Justia Education Law Opinion Summaries

This case started more than fifty years ago when Minnie Liddell sued to desegregate the St. Louis public school system. The NAACP joined the lawsuit, and the State of Missouri (among others) became a defendant. The parties struck a deal that lasted until 1999 when they agreed to end Missouri’s remedial obligations. The Missouri Legislature ratified the parties’ settlement agreement and created a charter-school option. A group of charter schools complained to the Missouri Legislature, which altered the funding formula in 2006. The revised formula, part of Senate Bill 287, is what has led to the current dispute. The St. Louis Public School District and one of the plaintiffs asked the district court to enforce the settlement agreement by having Missouri reimburse it for the special-sales-tax revenue it had lost under the new funding formula. The district court sided with Missouri, and both sides appealed. Plaintiffs continued to believe that the St. Louis Public School District should receive all the special-sales-tax revenue. And Missouri argued that the desegregation-spending condition finds no support in the settlement agreement.   The Eighth Circuit affirmed the district court’s judgment but vacated the part requiring charter schools to spend those funds on “desegregation measures.” The court explained that there has been no “disproportionate adverse financial impact” on the St. Louis Public School District because it never had a right to keep all the special-sales-tax revenue for itself. Moreover, the court rejected the argument that allowing charter schools to spend their money as they see fit is inconsistent with the “purpose” of the settlement agreement. View "Deric Liddell v. State of Missouri" on Justia Law

Plaintiff filed suit against the Board of Regents of the University of Minnesota (University) following the elimination of the University’s men’s gymnastics team. He then sought a preliminary injunction to reinstate the team pending the outcome of the litigation. The district court denied the motion for the preliminary injunction, finding that Plaintiff’s delay in filing for the injunction undermined his claim of irreparable harm and that the other preliminary injunction factors favored the University. Plaintiff appealed the order denying the motion for the preliminary injunction. At issue on appeal is whether Plaintiff has suffered irreparable harm, and second, whether he unreasonably delayed in bringing the claim.   The Eighth Circuit affirmed. The court explained that it has found that “delay is only significant if the harm has occurred and the parties cannot be returned to the status quo.” Here, the men’s collegiate gymnastics season begins in December at the earliest and January at the latest. The goal of a preliminary injunction is “to preserve the status quo until the merits are determined.” Given that the injunction motion was not filed until November 2021 and that the majority of the coaching staff and other gymnasts had left the University by this time, it would have been improbable, at best, for the team to have competed in the 2021–2022 season. Because Plaintiff sought an injunction after it would have been possible “to preserve the status quo,” the court held that the delay was unreasonable and that it consequently defeated Plaintiff’s goal of preventing irreparable harm. View "Evan Ng v. Board of Regents of the U of M" on Justia Law

Plaintiff States’ requested to preliminarily enjoin the United States Secretary of Education (“Secretary”) from implementing a plan to discharge student loan debt under the Higher Education Relief Opportunities for Students Act of 2003(“HEROES Act”). The States contend the student loan debt relief plan contravenes the separation of powers and violates the Administrative Procedure Act because it exceeds the Secretary’s authority and is arbitrary and capricious. The district court denied the States’ motion for a preliminary injunction and dismissed the case for lack of jurisdiction after determining none of the States had standing to bring the lawsuit.   The Eighth Circuit granted the Emergency Motion for Injunction Pending Appeal. The court concluded that at this stage of the litigation, an injunction limited to the plaintiff States, or even more broadly to student loans affecting the States, would be impractical and would fail to provide complete relief to the plaintiffs. MOHELA is purportedly one of the largest nonprofit student loan secondary markets in America. It services accounts nationwide and had $168.1 billion in student loan assets serviced as of June 30, 2022. Here the Secretary’s universal suspension of both loan payments and interest on student loans weighs against delving into such uncertainty at this stage. View "State of Nebraska v. Joseph Biden, Jr." on Justia Law

This case involves allegations that a teacher restrained, secluded, and abused her students as a teacher in a special education classroom. The students’ parents sued the teacher, along with Aberdeen School District (“ASD”) and a host of its administrative officials, on their children’s behalf under 42 U.S.C. Section 1983. The district court denied the teacher’s assertion of qualified immunity from claims for infringing the Fourth and Fourteenth Amendment rights of three students, identified as A.A., B.B., and C.C.   The Eighth Circuit affirmed the denial of qualified immunity for the teacher on the students’ Fourth Amendment claims to the extent held above. In all other respects, the court reversed the denial of qualified immunity for the teacher and the remaining ASD officials. The court explained that it found four violations of clearly established Fourth Amendment rights: (1) secluding A.A. in the little room before February 4, 2016; (2) secluding B.B. in the calm-down corner using dividers; (3) grabbing B.B.’s arms to push him into the swimming pool; and (4) pinning C.C. down to strip his clothes off. The teacher is not entitled to qualified immunity for those violations but is for all other unreasonable seizure allegations. However, the court wrote, the remaining generalized assertions of physical and verbal abuse fail to meet the high bar required for a substantive due process violation. View "Jane Doe v. Becky Guffin" on Justia Law

A child, through his parents, brought a due process challenge under the Individuals with Disabilities Education Act (IDEA), claiming that the School District failed to provide him a free appropriate public education (FAPE). An administrative law judge agreed and ordered compensatory education. The district court affirmed but reduced the compensatory education award based on the statute of limitations. The parties cross-appealed. On appeal, the Eighth Circuit found that the school provided the child with a FAPE and reversed the district court's order. View "Minnetonka Public Schools v. M.L.K." on Justia Law

