Justia Education Law Opinion Summaries

John Doe 2, a student athlete at North Carolina State University, alleged that he was sexually abused by Robert Murphy, the university’s Director of Sports Medicine, under the guise of medical treatment. Doe claimed that the university was deliberately indifferent to prior complaints of Murphy’s sexual misconduct. The district court dismissed Doe’s complaint, finding that he failed to plead facts supporting an inference that the university had actual notice of Murphy’s sexual harassment.The United States District Court for the Eastern District of North Carolina dismissed the complaint under Federal Rule of Civil Procedure 12(b)(6). The court concluded that a report of “sexual grooming” could not provide actual notice to the university of sexual harassment. The district court assumed without deciding that the report was made to an official with the requisite authority for Title IX purposes but found that the report did not describe an incident of sexual harassment and thus could not support a plausible inference of actual notice.The United States Court of Appeals for the Fourth Circuit reviewed the case and vacated the district court’s judgment. The Fourth Circuit held that a report of “sexual grooming” can objectively be construed as alleging sexual harassment, thus providing actual notice to the university. The court found that the district court erred in its conclusion and remanded the case for further proceedings to determine whether the report was made to an appropriate official with the authority to address complaints of sexual harassment and to institute corrective measures on behalf of the university. View "John Doe 2 v. North Carolina State University" on Justia Law

Davina Ricketts, a sophomore at a high school in North Carolina, decided to run for student council to address its lack of diversity. She faced racial harassment and cyberbullying from peers, and the school district allegedly failed to intervene. Ricketts filed a lawsuit claiming the school district was deliberately indifferent to her harassment. The district court dismissed her complaint and denied her motion to amend, stating her proposed amended complaint also failed to state a claim. Ricketts appealed the denial of her motion for leave to amend.The United States District Court for the Eastern District of North Carolina initially dismissed Ricketts' complaint and denied her motion to amend on futility grounds. The court reasoned that her proposed amended complaint did not sufficiently state claims for deliberate indifference, retaliation, or equal protection violations.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court found that Ricketts sufficiently alleged deliberate indifference, retaliation, and equal protection claims. The court held that Ricketts' allegations of racial harassment, the school administrators' authority and actual knowledge of the harassment, and their deliberate indifference were sufficient to state a Title VI claim. The court also found that Ricketts sufficiently alleged retaliation by showing she engaged in protected activity, faced materially adverse actions, and established a causal connection between the two. Additionally, the court held that Ricketts sufficiently alleged an equal protection claim against individual defendants and the Board of Education by showing discriminatory intent and a municipal custom or policy of indifference.The Fourth Circuit reversed the district court's judgment, directed the district court to allow Ricketts to amend her complaint, and remanded the case for further proceedings. View "Ricketts v. Wake County Public School System" on Justia Law

R.A. filed a lawsuit against her son G.A.'s special education teacher, Robin Johnson, and several school officials, alleging that Johnson mistreated G.A. during the first and second grades. The complaint claimed that Johnson subjected G.A. to physical and emotional abuse and that the school officials negligently failed to intervene despite knowing about the abuse. The school officials moved to dismiss the negligence claims, arguing they were protected by public official immunity. The district court denied the motion, and the school officials filed an interlocutory appeal.The United States District Court for the Western District of North Carolina initially denied the school officials' motion to dismiss the state law claims, leading to an appeal. The Fourth Circuit Court of Appeals previously ruled that the school officials were entitled to public official immunity and that the state law claims against them should be dismissed. Despite this, the district court allowed R.A. to file an amended complaint with additional details from new evidence, which the school officials again moved to dismiss. The district court denied this motion, interpreting the appellate mandate as allowing dismissal without prejudice.The Fourth Circuit Court of Appeals reviewed the case again and held that the district court violated the mandate rule by not dismissing the claims with prejudice as instructed. The appellate court emphasized that its prior decision required dismissal with prejudice and that the district court's interpretation was incorrect. The court reiterated that the mandate rule requires lower courts to follow the appellate court's instructions precisely and that no exceptions to the mandate rule applied in this case. Consequently, the Fourth Circuit reversed the district court's decision, reaffirming that the state law claims against the school officials must be dismissed with prejudice. View "R.A. v. McClenahan" on Justia Law

