Summit R-7 School Dist., et al" on Justia Law

CEF, a local chapter of an international non-profit organization that conducted weekly "good news clubs" (GNC) for children, appealed the district court's denial of a preliminary injunction against the district. Due to concerns about the "prayer and proselytizing," which occurred at GNC meetings, CEF was informed that it would be removed from the district's after-school enrichment program effective in the 2009-2010 school year. The court held that the district court abused its discretion in denying the preliminary injunction. CEF had a high likelihood of success on the merits of its First Amendment claim. The likely First Amendment violation further meant that the public interest and the balance of harms (including irreparable harm to CEF) favored granting the injunction. Therefore, the court reversed and remanded for further proceedings. View "Child Evangelism Fellowship v. Minneapolis Special Sch. Dist. 1" on Justia Law

Southeast Technical Institute (STI) in South Dakota is a public post-secondary technical school funded by the State through Sioux Falls School District No. 49-5 and governed by the Sioux Falls School Board. STI terminated Registrar Matt Onnen for awarding degrees to students who had not earned them, not awarding degrees when students had earned them, and failing to verify students for graduation. Meanwhile, Onnen filed a qui tam complaint against the school district, its superintendent, and the school board members, alleging that Defendants violated the False Claims Act (FCA) by knowingly submitting false or fraudulent claims to the federal government for student grants and guaranteed loans. Onnen did not sue STI or any STI employee. The district court granted summary judgment for Defendants. The Eighth Circuit Court of Appeals affirmed, holding the district court did not err in concluding Onnen's affidavit was insufficient to prove that any defendant committed a knowing violation of the FCA. Therefore, summary judgment was appropriate. View "United States ex rel. Onnen v. Sioux Falls Indep. Sch. Dist." on Justia Law

Sinan Cingilli, a student at the University of Minnesota, and TCA, a non-profit corporation that provided information about the nation of Turkey and Turkish-Americans, appealed the district court's dismissal of their respective First Amendment claims and TCA's state-law defamation claim for failure to state a claim. Defendant Professor Chaouat directed the Center for Holocaust and Genocide Studies at the university. The Center's website displayed a list of "Unreliable Websites" which included websites that disputed the factuality of the Nazi genocide of Jews during World War II. The first "Unreliable Website" on the list was that of TCA. The court held that, because Cingilli failed to plead facts sufficient to demonstrate an objectively reasonable chilling effect, he had not established standing to pursue a First Amendment claim under these circumstances; TCA had pled a cognizable injury and had standing to pursue its First Amendment claim; in light of the absence of the allegations that the challenged actions posed obstacle to students' access to the materials on TCA's website or made materials substantially unavailable at the university, the Rule 12(b)(6) dismissal of TCA's First Amendment claim was affirmed; and because the challenged statements at issue either were true or could not reasonably be interpreted as stating facts, the Rule 12(b)(6) dismissal of TCA's defamation claim was also affirmed. View "Turkish Coalition of America, et al. v. Bruininks, et al." on Justia Law

T.B.'s parents, on behalf of their autistic child, appealed the district court's finding that the school district did not violate the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq., by failing to provide a free appropriate public education (FAPE) to T.B., making the parents ineligible for reimbursement for the costs of T.B.'s home-based program. Given the parents' decision to ultimately settle the issue of the adequacy of the proposed individualized education program (IEP), the court questioned whether they could claim, much less successfully show, that the school district failed to provide a FAPE to T.B. Nonetheless, based on the record, the court could not say that T.B.'s home-based program was "reasonably calculated to enable [him] to receive educational benefits." The program was therefore not "proper" within the meaning of the IDEA and the parents were not entitled to reimbursement for the costs associated with it. Accordingly, the court affirmed the judgment. View "T.B., et al. v. St. Joseph School District" on Justia Law

Plaintiff, a licensed Iowa educator, filed suit in Iowa state court against his employer, school officials, and private citizens following his termination. Plaintiff alleged various state-law claims as well as violations of his procedural and substantive due process rights under 42 U.S.C. 1983. On appeal, plaintiff challenged the denial of his motion to remand and the dismissal of his section 1983 claims. The court held that the district court did not err in denying the motion to remand where, based upon the facts of the case, the unanimity requirement was satisfied. The court also held that the district court did not err in dismissing plaintiff's procedural due process claims as unexhausted where he failed to appeal his termination to an adjudicator under Iowa Code 279.17 and in dismissing plaintiff's substantive due process claim where he failed to plausibly plead a substantive due process claim. Accordingly, the court affirmed the judgment. View "Christiansen v. West Branch Community School, et al." on Justia Law

An Arkansas jury found in favor of plaintiff on her Title VII claims of race discrimination and constructive discharge against the school district and individual members of the County's Board of Education and awarded her compensatory damages, wage and fringe benefits, and punitive damages. Plaintiff subsequently appealed the district court's judgment. The court held that, under the circumstances, it believed that plaintiff presented sufficient evidence for a reasonable jury to conclude defendant was constructively discharged. Therefore, the court reversed the district court's decision to grant the Rule 50 motion on that claim. The court held that the jury was not instructed to consider whether the individual Board members affirmatively proved ignorance of federal law when discriminating against defendant on the basis of her race. Therefore, the court reversed the district court's Rule 50 motion vacating the punitive damage award, but remanded this issue to the district court. Because the court's resolution of the constructive discharge claim and the punitive damage awards directly affected the degree of success plaintiff obtained in her civil rights action, the court remanded the issue of attorneys' fees. View "Sanders v. Lee County Sch. Dist. No. 1, et al." on Justia Law

In consolidated appeals regarding continuing school desegregation efforts in the Little Rock, Arkansas area, NLRSD and PCSSD each appealed the district court's denial of their petitions for a declaration of unitary status. In addition, NLRSD and PCSSD joined with LRSD, several local teachers' unions, and a union member in appealing the district court's decision to terminate certain funding obligations of the State arising from a previous settlement agreement in this case. The court reversed the denial of unitary status for NLRSD in the area of staff recruitment where NLRSD had maintained levels of black teacher employment that exceeded the percentages in the relevant labor market, when viewed in light of NLRSD's good-faith efforts, which suggested that the vestiges of past discrimination have been eliminated to the extent practicable in the area of recruitment. The court affirmed, however, the denial of unitary status for PCSSD in the area of student assignment, advanced placement, discipline, school facilities, scholarships, special education, staff, student achievement, and monitoring. The court vacated the portion of the district court's order terminating the State's funding obligations under the 1989 Settlement Agreement. View "Little Rock Sch. Dist. v. State of Arkansas, et al.; Joshua, et al. v. Pulaski County Special Sch. Dist.; Armstrong, et al. v. North Little Rock Sch. Dist.; North Little Rock Classroom Teachers Assoc., et al. v. State of Arkansas, et al." on Justia Law