The parties to this matter—Plaintiff, on behalf of her son, and the Belton School District—disagree about the appropriate school placement for Plaintiff’s son pursuant to the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. Section 1400 et seq. Plaintiff appealed the decision of the district court granting judgment on the administrative record to the District.   On appeal, Plaintiff asserts that transferring her son to Trails West would violate his right under the IDEA to be educated in the least restrictive environment (LRE). Alternatively, Plaintiff argued, if her son needs additional services, the District should provide them in her son’s current placement. Thus, the question is whether Kentucky Trail or Trails West is the LRE in which Plaintiff’s son can receive a free appropriate public education (FAPE).   The Eighth Circuit affirmed finding no clear error in the district court’s factual findings and agreed that a preponderance of the evidence supports the AHC’s conclusion that placement at Trails West respects Plaintiff’s son's rights under the IDEA. Second, although Plaintiff emphasizes the social benefit her son receives from his more integrated placement at Kentucky Trail, the evidence shows that her son receives all of his instruction in the special education classroom and eats lunch there as well, and he has contact with nondisabled peers only when passing in the hallways or at recess. Further, there was sufficient evidence to support the conclusion that placement at Trails West offers substantial benefits for Plaintiff’s son. View "J.P. v. Belton School District No. 124" on Justia Law

Plaintiffs, the Arc of Iowa and Iowa parents whose children have serious disabilities that place them at heightened risk of severe injury or death from COVID-19, filed suit to enjoin enforcement of Iowa's law prohibiting mask requirements in schools. The district court concluded that the law violated the Americans with Disabilities Act and Section 504 of the Rehabilitation Act, granting a preliminary injunction completely enjoining the law.After determining that it has jurisdiction, the Eighth Circuit held that plaintiffs are entitled to a preliminary injunction because mask requirements are reasonable accommodations required by federal disability law to protect the rights of plaintiffs' children. However, the court concluded that the injunction imposed by the district court sweeps more broadly than necessary to remedy plaintiffs' injuries. Accordingly, the court vacated in part and remanded to allow the district court to enter a tailored injunction prohibiting defendants from preventing or delaying reasonable accommodations and ensures that plaintiffs' schools may provide such reasonable accommodations. View "The Arc of Iowa v. Reynolds" on Justia Law

For budget reasons, St. Cloud State University shut down six of its sports teams, including women's tennis and Nordic Skiing teams. Female student-athletes brought a Title IX discrimination action. 20 U.S.C. 1681(a). The district court preliminarily enjoined cutting the women's teams, concluding the University failed to comply with Title IX requirements in its allocation of athletic participation opportunities and treatment and benefits for student-athletes.The Eighth Circuit reversed in part and remanded. The court upheld findings that the University uses a tier system for dividing particular teams, offering different levels of support to each tier. The University violated Title IX by not providing equitable participation opportunities for men and women. The district court erred, however, by requiring the University to provide equitable treatment and benefits “among the tiers of support,” and by mandating steps toward eliminating the unequal distribution of “participation opportunities among the tiers” rather than analyzing the institution's programs as a whole. View "Portz v. St. Cloud State University" on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983 against University officials, alleging that the University's then-existing events policy was unconstitutional facially and as applied to them under the First and Fourteenth Amendments. In this case, after Students for a Conservative Voice (SCV) brought Ben Shapiro to speak at the University, officials rejected various proposed venues for the event, citing security concerns. Ultimately, the officials approved a smaller, more remote venue than what SCV had requested.The Eighth Circuit concluded that SCV's facial challenges and requests for injunctive relief are now moot and that plaintiffs lack standing to maintain their as-applied claim. The court explained that the University's "Large Scale Event Process" policy had been replaced with a new "Major Events" policy, which was more detailed and pertains to the entirety of the University's campus, and plaintiffs failed to show that it is "virtually certain" that the prior policy will be reenacted. In regard to plaintiffs' as-applied claim, they have failed to show that the policy was in fact applied to them. The court stated that the record reflects that the officials' decisions were independent of the Large Scale Event Process and made within the scope of each officials' position at the University, but plaintiffs' complaint presents no First Amendment challenge to the officials' actions apart from the application of the now repealed policy. Accordingly, the court vacated the district court's orders with respect to those claims and remanded with instructions to dismiss without prejudice. View "Young America's Foundation v. Kaler" on Justia Law

After the school districts sought modification of existing desegregation consent decrees to allow their exemption from Arkansas's Public School Choice Act, Ark. Code. Ann. 6–18–1906, the district court granted the motions and modified the consent decrees to explicitly limit the transfer of students between school districts. The Department appealed, alleging that the modification imposed an impermissible interdistrict remedy.After a panel of the Eighth Circuit affirmed the district court's modifications, the Department moved for rehearing, at which point the United States—for the first time—involved itself in the case and asked the court to reconsider its opinion. The court accepted the invitation, received supplemental briefing from the parties, and reversed the judgment of the district court.The court agreed with the Department that the district court abused its discretion by modifying the consent decrees because the 2017 amendments were not a significant change in circumstances supporting modification of the decrees and—even if they were—the district court did not impose a suitably tailored modification. Because no vestige of discrimination traces to interdistrict school transfers, the district court abused its discretion in expanding the consent decrees to prohibit such transfers. View "United States v. Arkansas Department of Education" on Justia Law