Justia Education Law Opinion Summaries

A high school student, Adrianna Wadsworth, filed a lawsuit against her principal, Andrew Cavanaugh, a school social worker, Chuck Nguyen, and the school district, MSAD 40/RSU 40, alleging constitutional violations and a Title IX claim. Wadsworth claimed that Cavanaugh sexually harassed her, Nguyen failed to protect her, and the school district was indifferent to the harassment.The United States District Court for the District of Maine dismissed some of Wadsworth's claims and granted summary judgment in favor of the defendants on others. The court dismissed the supervisor-liability claim against Nguyen, finding no control over Cavanaugh. It also granted summary judgment to Cavanaugh on the substantive due process claim, concluding that non-physical harassment did not violate Wadsworth's right to bodily integrity. The court found that Wadsworth's equal protection claim against Cavanaugh was valid but granted him qualified immunity. Nguyen was granted summary judgment on the state-created-danger claim, as his conduct did not shock the conscience. The court also granted summary judgment to MSAD on the § 1983 municipal liability claim, finding no deliberate indifference, and on the Title IX claim, concluding that the assistant principals did not have actual knowledge of the harassment.The United States Court of Appeals for the First Circuit reviewed the case. It affirmed the district court's decision on the substantive due process claim against Cavanaugh but reversed the summary judgment on the equal protection claim, finding that a reasonable jury could conclude that Cavanaugh's conduct was severe and pervasive enough to constitute sexual harassment. The court also affirmed the dismissal of the supervisor-liability claim against Nguyen and the summary judgment on the state-created-danger claim. However, it reversed the summary judgment on the Title IX claim against MSAD, concluding that a reasonable jury could find that the assistant principals had actual knowledge of the harassment. The case was remanded for further proceedings consistent with the opinion. View "Wadsworth v. MSAD 40/RSU 40" on Justia Law

The case involves parents (the "Parents") of a student at Baird Middle School in Ludlow, Massachusetts, who challenged the school's protocol regarding the use of a student's requested name and gender pronouns without notifying the parents unless the student consents. The Parents argued that this practice interfered with their parental rights under the U.S. Constitution. The school, represented by the Ludlow School Committee and various school officials, defended the protocol as necessary to ensure a safe and inclusive environment for students.In the United States District Court for the District of Massachusetts, the Parents' complaint was dismissed. The court held that the Parents failed to state a plausible claim that the school's protocol violated their fundamental right to direct the upbringing of their child. Specifically, the court found that the Parents did not adequately allege that the school's actions constituted medical treatment or that the conduct was so egregious as to shock the conscience, which is required to establish a substantive due process violation.The United States Court of Appeals for the First Circuit reviewed the case. The court concluded that the protocol is a form of legislative conduct, not executive conduct, and thus did not require the shock-the-conscience test. The court determined that the Parents had identified a fundamental right but failed to plausibly allege that the school's conduct restricted that right. The court found that the school's actions, including the use of the student's chosen name and pronouns, did not constitute medical treatment and that the protocol did not restrict the Parents' rights to direct their child's upbringing.The First Circuit held that the protocol was rationally related to the legitimate state interest of creating a safe and inclusive educational environment for students. Therefore, the court affirmed the district court's dismissal of the Parents' complaint. View "Foote v. Ludlow School Committee" on Justia Law

O.M. was a student of the Falmouth School Department. O.M.’s mother, Ms. M. argued that her daughter’s individualized education program (IEP) specified that Falmouth would instruct O.M. using a Specialized Program Individualizing Reading Excellence (SPIRE) system during her third-grade year, and because Falmouth did not provide O.M. with the SPIRE instruction, the School Department violated O.M.’s right to a free appropriate public education (FAPE) as guaranteed under the Individuals with Disabilities Education Act (IDEA). The district court entered judgment in favor of Ms. M. The First Circuit reversed, holding that O.M.’s IEP did not mandate that Falmouth use SPIRE, and therefore, the School Department neither breached the terms of the IEP nor denied O.M. a FAPE by omitting such instruction. View "M v. Falmouth School Department" on Justia Law

