Justia Education Law Opinion Summaries

Four female hockey players filed a lawsuit against the University of North Dakota, alleging that the university violated Title IX by eliminating the women’s ice hockey program after the 2016-17 season. None of the plaintiffs were enrolled at the university at the time of the program's termination. They sought to represent a class of current, prospective, and future female students and requested a declaratory judgment and an injunction to reinstate the women’s hockey program.The United States District Court for the District of North Dakota dismissed the case for lack of jurisdiction, finding that the plaintiffs did not demonstrate a "concrete" injury as required for standing under Article III.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court found that two plaintiffs, Calli Forsberg and Maya Tellmann, had standing. Forsberg was recruited to play for the university’s hockey team but chose another school after the program was cut. Tellmann, a two-time state hockey champion, was accepted as a student but had no opportunity to play due to the program's elimination. Both plaintiffs demonstrated a concrete injury by being denied the opportunity to compete for the team of their choice, and they expressed a definite intent to attend the university if the program were reinstated.The court found that the other two plaintiffs, Emily Becker and Morgan Stenseth, did not allege sufficient facts to establish standing. Becker did not provide details about her qualifications or acceptance to the university, and Stenseth did not express an intent to attend the university in the future.The Eighth Circuit reversed and remanded the case in part, allowing Forsberg and Tellmann’s claims to proceed, but affirmed the dismissal of Becker and Stenseth’s claims. View "Becker v. North Dakota University System" on Justia Law

The case involves several states suing the President of the United States, the Secretary of Education, and the U.S. Department of Education to prevent the implementation of a plan to forgive approximately $475 billion in federal student loan debt. The plan, known as SAVE, significantly alters the existing income-contingent repayment (ICR) plan by lowering payment amounts, often to $0 per month, and forgiving principal balances much sooner than previous plans.The United States District Court for the Eastern District of Missouri granted a preliminary injunction in part, finding that Missouri had standing through its state instrumentality, MOHELA, which faced certain irreparable harm. The court concluded that the states had a fair chance of success on the merits, particularly that loan forgiveness under SAVE was not statutorily authorized and violated the separation of powers under the major-questions doctrine. However, the court only enjoined the ultimate forgiveness of loans, not the payment-threshold provisions or the nonaccrual of interest.The United States Court of Appeals for the Eighth Circuit reviewed the case and agreed with the district court that Missouri had standing. The court found that the states demonstrated a fair chance of success on the merits, noting that the SAVE plan's scope was even larger than a previously contested loan-cancellation program. The court also found that the Government's actions had rendered the district court's injunction largely ineffective. Balancing the equities, the court decided to grant in part and deny in part the states' motion for an injunction pending appeal, prohibiting the use of the hybrid rule to circumvent the district court's injunction. The injunction will remain in effect until further order of the court or the Supreme Court of the United States. View "State of Missouri v. Biden" on Justia Law

In May 2023, Iowa's Governor signed Senate File 496 (SF496) into law, which introduced new regulations for public school libraries, classrooms, and curriculum, and required parental notification for certain gender identity accommodations. Two groups of plaintiffs, including students, authors, and educators, filed lawsuits to enjoin SF496, arguing it violated the First Amendment, the Fourteenth Amendment, and the Equal Access Act. The plaintiffs sought a preliminary injunction to prevent the law's enforcement.The United States District Court for the Southern District of Iowa granted the preliminary injunction, enjoining the enforcement of SF496's provisions related to the removal of books from school libraries and the prohibition of instruction on gender identity and sexual orientation for students in kindergarten through grade six. The court found that the plaintiffs had standing and that the law's enforcement would likely cause irreparable harm.The United States Court of Appeals for the Eighth Circuit reviewed the case and found that the district court's analysis was flawed. The appellate court held that the district court did not properly apply the legal standards for facial challenges and failed to consider the law's legitimate applications. The Eighth Circuit also noted that the district court did not adequately address the as-applied challenges raised by the plaintiffs. Consequently, the appellate court reversed the district court's decision, vacated the preliminary injunction, and remanded the case for further proceedings consistent with its opinion. The plaintiffs were allowed to pursue injunctive relief under the correct legal framework and address the unconsidered as-applied challenges. View "GLBT Youth in Iowa Schools Task Force v. Reynolds" on Justia Law

