Justia Education Law Opinion Summaries

A former public school principal in Brooklyn, New York, brought a lawsuit against the New York City Department of Education (DOE) and its former chancellor, alleging retaliation after she complained about racially segregated sports teams at her school. The principal claimed that the DOE's investigation into her was a retaliatory action for her complaints about race discrimination affecting her students.The United States District Court for the Southern District of New York dismissed the principal's Title VI claim, reasoning that her challenge was related to an employment practice and that the primary objective of the federal funds received by the DOE was not to provide employment. The court also denied her motion for leave to amend her complaint, even after reconsidering its initial decision.The United States Court of Appeals for the Second Circuit reviewed the case and held that the principal's retaliation claim was not an action "with respect to any employment practice" under Title VI because her underlying protected activity was unrelated to the DOE’s employment practices. The court concluded that Title VI does provide a private right of action for retaliation claims when the retaliation is for opposing non-employment-related race discrimination. The court affirmed the dismissal of the claim against the former chancellor but vacated the dismissal of the Title VI claim against the DOE and remanded the case for further proceedings. View "Bloomberg v. N.Y.C. Department of Education" on Justia Law

A coalition of organizations and individuals, led by the Chinese American Citizens Alliance of Greater New York, filed a lawsuit against New York City's Mayor and Department of Education Chancellor. They challenged the revised admissions policy for the Discovery Program in the Specialized High Schools (SHSs), alleging it was intended to discriminate against Asian-American applicants by reducing their admission rates. The plaintiffs argued that the new policy, which included an Economic Need Index (ENI) criterion, negatively impacted Asian-American students.The United States District Court for the Southern District of New York granted summary judgment in favor of the City. The court concluded that the plaintiffs failed to demonstrate an aggregate disparate impact on Asian-American students, as required under Village of Arlington Heights v. Metropolitan Housing Development Corp. The court held that without showing a group-wide effect, the plaintiffs could not establish the necessary discriminatory effect for an equal protection claim.The United States Court of Appeals for the Second Circuit reviewed the case. The court assumed, for the purpose of the appeal, that the plaintiffs could prove the policy changes were made with discriminatory intent. The court concluded that the district court erred in requiring an aggregate disparate impact to establish discriminatory effect. Instead, the court held that if discriminatory intent is proven, a negative effect on individual Asian-American students would suffice to trigger strict scrutiny review. The court found that the exclusion of economically disadvantaged Asian-American students from certain middle schools due to the new ENI criterion constituted a sufficient discriminatory effect. Consequently, the Second Circuit vacated the district court's grant of summary judgment and remanded the case for further proceedings. View "Chinese Am. Citizens All. of Greater N.Y. v. Adams" on Justia Law

Jason Doherty, a former student at Purchase College, State University of New York, who has Asperger Syndrome, sued several administrators of the college under the Americans with Disabilities Act (ADA) for declaratory and injunctive relief and emotional distress damages. The lawsuit was initiated after the college issued no-contact orders against Doherty at the request of three other students during his freshman orientation in August 2017.The United States District Court for the Southern District of New York dismissed Doherty's claims, ruling that it lacked subject matter jurisdiction over his claims for declaratory and injunctive relief since they were moot, and that Doherty failed to state a claim for damages because emotional distress damages are not available under Title II of the ADA. The district court based its decision on the Supreme Court’s ruling in Cummings v. Premier Rehab Keller, P.L.L.C., which held that emotional distress damages are not available under the Rehabilitation Act, a law that Title II of the ADA explicitly tracks.On appeal, the United States Court of Appeals for the Second Circuit affirmed the district court's decision. The appellate court agreed that Doherty's claims for declaratory and injunctive relief were moot given that the no-contact orders were not disciplinary actions, were not part of his permanent record, and expired upon his graduation. The court also agreed that emotional distress damages are not available under Title II of the ADA, which explicitly tracks the remedies, procedures, and rights available under the Rehabilitation Act. Finally, the court ruled that Doherty had forfeited any claims for other damages. View "Doherty v. Bice" on Justia Law

