Justia Education Law Opinion Summaries

A former public high school student alleged that his history teacher violated his rights under the Establishment Clause by making comments during class that were hostile to religion in general, and to Christianity in particular. At issue was whether the teacher was entitled to qualified immunity. The court affirmed the district court's conclusion that the teacher was entitled to qualified immunity. The court also held that because it was readily apparent that the law was not clearly established at the time of the events in question, and because the court could resolve the appeal on that basis alone, the court declined to pass upon the constitutionality of the teacher's challenged statements. View "C.F. v. Capistrano Unified Sch. Dist, et al." on Justia Law

This case arose when a student told a police officer that her teacher, plaintiff, inappropriately touched her and police subsequently searched plaintiff's home for child pornography. Plaintiff and his son sued the police officer, the City of Covina, and the Chief of Police for violating his constitutional rights, claiming that the city and the officers violated his and his son's Fourth Amendment right to be free from unreasonable search and seizure; the city inadequately trained and inadequately investigated complaints about its officers (Monell claim); and all defendants inadequately supervised and trained their subordinates with respect to the incidents alleged. The court held that, under the totality of the circumstances, a search warrant issued to search a suspect's home computer and electronic equipment lacked probable cause when no evidence of possession or attempt to posses child pornography was submitted to the issuing magistrate; no evidence was submitted to the magistrate regarding computer or electronics used by the suspect; and the only evidence linking the suspect's attempted child molestation to possession of child pornography was the experience of the requesting police officer, with no further explanation. The court held, however, that it had not previously addressed such issues and therefore, the officers involved in the search were entitled to qualified immunity. The court also affirmed the dismissal of plaintiff's Monell and supervisory liability claims where amending the complaint would be futile. View "Dougherty, et al. v. City of Covina, et al." on Justia Law

Qui tam relators brought this action on behalf of the United States government, appealing the district court's judgment dismissing, without leave to amend, their original complaint against the Individual Defendants and Ernst & Young (EY) under Federal Rule of Civil Procedure 12(b)(6). Relators alleged that the Individual Defendants, with the help of EY, falsely certified to the Department of Education its compliance with the Higher Education Act's (HEA), 20 U.S.C. 1094, ban on recruiter-incentive compensation in order to receive federal education funds, thereby violating the False Claims Act (FCA), 31 U.S.C. 3729(a)(1), (2), (3), (7). The court held that under the liberal standards for amending complaints, relators should be permitted to plead additional facts that could cure the complaint's deficiencies as to the allegations that Corinthian made a false statement and acted with the requisite scienter. The court also held that relators should have been allowed to amend the complaint to sufficiently state an FCA claim against the Individual Defendants. The court further held that, assuming that their complaint sufficiently alleged a false statement, relators have sufficiently pled an FCA violation as to EY. Accordingly, the court reversed the district court's Rule 12(b)(6) dismissal as to Corinthian, the Individual Defendants, and EY, and remanded with instructions to permit leave to amend the complaint. View "United States, et al. v. Corinthain Colleges, et al." on Justia Law

Plaintiffs, a Christian sorority and fraternity, as well as several of their officers at San Diego State University, brought suit in federal district court challenging the university's nondiscrimination policy under the First and Fourteenth Amendments. Plaintiffs subsequently appealed the district court's grant of summary judgment on all counts in favor of defendants. At issue was whether the Supreme Court's holdings in Christian Legal Society Chapter of the University of California, Hastings College of the Law v. Martinez extended to a narrow nondiscrimination policy that, instead of prohibiting all membership restrictions, prohibited membership restrictions only on certain specified bases. The court held that the narrower policy was constitutional. The court held, however, that plaintiffs have raised a triable issue of fact as to whether the narrower policy was selectively enforced in this particular case, thereby violating plaintiffs' rights under the First and Fourteenth Amendments. Accordingly, the court affirmed in part and reversed in part, and remanded to the district court for further proceedings. View "Alpha Delta Chi-Delta Chapter, et al. v. Reed, et al." on Justia Law

