Justia Education Law Opinion Summaries

Articles Posted in US Court of Appeals for the Eighth Circuit
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Plaintiffs filed suit under the Individuals with Disabilities Education Act (IDEA), bringing a due process challenge to the school district's individualized education plan (IEP) and school placement before the Missouri Administrative Hearing Commission. The Commission affirmed the plan and placement, denying reimbursement. The district court reversed the Commission but limited the reimbursement award based on equitable considerations. The Eighth Circuit held that the school district violated the IDEA and the district court erred in limiting the award. As a preliminary matter, the court held that the school district's jurisdictional challenge was without merit; the school district's mootness challenge also failed; and the district court properly placed the burden on plaintiffs in the proceeding before it and correctly stated the standard of review on appeal. On the merits, the court held that the school district denied plaintiffs' son a free and appropriate education as required by the IDEA when it placed him at a school without direct occupational therapy or a sensory diet plan in place to address his autism-related issues. The court also held that an award limitation based on improvements to the school was inappropriate and inconsistent with the purposes of the IDEA because the school district failed to give any notice to plaintiffs. Furthermore, limiting an award based on improvements not communicated to plaintiffs was inconsistent with the IDEA's purpose. Accordingly, the court reversed the district court's limitation of tuition reimbursement and awarded full tuition reimbursement. View "D. L. v. St. Louis City School District" on Justia Law

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Vianney appealed the district court's summary judgment rulings on their Religious Land Use and Institutionalized Persons Act (RLUIPA) claims, Missouri Religious Freedom Restoration Act (Missouri RFRA) claim; and inverse condemnation claim under Missouri's Constitution. The Eighth Circuit affirmed as to the RLUIPA claims, holding that the city's lighting and sound regulations did not substantially burden, rather than merely inconvenienced, Vianney's religious exercise. In this case, Vianney has not demonstrated that a requirement that it avail itself of alternatives would substantially burden its religious exercise, and the record demonstrated that Vianney was not treated less favorably than other schools. The court also affirmed as to the inverse condemnation claim, holding that Missouri courts have held that the reasonable exercise of a city's police power does not constitute a taking and the regulations here did not impose unusually restrictive limitations. However, the court vacated as to the Missouri RFRA claim, because the district court abused its discretion in deciding this state law claim on the merits after granting the city summary judgment on the RLUIPA claims. Accordingly, the court remanded to the district court with instructions to dismiss the claim without prejudice. View "Marianist Province of the U.S. v. City of Kirkwood" on Justia Law

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Plaintiffs filed suit against the University under Title IX of the Education Amendments of 1972 and various state laws, alleging that the University failed to protect them against stalking and sexual harassment by a fellow student. The Eighth Circuit affirmed the district court's grant of summary judgment to the University, holding that, because Plaintiff Kirkpatrick could not satisfy the actual knowledge element, her Title IX claim failed as a matter of law and the district court properly granted summary judgment in favor of the University on that claim; the district court properly granted summary judgment to the University on Pearson's Title IX claim because there was no genuine dispute of material fact as to whether the University was deliberately indifferent to any stalking or harassment that she experienced; and the district court properly dismissed plaintiffs' state law premises liability and general negligence claims, because plaintiffs could not establish that the school owed them a duty of care under Missouri law. View "Pearson v. Logan University" on Justia Law

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The Eighth Circuit affirmed the district court's grant of summary judgment for the school district and partial denial of plaintiff's motion for leave to amend her complaint. Plaintiff filed suit alleging that the school district was deliberately indifferent to her allegations that another student sexually assaulted her. The court could not say that the school district's response to the complaint effectively caused the first incident with plaintiff. Furthermore, the school district's response was not clearly unreasonable in light of the known circumstances and, even if the school district were deliberately indifferent, it was not deliberately indifferent to sexual harassment that was so severe, pervasive, and objectively offensive that it could be said to have deprived plaintiff of access to the educational opportunities or benefits provided by the school. Finally, the court held that the district court did not err by denying the motion to amend in order for plaintiff to add a negligence claim against the school district through a direct action against its insurance provider, because the claim was futile. View "Doe v. Dardanelle School District" on Justia Law