Plaintiffs, two high-profile medical researchers that held faculty appointments at Harvard Medical School and were intimately involved with a research laboratory at Brigham and Women’s Hospital, were investigated for alleged research misconduct. Responding to allegations that Plaintiffs used manipulated research data in articles reporting on studies supported by government funds, Harvard and Brigham triggered a unique federal statutory and regulatory scheme. Without awaiting the outcome of the administrative proceedings, Plaintiffs filed suit in federal court against the institutional defendants, alleging, inter alia, tortious interference with business relations, invasion of privacy, and unfair and deceptive business practices. The district court dismissed the action, concluding that the suit was premature because Plaintiffs had not exhausted their administrative remedies. The First Circuit affirmed as modified, holding (1) the district court correctly applied the doctrine of administrative exhaustion; but (2) on remand, the district court is directed to convert its order of dismissal to an order staying the case pending the timely resolution of administrative proceedings. View "Anversa v. Partners Healthcare Sys., Inc." on Justia Law

When Jane Doe was in second grade, she began receiving special education under the Individuals with Disabilities Education Act based on her deficiency in reading fluency. More than six years later, an administrative hearing officer determined that Jane was no longer eligible to receive special education. The district court affirmed. The First Circuit vacated and remanded the case, holding (1) the district court erred in relying on evidence of Jane’s overall academic performance without regard to how it reflected her reading fluency skills; and (2) the district court did not make an independent judgment as to the additional evidence submitted by Jane’s parents and afforded excessive deference to the hearing officer’s determinations in weighing the relevant reading fluency measures. View "Mr. & Mrs. Doe v. Cape Elizabeth Sch. Dist." on Justia Law

Ms. S. filed a request for a due process hearing with the Maine Department of Education (MDOE) concerning alleged Individuals with Disabilities Education Act (IDEA) violations in the case of her son, B.S., during his ninth, tenth, eleventh, and twelfth grade years. A hearing officer with the Maine Department of Education (MDOE) dismissed Ms. S.’s ninth and tenth grade claims as time barred by a two-year filing limitation. Ms. S. sought judicial review, arguing that the two-year filing limitation was void because it was not promulgated in compliance with the Maine Administrative Procedure Act (MAPA). The district court upheld the hearing officer’s decision, concluding (1) the two-year filing limitation was valid; and (2) B.S. received a free appropriate public education (FAPE) in the eleventh and twelfth grades. The First Circuit vacated and remanded in part and affirmed in part, holding (1) the district court erred in its analysis of the validity of the two-year filing limitation, and the record is insufficient to determine whether the MDOE adequately complied with MAPA procedures when adopting the filing limitation; and (2) B.S. received a FAPE in the eleventh and twelfth grades. View "Ms. S. v. Regional School Unit 72" on Justia Law

R.M. was a 12-year-old middle school student in Lexington, when several students pulled him to the ground and beat him, repeatedly kicking and punching him in the head and stomach. The beating was captured on a video. Principal Flynn discussed the incident with R.M.’s mother, Morgan. He indicated that R.M. had agreed to the beating as part of an initiation into a group and had "delay[ed] the investigation," so that R.M. would not be allowed to participate in an upcoming track meet. Later, R.M. was "pushed, tripped, punched or verbally assaulted while walking in school hallways." R.M. had his pants pulled down in front of other students and was pushed into a locker. Morgan emailed Principal Flynn that R.M. did not feel safe at school and was scared to report bullying for fear of retaliation. R.M. missed a significant amount of school due to anxiety attacks. Morgan filed suit, alleging violation of R.M.'s federal substantive due process rights, relying upon a theory once suggested by the Supreme Court that when the state creates a danger to an individual, an affirmative duty to protect might arise. The First Circuit affirmed dismissal, further agreeing that the conduct did not fall within the scope of Title IX, which is concerned with actions taken "on the basis of sex," and not undifferentiated bullying. View "Morgan v. Town of Lexington" on Justia Law

An organization called Students for Fair Admissions, Inc. (SFFA) brought this lawsuit challenging Harvard College’s consideration of race in its undergraduate admissions decision. An opposing group of current and prospective Harvard students (“Students”) sought to intervene, over both parties’ objection, to advocate for the defeat of SFFA’s claims. The district court denied Students’ motion to intervene. Students appealed. The First Circuit affirmed, holding that the district court did not err in finding that Students failed to show that no existing party would adequately represent Students’ interest and thus that Students’ participation as a party was not needed. View "Students for Fair Admissions, Inc. v. President and Fellows of Harvard College" on Justia Law