Four parents of students in the Independence School District challenged the District’s policy of removing library materials upon receiving a complaint, pending a formal review. They argued that this policy violated their children's First Amendment rights and Fourteenth Amendment due process rights. The District moved to dismiss the case.The United States District Court for the Western District of Missouri granted the District’s motion to dismiss. The court concluded that the parents failed to demonstrate an injury-in-fact necessary for standing, as their claims were based on hypothetical future challenges rather than any current or imminent harm. The court noted that the plaintiffs did not allege any ongoing or threatened challenges to library materials, nor did they challenge the removal of any specific book.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s decision. The appellate court agreed that the plaintiffs lacked standing because they did not show a concrete and particularized injury that was actual or imminent. The court emphasized that the plaintiffs’ claims were speculative, as they were based on the possibility of future book challenges and removals. The court also noted that the plaintiffs did not allege any self-censorship or chilling effect on their children’s speech due to the policy. Therefore, the court held that the plaintiffs failed to meet the requirements for pre-enforcement review and affirmed the dismissal of the case. View "L.H. v. Independence School District" on Justia Law

The case involves a group of plaintiffs who filed a civil rights action under 42 U.S.C. § 1983 against Independent School District 194 and its superintendent. The plaintiffs alleged that the defendants violated their First Amendment rights by discriminating against their political viewpoints. The controversy arose when the school district allowed the display of Black Lives Matter (BLM) posters in classrooms but rejected requests to display "All Lives Matter" and "Blue Lives Matter" posters and shirts. The district court dismissed the plaintiffs' First Amendment claims and denied the unnamed plaintiffs' motion to proceed under pseudonyms.The district court ruled that the unnamed plaintiffs had not sufficiently established a threat of a hostile public reaction to their lawsuit that would warrant anonymity. It also concluded that the BLM posters constituted government speech that is not subject to scrutiny under the First Amendment’s Free Speech Clause. The plaintiffs appealed both orders.The United States Court of Appeals for the Eighth Circuit affirmed in part, reversed in part, and remanded the case for further proceedings. The court affirmed the district court's denial of the motion to proceed under pseudonyms, finding that the unnamed plaintiffs did not provide sufficient evidence of a compelling fear of retaliation. However, the court reversed the district court's dismissal of the complaint, concluding that the plaintiffs had pleaded sufficient facts to allow a court to draw the plausible inference that the BLM posters are expressions of private persons, not government speech. The court also found that the district had engaged in viewpoint discrimination by allowing the display of BLM posters but rejecting "All Lives Matter" and "Blue Lives Matter" posters and shirts. View "Cajune v. Independent School District 194" on Justia Law

The case involves Charles and Lisa Kass, parents of Brody Kass, who sued the Western Dubuque Community School District (the District) alleging that the District violated the Individuals with Disabilities Education Act (IDEA) and other statutes when it developed Brody’s individualized education program (IEP) for the 2020–21 school year. Brody has epilepsy, autism, attention deficit/hyperactivity disorder, severe vision impairment, and intellectual disabilities. Despite Brody having enough credits to graduate, his IEP Team determined he had unmet transitional needs and should remain in school. The District proposed that Brody would not enroll in general education courses in the traditional classroom setting. Instead, Brody would spend a half-day focusing on developing his reading and math skills through individualized and practical training. The Kasses objected to the proposed IEP and filed a complaint with the Iowa Department of Education.The administrative law judge (ALJ) ruled in favor of the District on all claims, concluding the District did not violate Brody’s right to a free appropriate public education (FAPE) in the 2018–19 or 2019–20 school years. The ALJ also determined neither the draft IEP nor its development violated any procedural or substantive provisions of the IDEA. The Kasses brought this action in federal district court, alleging violations of the IDEA, the Americans with Disabilities Act (ADA), and the Rehabilitation Act. The district court affirmed the ALJ’s decision on the IDEA claims and dismissed the other claims as subsumed under the IDEA claims.The United States Court of Appeals For the Eighth Circuit affirmed the district court's decision. The court held that compensatory education may be available beyond a student’s twenty-first birthday. The court also concluded that the District complied with the IDEA’s procedural requirements in drafting the May 2020 IEP. The court found that the May 2020 IEP’s specific and measurable goals were reasonably calculated to enable Brody to progress in light of his circumstances, and thus met the IDEA’s requirements. View "Kass v. Western Dubuque Community School District" on Justia Law

Four ninth-grade football players at Park Hill High School in Kansas City, Missouri, were suspended or expelled after one of them created an online petition titled "Start Slavery Again" and the others posted comments favoring the petition. They filed a lawsuit against the Park Hill School District and various school officials, claiming that their rights to equal protection and due process were violated.In their suit, the students argued that they were deprived of substantive and procedural due process in the disciplinary procedures. They also claimed that they were deprived of equal protection because another student, who they alleged was a willing participant in creating the petition, was not punished. The U.S. District Court for the Western District of Missouri granted summary judgment for the school district, dismissing all of the students' claims.On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the lower court's decision. The appellate court found that the students received adequate notice and meaningful opportunity to present their case in the school disciplinary proceedings, satisfying the requirements of due process. The court further held that the disciplinary actions taken by the school district were not so egregious as to violate the students' substantive due process rights. Lastly, the court rejected the students' equal protection claim on the basis that the student who was not punished was not similarly situated to the plaintiffs given their greater involvement in creating and supporting the petition. View "Plaintiff A v. Park Hill School District" on Justia Law