Two students receiving special education services filed a class action lawsuit against the Kanawha County Board of Education, alleging that the Board denied them and other similarly situated students a free appropriate public education (FAPE) as guaranteed by the Individuals with Disabilities Education Act (IDEA). The lawsuit also claimed violations of Title II of the Americans with Disabilities Act (ADA) and Section 504 of the Rehabilitation Act. The district court certified a class of all Kanawha County Schools students with disabilities who need behavior supports and have experienced disciplinary removals from any classroom.The United States District Court for the Southern District of West Virginia granted the plaintiffs' motion to certify the class, reasoning that the plaintiffs had presented expert evidence of disproportionate rates of suspension for students with disabilities and a detailed qualitative analysis of student records. The court found that these factors revealed a cohesive pattern indicating the absence of an effective system for developing and implementing behavioral supports for students with disabilities. The Board appealed, arguing that the certification of the plaintiff class was inconsistent with Federal Rules of Civil Procedure 23(a) and (b)(2).The United States Court of Appeals for the Fourth Circuit reviewed the case and reversed the district court’s certification order. The Fourth Circuit held that the certified class failed to satisfy Rule 23(a)(2)’s commonality prerequisite. The court found that the plaintiffs did not identify a common contention central to the validity of all class members’ claims. The court noted that the claims were highly diverse and individualized, involving different practices at different stages of the special education process. The absence of a common contention foreclosed class treatment. The case was remanded for further proceedings consistent with the opinion. View "G.T. v. The Board of Education of the County of Kanawha" on Justia Law

G.M., a second-grade student with dyslexia and ADHD, was deemed ineligible for special education by Howard County Public Schools (HCPS) under the Individuals with Disabilities Education Act (IDEA). His parents, disagreeing with this determination, pursued the IDEA’s dispute resolution process, which included a state administrative hearing. The administrative law judge (ALJ) sided with HCPS, leading G.M.’s parents to file a lawsuit in federal district court. The district court upheld the ALJ’s decision, prompting an appeal to the United States Court of Appeals for the Fourth Circuit.The ALJ conducted a six-day hearing, considering evidence from both sides. G.M.’s parents presented private evaluations indicating deficiencies in reading and writing, while HCPS provided assessments showing average performance. The ALJ found HCPS’s evidence more persuasive, concluding that G.M. did not exhibit a pattern of strengths and weaknesses necessary to qualify as having a specific learning disability (SLD) under the IDEA. The ALJ also determined that although G.M. had an other health impairment (OHI) due to ADHD, he did not need special education because he was performing adequately relative to grade-level standards.The United States Court of Appeals for the Fourth Circuit affirmed the district court’s judgment. The court held that the ALJ’s factual findings and credibility determinations were regularly made and thus entitled to deference. The court agreed that G.M. did not qualify as a “child with a disability” under the IDEA because he did not exhibit the necessary pattern of strengths and weaknesses in reading and writing, and his ADHD did not necessitate special education. The court also found that G.M. received a free appropriate public education (FAPE) without special education services, as he was achieving passing marks and advancing from grade to grade. Consequently, HCPS did not substantively violate the IDEA, and G.M. was not entitled to the requested relief. View "G.M. v. Barnes" on Justia Law

A group of parents in Montgomery County, Maryland, challenged the local school board's decision to include LGBTQ-inclusive books in the English Language Arts curriculum without providing parents notice or the option to opt their children out of exposure to these books. The parents, who held various religious beliefs, argued that the board's decision violated their rights under the Free Exercise and Due Process Clauses of the U.S. Constitution.The United States District Court for the District of Maryland denied the parents' motion for a preliminary injunction, which would have required the board to provide notice and an opt-out option. The parents appealed this decision to the United States Court of Appeals for the Fourth Circuit.The Fourth Circuit affirmed the district court's decision. The court found that the parents had not shown a likelihood of success on the merits of their claims, a necessary requirement for a preliminary injunction. Specifically, the court found that the parents had not provided sufficient evidence to show that the board's decision coerced them or their children to act or believe contrary to their religious faith. The court also found that the parents had not shown that their due process rights were likely to be violated. The court noted that the parents still had the right to instruct their children on their religious beliefs and to discuss the topics raised in the books with their children. View "Mahmoud v. McKnight" on Justia Law

