Justia Education Law Opinion Summaries

Plaintiff appealed the district court's grant of summary judgment dismissing her 42 U.S.C. 1983 suit against the Dean of the University of Iowa's College of Law. Plaintiff alleged that the Dean discriminated against her in violation of her First Amendment rights of political belief and association when plaintiff was not hired to be a full-time instructor or part-time adjunct instructor. The court held that plaintiff had presented sufficient evidence for a fact finder to infer that the Dean's repeated decisions not to hire her were in part motivated by her constitutionally protected First Amendment rights of political belief and association; the facts viewed in the light most favorable to plaintiff were sufficient to establish a violation of her First Amendment rights where it was apparent that a dispute existed regarding a material issue of fact, namely whether the Dean would have made the same hiring decisions in the absence of plaintiff's political affiliations and beliefs; the Dean had not shown that a reasonable university dean in her position would have believed that failing to hire plaintiff was lawful in light of clearly established law; and the district court erred in finding that qualified immunity protected the Dean from liability in her individual capacity. Accordingly, the court reversed the grant of summary judgment and remanded for further proceedings. View "Wagner v. Jones" on Justia Law

This case arose out of a dispute between plaintiff and her ex-husband over the education and custody of their three minor children. Plaintiff sued City Defendants, alleging that they unlawfully impeded her access to the children. Plaintiff sued the School District Defendants, asserting that they unlawfully denied her access to the children and their education records. The district court dismissed plaintiff's claims against the City Defendants for failure to state a claim and granted summary judgment for the School District Defendants. The court held that the fact that plaintiff lived in a different state did not suffice to convert the loss of a single three-hour visit into a deprivation of a fundamental right for purposes of substantive due process and, even if plaintiff could show a deprivation, the City Defendants' alleged conduct would not shock the conscience. The court also held that plaintiff failed to state a procedural due process claim against the City Defendants, given the relatively minimal deprivation alleged in this case, where the post-deprivation procedures were adequate to protect her rights to be heard at a meaningful time and in a meaningful manner. The court further held that plaintiff had no fundamental liberty interest in contacting her children at their schools and the court agreed with the district court that an attendance clerk's one-time refusal to tell plaintiff why one of the children had been absent from school, a coach's referral of plaintiff to her ex-husband for information about the children's swimming activities, and the school's refusal to send plaintiff all of the school's projects she requested did not amount to a deprivation of a fundamental liberty interest. Given the limited nature of any infringement of plaintiff's protected liberty interest, the procedures at issue were sufficient to protect plaintiff's right to procedural due process. The court finally held that plaintiff's right, as a non-custodial parent, under state law and her role in the children's lives vary significantly from the rights and role afforded to the ex-husband or to a typical married parent. Therefore, the court affirmed the grant of summary judgment to defendants with respect to her equal protection claims. Accordingly, the judgment of the district court was affirmed. View "Schmidt v. Des Moines Public Schools, et al." on Justia Law

Plaintiffs, parents of deaf and hearing impaired children, brought suit against defendants, claiming that the closure of the South Dakota School for the Deaf and the discontinuation of its programs at the school's campus violated state and federal law. The complaint sought, among other things, class certification and an order enjoining the closure of the school and outsourcing of its programs to other school districts. Plaintiffs subsequently appealed from the district court's order granting summary judgment in favor of defendants. The court held that the district court did not err in converting defendants' motion to dismiss to a motion for summary judgment. The court also held that plaintiffs have failed to allege facts to support their claim that the school's discontinuation of education programs at the Sioux Falls campus violated the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq., and therefore, the district court properly granted summary judgment in favor of defendants on that cause of action. The court further held that plaintiffs have failed to point out any facts supporting their claim that their constitutional rights were violated and therefore, their 42 U.S.C. 1983 cause of action against defendants in their individual capacities failed. The court finally held that plaintiffs did not have standing to sue on behalf of students in the auditory-oral program because they could not show an injury in fact. Therefore, the court concluded that it was within the South Dakota Board of Regents' power to discontinue offering education programs at the school's campus, in favor of contracting with other school districts to offer those programs and maintaining funds in its budgets for students to attend residential programs. View "Barron, et al. v. South Dakota Board of Regents, et al." on Justia Law

Two administrative hearing panels (Panels) concluded that the school district failed to provide plaintiffs' twin sons with a free appropriate public education (FAPE) in 2005, pursuant to the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq., but did provide one in 2006. The district court upheld these decisions and later awarded attorney's fees to plaintiffs. Plaintiffs and the school district cross appealed. The court held that the school district offered the twins a FAPE in 2005 and therefore, reversed the award of a reduced attorney's fee. The court affirmed, however, the district court's ruling that plaintiffs waived or abandoned their appeal of the Panels' 2006 FAPE decision. View "Park Hill Sch. Dist.v. Dass, et al." on Justia Law