In this case, a minor student known as A.J.T., who suffers from epilepsy, sued her school district, Osseo Area Schools, alleging disability discrimination for not providing her evening instruction sessions. A.J.T.'s epilepsy is severe in the mornings, preventing her from attending school until noon. The child's parents requested evening instruction so that she could have a school day closer in length to her peers. However, the school district denied these requests.A.J.T., through her parents, filed a lawsuit alleging violations of Section 504 of the Rehabilitation Act and the Americans with Disabilities Act (ADA). The district court granted Osseo Area Schools' motion for summary judgment, finding that the school district could not be held liable as it did not act with bad faith or gross misjudgment.The United States Court of Appeals for the Eighth Circuit affirmed the district court's decision. The court stated that while A.J.T. might have established a genuine dispute about whether the district was negligent or even deliberately indifferent, she failed to prove that school officials acted with "either bad faith or gross misjudgment." The court found that the school district did not ignore A.J.T.'s needs or delay its efforts to address them. It further held that in cases involving educational services for disabled children, mere noncompliance with applicable federal statutes or failure to provide a reasonable accommodation is not enough to trigger liability. The plaintiff must prove that the school officials acted with bad faith or gross misjudgment. In this case, A.J.T. failed to identify conduct that cleared that high bar, and as such, the court held that summary judgment was proper. View "A.J.T. v. Osseo Area Schools, Independent School District No. 279" on Justia Law

In this case, the United States Court of Appeals for the Eighth Circuit considered the appeal of Osseo Area Schools (the District) against the ruling of the district court, which held that the District had denied A.J.T., a student with a disability, a Free Appropriate Public Education (FAPE) as mandated by the Individuals with Disabilities Education Act (IDEA). A.J.T. suffers from a rare form of epilepsy, causing seizures that prevent her from attending school before noon. Consequently, her parents had requested the District to provide evening instruction, which was refused.The district court found that the District's refusal to provide A.J.T. with evening instruction resulted in her making de minimis progress overall and even regressing in some areas, such as toileting. The court also determined that A.J.T. would have made more progress had she received evening instruction. On these grounds, the court concluded that the District had failed to provide A.J.T. with a FAPE.On appeal, the Eighth Circuit affirmed the district court's judgment. The court rejected the District's argument that the IDEA's scope was limited to regular school hours, noting nothing in the IDEA suggested such a limitation. Furthermore, the court agreed with the district court's assessment of A.J.T.'s limited progress and regression in toileting. After considering the evidence, the court concluded that the District's refusal to provide evening instruction, based solely on administrative concerns, resulted in A.J.T.'s minimal progress and denied her a FAPE. View "Osseo Area Schools, Independent School District No. 279 v. A.J.T." on Justia Law

In a case before the United States Court of Appeals for the Eighth Circuit, the plaintiffs, The Arc of Iowa and several parents of children with disabilities, sought to challenge a provision of the Iowa Code that prevents schools from imposing mask mandates unless required by other laws. They had received a preliminary injunction from a lower court that had been vacated by this court due to changing circumstances related to the COVID-19 pandemic. On remand, the district court granted the plaintiffs' motion for summary judgment, declaring that the phrase 'other provisions of law' in the contested Iowa Code section includes Title II of the Americans with Disabilities Act (ADA) and section 504 of the Rehabilitation Act, and that the contested Iowa Code section cannot be cited as the sole basis for denying a student's request for reasonable modification or accommodation under the ADA or the Rehabilitation Act that requires others to wear masks.The defendants, the Governor of Iowa and the Director of the Iowa Department of Education, appealed to the Eighth Circuit, raising issues of exhaustion of remedies under the Individuals with Disabilities Act (IDEA), standing of the plaintiffs, and the propriety and necessity of the relief granted by the district court.The appellate court, after de novo review, found that the plaintiffs failed to meet the requirements for standing, which include having suffered an injury in fact, traceability of the injury to the defendant's conduct, and the likelihood of redress by a favorable judicial decision. The court found that the general risks associated with COVID-19 were not enough to constitute "imminent and substantial" harm for standing. It also concluded that the plaintiffs had not demonstrated that the alleged injuries were fairly traceable to the conduct of the Governor or the Director of the Department of Education. As a result, the court vacated the district court's order and remanded the case with instructions to dismiss due to lack of standing. View "The Arc of Iowa v. Reynolds" on Justia Law