The case involves Jane Doe, who sued the Franklin Square Union Free School District on behalf of herself and her minor daughter, Sarah Doe. The lawsuit was filed after the school district refused to grant Sarah an exemption from a school mask mandate implemented in response to the COVID-19 pandemic. Jane Doe argued that the school district violated the Due Process Clause of the Fourteenth Amendment and her claims under the Americans with Disabilities Act (ADA) and § 504 of the Rehabilitation Act.The United States District Court for the Eastern District of New York dismissed Jane Doe's constitutional claim, concluding that the school district's conduct survived rational basis review. The court also dismissed her federal statutory claims for failure to exhaust administrative remedies under the Individuals with Disabilities Education Act (IDEA).On appeal, the United States Court of Appeals for the Second Circuit concluded that the school district did not violate Jane Doe or Sarah’s constitutional rights by denying their request for an accommodation. However, the court agreed with Jane Doe that she was not required to satisfy the exhaustion requirement of the IDEA and held that the district court erred in dismissing Jane Doe’s ADA and § 504 claims. The court affirmed in part and reversed in part the judgment of the district court and remanded the case for further proceedings. View "Doe v. Franklin Square Union Free Sch. Dist." on Justia Law

In the United States Court of Appeals for the Second Circuit, the appellant, Brittany Jones, claimed she was sexually abused by a teacher between 2009 and 2011, when she was a high school student. She brought her claims under the Child Victims Act (CVA) of New York, which revived time-barred claims of child sexual abuse victims, and provided a two-year window from August 14, 2019 to August 14, 2021 for the filing of such claims. However, Jones filed her suit four months before the commencement of this window. The United States District Court for the Western District of New York, in a summary judgment, ruled in favor of the school district, holding that Jones's premature filing created a valid statute-of-limitations defense for the school district.This decision was appealed and the key question before the appellate court was whether the six-month waiting period created by the CVA was a statute of limitations. The appellate court concluded that neither the text of the CVA nor any precedent from New York courts provided clear guidance on this issue. Given the significant state policy interests implicated by the CVA, the appellate court decided to certify the question to the New York Court of Appeals: whether the six-month waiting period for claims under the CVA establishes a statute of limitations, a condition precedent to bringing suit, or some other affirmative defense. The court reserved its decision on the appeal pending the response from the New York Court of Appeals. View "Jones v. Cattaraugus-Little Valley Central School District" on Justia Law

This case is about a dispute between Richard Roe and St. John’s University (SJU) and Jane Doe. Roe, a male student at SJU, was accused of sexually assaulting two female students, Doe and Mary Smith, on separate occasions. SJU's disciplinary board found Roe guilty of non-consensual sexual contact with both Doe and Smith and imposed sanctions, including a suspension and eventual expulsion. Roe then sued SJU, alleging that his rights under Title IX of the Education Amendments of 1972 and state contract law had been violated. He also sued Doe for allegedly defaming him in an anonymous tweet accusing him of sexual assault. The United States District Court for the Eastern District of New York dismissed Roe's Title IX and state law claims, and declined to exercise jurisdiction over his defamation claim. On appeal, the United States Court of Appeals for the Second Circuit affirmed the district court's decision, holding that Roe's complaint failed to state a plausible claim of sex discrimination under Title IX. The court found that, while Roe had identified some procedural irregularities in SJU's disciplinary proceedings, these were not sufficient to support a minimal plausible inference of sex discrimination. Furthermore, the court ruled that Roe's hostile environment claim was fatally deficient, as the single anonymous tweet at the center of his claim was not, standing alone, sufficiently severe to support a claim of a hostile educational environment under Title IX. View "Roe v. St. John's University" on Justia Law