Plaintiff sued his former music teacher, the Logan-Rogersville R-VII School District, and the school principal, asserting nine different claims stemming from the teacher's alleged sexual abuse of plaintiff. At issue was whether the district court erred in dismissing plaintiff's claims and denying his motion to amend his complaint. The court held that the district court correctly concluded that Counts 3, 4, 7, 8, and 9 were time-barred where plaintiff's complaint established that his cause of action accrued in 1992 when he was 15 years old, the statute of limitations was tolled until his 21st birthday, and he had five years, until November 22, 2003, to file his complaint. The court also held that plaintiff's claims under 42 U.S.C. 1983 and Title IX were also time-barred where both claims relied on the state's statute of limitations governing personal-injury claims and Missouri imposed a five-year statute of limitations for personal injury actions, Mo. Rev. Stat. 516.120.4. For the same reasons, plaintiff's state-law claims were time barred by section 516.120.4. The court further held that the district court's dismissal of plaintiff's childhood sexual abuse claim was affirmed where Mo. Rev. Stat. 537.046 required him to commence his action within five years of his 18th birthday. The court finally held that the district court properly dismissed plaintiff's sexual abuse claim against the school district and principal and the district court did not err in denying as futile plaintiff's motion to amend. Accordingly, the court affirmed the judgment of the district court. View "Walker v. Barrett, et al." on Justia Law

Appellant filed suit against the Fayetteville, Arkansas School District (District) alleging he was a victim of sexual harassment in violation of Title IX, 20 U.S.C. 1681. At issue was whether the district court erroneously instructed the jury and further erred in empaneling a twelve-member jury as oppose to a six-member jury. The court held that the district court did not abuse its discretion because the instruction provided by the district court accurately portrayed the law underlying appellant's Title IX claim where the "harasser must be motivated by [appellant's] gender or his failure to conform to stereotypical male characteristics" and because appellant was not entitled to an instruction on his theory of the case since it did not comport with the law where mere name-calling and rumors with sexual connotations were insufficient to provide relief under Title IX. The court also held that appellant's argument regarding the district court's error in empaneling a twelve-member jury had no merit where the district court had discretion to select "at least 6 and no more than 12 members" for a jury. Accordingly, the judgment was affirmed. View "Wolfe v. Fayetteville, AR Sch. Dist." on Justia Law

Plaintiff, an eleven-year-old special education student, lived in the Minnesota Independent School District No. 15 (district). An ALJ for the Minnesota Department of Education determined that the district had denied plaintiff a free appropriate public education (FAPE) within the meaning of the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400-1482. After plaintiff filed an action in federal court seeking attorney fees and costs, both parties filed cross-motions for judgment on the administrative record. The district court reversed the ALJ's decision and denied plaintiff's motion for fees and costs and plaintiff appealed. The court affirmed the district court's judgment and held that plaintiff was not denied a FAPE where the district court did not fail to give "due weight" to the results of the administrative hearing; where the district court did not commit procedural violations of the IDEA; and where the district court did not violate the IDEA's substantive requirements. View "K.E. v. Indep. Sch. Dist. No. 15" on Justia Law

D.J.M., a student in the Hannibal Public School District #60 (district), sent instant messages from his home to a classmate in which he talked about getting a gun and shooting some other students at school. After D.J.M. was subsequently suspended for ten days and later for the remainder of the school year as a result of his actions, D.J.M.'s parents sued under 42 U.S.C. 1983, alleging that the district violated D.J.M.'s First Amendment rights. At issue was whether the district court properly granted summary judgment to the district on D.J.M.'s constitutional claims and remanded his state claim for administrative review. The court held that D.J.M. intentionally communicated his threats to a third party and the district court did not err in finding that they were true threats. The court also held that true threats were not protected under the First Amendment and the district was given enough information that it reasonably feared D.J.M. had access to a handgun and was thinking about shooting specific classmates at the high school. Therefore, in light of the district's obligation to ensure the safety of its students and reasonable concerns created by shooting deaths at other schools, the district court did not err in concluding that the district did not violate the First Amendment by notifying the police and subsequently suspending him after he was placed in juvenile detention. The court further held that it was reasonably foreseeable that D.J.M.'s threats would be brought to the attention of school authorities and created a risk of substantial disruption within the school environment. The court finally held that it was not an abuse of discretion to dismiss the state law claim as moot. Accordingly, the judgment of the court was affirmed. View "D.J.M., et al. v. Hannibal Public Sch. Dist., et al." on Justia Law

The ACLU sued public charter school Tarek ibn Ziyad Academy (TIZA) and other defendants for violations of the Establishment Clause. At issue was whether the parents of students who attended TIZA had standing to intervene on behalf of the children and, in the alternative, whether the motion to intervene was timely. The court held that the parents had Article III standing where the parents have alleged an injury in fact, facts showing that the injury was imminent, the injury was fairly traceable to defendant's conduct, and redressability. The court held, however, that the district court did not make a clear error in finding the motion untimely where it was evident that for fourteen months, the parents were content to remain aloof from the litigation and dependent on TIZA to adequately represent their interests despite their knowledge of the case and its progress. The court further denied the ACLU's motion to supplement the record on appeal because the material proffered would not affect the outcome of the trial and denied the ACLU's motion to seal because it was moot. Accordingly, the court affirmed the district court's denial of the parents' motion to intervene. View "American Civil Liberties Union v. Mohammad, et al." on Justia Law

Appellants, on behalf of their disabled daughter, appealed the district court's finding that the Fort Osage R-1 School District ("school district") offered the daughter a free appropriate public education ("FAPE") within the meaning of the Individuals with Disabilities Education Act ("IDEA"), 20 U.S.C. 1400, et seq., for the 2006-2007 school year. Appellants sought reimbursement for their costs of placing their daughter at a private facility during the school year. The court held that the district court did not err in concluding that the school district offered the daughter a FAPE and that the Individualized Education Plan put forward by the school district did not suffer from any procedural error. Accordingly, the court affirmed the judgment of the district court.