The court agreed to rehear this case en banc to clarify under what circumstances the exhaustion requirement of the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1415(l), barred non-IDEA federal or state law claims. Plaintiff, on behalf of herself and her son, appealed the district court's grant of summary judgment to defendants where the district court dismissed her claims for lack of subject matter jurisdiction because plaintiff did not initially seek relief in a due process hearing and therefore, failed to comply with one of the exhaustion-of-remedies requirement of the IDEA. The court held that the IDEA's exhaustion requirement was not jurisdictional and that plaintiff's non-IDEA federal and state-law claims were not subject to the IDEA's exhaustion requirement. Therefore, the court reversed the judgment. View "Payne, et al. v. Peninsula Sch. Dist., et al." on Justia Law

In 1974, African American and Mexican American students sued the Tucson, Arizona, school system alleging intentional segregation and unconstitutional discrimination on the basis of race and national origin. For some 30 years after the parties settled, Tucson's schools operated subject to a federally enforced desegregation decree. At issue was whether the school district had achieved unitary status and whether oversight of the school district's operations could terminate. The court reversed and ordered the district court to maintain jurisdiction until it was satisfied that the school district had met its burden by demonstrating, not merely promising, its "good-faith compliance... with the [Settlement Agreement] over a reasonable period of time." The court also held that the district court must be convinced that the district had eliminated "the vestiges of past discrimination... to the extent practicable" with regard to all of the Green v. Cnty. Sch. Bd. of New Kent Cnty. factors. The court further held that the district court retained discretion to order an incremental or partial withdrawal of its supervision and control. Accordingly, the case was remanded for further proceedings. View "Fisher, et al. v. Tucson Unified Sch. Dist. et al." on Justia Law

The parents of E.M., a bilingual student, brought an action to challenge the Pajaro Valley Unified School District's (District) determination that E.M. did not qualify for special education under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq. The Special Education Division of the California Office of Administrative Hearings (OAH) upheld the District's assessment and the district court affirmed the OAH's decision. The court disagreed with the district court's assessment only to the extent that it found one claim not addressed and one report not measured for its relevance. Accordingly, the court affirmed the judgment of the district court in part and reversed in part. The court remanded for the district court to consider whether the report was relevant to the determination of whether the district met its obligations to E.M. under the IDEA and whether an auditory processing disorder could qualify as an other health impairment, and if so, whether the district met its obligations to assess E.M. and identify him as a child with an other health impairment. View "E. M. v. Pajaro Valley Unified Sch. Dist." on Justia Law

Plaintiff, the mother of a developmentally disabled high school student, alleged that the several sexual encounters her daughter had with another developmentally disabled student in a school bathroom were the result of the school's failure to properly supervise her daughter. At issue was whether plaintiff, individually and on behalf of her daughter, had a cognizable Fourteenth Amendment due process claim against the daughter's special education teacher. The court held that the district court properly dismissed plaintiff's 42 U.S.C. 1983 civil rights claim at summary judgment where the special-relationship exception and the state-created danger exception did not apply in this case. The court held that whatever liability the special education teacher faced, that liability must come from state tort law, not the Fourteenth Amendment. Accordingly, the judgment of the district court was affirmed. View "Patel v. Kent Sch. Dist., et al." on Justia Law

Plaintiff filed a lawsuit under 42 U.S.C. 1983 against defendants claiming that she had been demoted in retaliation for exercising her First Amendment rights by attending a school board meeting and sitting next to her boss, who was fired at the meeting. At issue was whether the district court properly granted defendants' motion for summary judgment holding that defendants' efficiency interests were greater than plaintiff's interest in free association. The court held that it appeared that the triggering factor in defendants' action was simply plaintiff's decision to sit next to her boss at the public school meeting, without even speaking to him. The court also held that, because defendants produced no evidence that plaintiff's association with her boss actually disrupted the office or her performance, or reasonably threatened to cause future disruption, defendants failed to show that its interests in work-place efficiency outweighed plaintiff's First Amendment interests. Accordingly, the court reversed the district court's grant of summary judgment in favor of defendants.

A.S., a California minor, filed a request for a special education due process hearing where he was eligible for special education services under the Individuals with Disabilities Education Act ("IDEA"), 20 U.S.C. 1400 et seq., as an emotionally disturbed child. At issue was which California agency was responsible for funding a special education student's placement in an out-of-state residential treatment facility. The court requested the California Supreme Court exercise its discretion and decide the following certified question, "Whether under California law the school district responsible for the costs of a special education student's education while the student is placed at an out-of-state residential treatment facility is the district in which the student's de facto parent, who is authorized to make educational decisions on behalf of the student, resides."