A West Virginia law, known as the "Save Women's Sports Act," stipulates that athletic teams or sports designated for females, women, or girls shall not be open to students of the male sex, with "male" defined as an individual whose biological sex determined at birth is male. The law was challenged by a 13-year-old transgender girl, B.P.J., who has been taking puberty-blocking medication and has publicly identified as a girl since the third grade. B.P.J. argued that the law violated the Equal Protection Clause and Title IX by preventing her from participating in her school's cross country and track teams.The United States District Court for the Southern District of West Virginia initially granted a preliminary injunction, allowing B.P.J. to participate in her school's sports teams. However, upon review of cross-motions for summary judgment, the court reversed its decision, rejecting B.P.J.'s claims and ruling that the law was constitutional and did not violate Title IX.On appeal, the United States Court of Appeals for the Fourth Circuit disagreed with the lower court's decision. The appellate court held that the law could not lawfully be applied to prevent B.P.J. from participating in her school's sports teams. The court found that the law's sole purpose and effect were to prevent transgender girls from playing on girls' teams, which was not substantially related to an important government interest. The court also found that the law violated Title IX by treating B.P.J. worse than people to whom she was similarly situated, depriving her of any meaningful athletic opportunities, and doing so on the basis of sex. The court dismissed the cross-appeal, vacated in part, reversed in part, and remanded the case with instructions to enter summary judgment for B.P.J. on her Title IX claims. View "B.P.J. v. West Virginia State Board of Education" on Justia Law

In a case before the United States Court of Appeals for the Fourth Circuit, a private school, Concordia Preparatory School, was sued by a student and her mother for alleged violations of Title IX of the Education Amendments of 1972, which prohibits sex-based discrimination in federally-funded educational programs. The plaintiffs claimed that the school's tax-exempt status under 26 U.S.C. § 501(c)(3) constituted federal financial assistance, thus making it subject to Title IX.The school moved to dismiss the claim, arguing that it did not receive federal financial assistance and was therefore not subject to Title IX. The district court denied the school's motion, agreeing with the plaintiffs that the school's tax-exempt status constituted federal financial assistance for Title IX purposes. However, the court certified an interlocutory appeal on this issue.Upon review, the Fourth Circuit Court of Appeals disagreed with the district court's interpretation. The appellate court reasoned that while tax exemption is a benefit, it is not equivalent to "receiving Federal financial assistance" as required by Title IX. The court explained that the term "assistance" implies aid, help, or support, which suggests a grant of funds. Tax exemption, however, is merely the withholding of a tax burden rather than an affirmative grant of funds. Furthermore, the court distinguished tax exemption from the indirect receipt of federal funds as was the case in Grove City College v. Bell.As such, the Fourth Circuit reversed the district court's decision and held that tax-exempt status does not equate to "receiving Federal financial assistance" for purposes of Title IX. The case was remanded for further proceedings. View "Buettner-Hartsoe v. Baltimore Lutheran High School Association" on Justia Law

In this case, the United States Court of Appeals for the Fourth Circuit was asked to determine the constitutionality of a process for selecting a student member of a county school board in Howard County, Maryland. Two parents sued the board, arguing that allowing public-school students to elect the student member diminishes adults’ voting power, violating the Equal Protection Clause, and that the selection process violates the Free Exercise Clause as it excludes students who opt not to attend public schools, including those who do so for religious reasons.The court affirmed the dismissal of both claims. It held that the selection process was "basically appointive rather than elective," therefore, the one-person, one-vote principle derived from the Equal Protection Clause was not applicable. The court also found that the selection process was neutral and generally applicable, thus it did not violate the Free Exercise Clause. The process excluded students who chose not to attend public school for any reason, not just those who did so for religious reasons. View "Kim v. Board of Education of Howard County" on Justia Law

A former medical student at the University of Virginia School of Medicine, Kieran Bhattacharya, sued multiple university officials, alleging they reprimanded, suspended, and expelled him in violation of the First Amendment because of his views expressed during a faculty panel on microaggressions. The officials asserted that they took these actions due to Bhattacharya’s confrontational and threatening behavior.The United States District Court for the Western District of Virginia held that Bhattacharya could not provide evidence that the officials punished him due to his speech, siding with the officials. Bhattacharya appealed to the United States Court of Appeals for the Fourth Circuit.The Fourth Circuit affirmed the district court's decision. The court held that Bhattacharya failed to present evidence sufficient to create a triable issue as to whether his speech caused the actions taken against him. The court found that the university's administrators appropriately exercised their authority to ensure the safety of the school’s faculty and staff. The court also affirmed the district court's denial of Bhattacharya's request to amend his complaint to add a conspiracy claim and the dismissal of his due process claim. View "Bhattacharya v. Murray" on Justia Law