The United States Court of Appeals for the Second Circuit ruled that a group of non-transgender female athletes have legal standing to challenge a policy that allows transgender girls to compete in girls' high school sports. The athletes had sued the Connecticut Association of Schools and several school districts, claiming that the policy violated Title IX by depriving them of equal athletic opportunity. The court held that the athletes had established Article III standing because they had plausibly stated a concrete, particularized, and actual injury in fact - the alleged denial of equal athletic opportunity and concomitant loss of publicly recognized titles and placements during track and field competitions in which they competed against and finished behind transgender athletes. The court also held that the injury was plausibly redressable by monetary damages and an injunction ordering defendants to alter certain athletic records. The court did not rule on the merits of the athletes' Title IX claim, instead remanding the case to the district court for consideration of whether the athletes have plausibly stated a claim under Title IX. View "Soule ex rel. Stanescu v. Connecticut Association of Schools, Inc." on Justia Law

The United States Court of Appeals for the Second Circuit affirmed the judgment of the United States District Court for the Southern District of New York in the case of a student, Brett Goldberg, against Pace University. Goldberg, a graduate student in performing arts, sued Pace for breach of contract, unjust enrichment, promissory estoppel, and violation of New York General Business Law § 349, following the university's decision to move classes online and postpone the performance of his play and a class due to the COVID-19 pandemic. The district court granted Pace's motion for judgment on the pleadings, holding that Goldberg failed to sufficiently allege a breach given the university's published Emergency Closings provision and failed to identify a sufficiently specific promise under New York law of in-person instruction. The court also found that Goldberg's unjust enrichment, promissory estoppel, and § 349 claims were either duplicative or failed for similar reasons. On appeal, the Second Circuit agreed with the lower court, holding that the university's postponement and move to an online format were permitted by the Emergency Closings provision, thus affirming the district court's judgment. View "Goldberg v. Pace University" on Justia Law

Appellants in these tandem appeals are each a parent of a disabled child. Arguing that his or her child was entitled to benefits under the Individuals with Disabilities Education Act (“IDEA”), 20 U.S.C. Section 1415(i), each parent brought an administrative action against his or her local education agency and prevailed. Subsequently, each parent brought a federal action for attorneys’ fees pursuant to 20 U.S.C. Section 1415(i)(3)(B). In each case, the district court awarded less attorneys’ fees than the parent requested, and the parents appealed.   The Second Circuit reversed the district court’s denial of travel-related fees in No. 21-1961 and remanded for further proceedings. The court otherwise affirmed the judgments of the district courts. The court found that it was persuaded that there was no abuse of discretion in the district court’s calculation of reasonable attorneys’ fees in each case. Further, the court wrote that the district courts that declined to award prejudgment interest did not abuse their discretion because “delays in payment” may be remedied by “application of current rather than historic hourly rates.” However, the court held that the district court abused its discretion when it denied any travel-related fees to M.D.’s counsel. A district court may permissibly adjust excessive travel costs. But the district court could not “eliminate all of the hours submitted by [CLF] as travel time” by denying travel-related fees altogether. View "H.C. v. NYC DOE, et al." on Justia Law

Parents and guardians of students with disabilities brought an enforcement action under the Individuals with Disabilities Education Act, alleging that the New York City Department of Education must immediately fund their children’s educational placements during the pendency of ongoing state administrative proceedings. Plaintiffs moved for a preliminary injunction, which the district court denied. Plaintiffs appealed from that denial.   The Second Circuit affirmed. As a threshold jurisdictional matter, the court held that although the Plaintiffs are not yet entitled to tuition payments for the portion of the school year that has yet to occur, their claims are nevertheless ripe because they also seek payments for past transportation costs. On the merits, the court held that the IDEA’s stay-put provision does not entitle parties to automatic injunctive relief when the injunctive relief concerns only educational funding, not placement. Applying the traditional preliminary injunction standard, the court concluded that Plaintiffs are not entitled to the relief they seek because they have not shown a likelihood of irreparable injury. View "Mendez v. Banks" on Justia Law