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The Eighth Circuit affirmed the district court's dismissal of plaintiff's Missouri state-law claims for breach of contract, breach of the implied covenant of good faith and fair dealing, and fraudulent misrepresentation against St. Louis University. Plaintiff's claims stemmed from his unsuccessful attempts to receive a Ph.D from the university in mechanical and aerospace engineering in four years. The court held that the educational malpractice doctrine barred all of plaintiff's claims. In this case, all of the statements plaintiff relied on in the student catalog and handbook were aspirational in nature. The court also held that the district court did not abuse its discretion by denying plaintiff leave to amend his complaint when he did not submit a proposed amendment or include anything in his motion to indicate what an amended complaint would contain. View "Soueidan v. St. Louis University" on Justia Law

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The Eighth Circuit affirmed the district court's judgment in favor of the school district in an action originally alleging that plaintiff's daughter, a young student with autism and significant intellectual deficits, was not provided a free appropriate public education (FAPE) under the Individuals with Disabilities Education Act (IDEA). Plaintiff also brought additional claims for constitutional violations under 42 U.S.C. 1983, disability discrimination and retaliation under section 504 of the Rehabilitation Act, disability discrimination under Title II of the Americans with Disabilities Act (ADA), and violations of Arkansas law. The court found no clear error in the district court's factual findings and gave due weight to the hearing officer's credibility determinations, concluding that the child was not denied a FAPE. The court also held that the district court did not abuse its discretion in denying plaintiff's motions for extensions of time and her motion to accept her summary judgment response out of time. The court also held that some of plaintiff's claims were barred for failure to exhaust and that her retaliation claim based on a violation of the IDEA also failed. View "Albright v. Mountain Home School District" on Justia Law

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Two male students filed suit against Minnesota's high school athletic league and others, alleging that the league unlawfully discriminated against them on the basis of sex through its rule prohibiting boys from participating on high school competitive dance teams. The Eighth Circuit reversed the district court's denial of the students' motion for preliminary injunction and directed the district court to enter a preliminary injunction. The court held that the heightened, likely-to-prevail standard did not apply to the boys' preliminary injunction motion, but instead, whether the boys have a fair chance of prevailing. On the merits, the court held that the boys had more than a fair chance of prevailing on the merits of their equal protection claim where the league has not asserted an exceedingly persuasive justification for keeping them from participating on high school competitive dance teams. Furthermore, the remaining Dataphase factors favored a preliminary injunction. View "D.M. v. Minnesota State High School League" on Justia Law

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The Eighth Circuit affirmed the district court's grant of summary judgment to the University in a Title IX action alleging that plaintiff was excluded from participation in and denied the benefits of the educational programs at the University as a result of its response to her sexual assault by another student. The court assumed, without deciding, that plaintiff's claim survived Iowa's statute of limitations and held that plaintiff's Title IX claim failed on the merits. The court held that there was no genuine dispute as to whether the University was deliberately indifferent after its investigative report concluded that plaintiff was sexually assaulted. In this case, the University was waiting to take action until the hearing process concluded and it had instituted a no-contact order between plaintiff and the other student. View "Maher v. Iowa State University" on Justia Law

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The Eighth Circuit affirmed the district court's grant of summary judgment for the school district in an action under Section 504 of the Rehabilitation Act. The court held that, where parents refuse special education services for their child under the Individuals with Disabilities Education Act (IDEA) and bring suit under another act, they must first exhaust their administrative remedies under the IDEA if the relief they seek in the suit is also available under the IDEA. Therefore, because plaintiffs failed to exhaust their administrative remedies under the IDEA in this case, the school district was entitled to summary judgment. View "E. D. v. Palmyra R-I School District" on Justia Law

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The Eighth Circuit affirmed the district court's grant of summary judgment to the school district in an action filed by plaintiffs of a student, alleging violation of the student's rights under the Rehabilitation Act when the school district failed to make reasonable accommodations for her. The court held that the parents' complaint sought relief available under the Individuals with Disabilities Education Act (IDEA) -- relief for the denial of a free and appropriate public education-- and thus they must exhaust their administrative remedies unless an exception to the exhaustion requirement applied. In this case, none of the three exceptions to the exhaustion requirement applied. Therefore, the district court properly granted summary judgment for failure to exhaust administrative remedies under the IDEA. View "Nelson v. Charles City Community School District" on Justia Law