Justia Education Law Opinion Summaries

The case involves Shannon Blick, a former principal of an elementary school in the Ann Arbor Public School District. In 2019, Blick was placed on paid leave while the school district investigated her role in a custodian's over-billing scheme. The leave lasted two years, and the school district eventually terminated Blick's contract. Blick filed a lawsuit while still on leave, alleging that various officials violated her freedoms of speech and association under the First Amendment. She also brought race-discrimination, due-process, and conspiracy claims against these officials. The district court rejected Blick's First Amendment claims at the summary-judgment stage and dismissed the other claims on the pleadings.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court's decision. The court found that Blick failed to show a reversible error. She argued that the school district violated the First Amendment by imposing a prior restraint that barred her from speaking during her leave and by taking harmful actions against her in retaliation for her speech. However, the court found that Blick's lawyers did not provide sufficient information about what she wanted to say or what she did say. The court also found that Blick's opening brief did not preserve her challenges to much of the district court's motion-to-dismiss decision. As a result, the court affirmed the district court's decision. View "Blick v. Ann Arbor Public School District" on Justia Law

The case involves Benjamin Stanley, who was employed by Western Michigan University (WMU) for about a month before his employment was terminated. Stanley, who has severe ADHD, claimed that WMU and certain supervisors discriminated and retaliated against him in violation of the Americans with Disabilities Act (ADA). He also brought a claim under Michigan’s Persons with Disabilities Civil Rights Act (PWDCRA), as well as a claim for intentional infliction of emotional distress. The district court dismissed Stanley’s federal claims for lack of subject-matter jurisdiction based on Eleventh Amendment immunity and dismissed his state-law claims for failure to comply with the Michigan Court of Claims Act’s notification statute.The district court's dismissal of Stanley's claims was appealed to the United States Court of Appeals for the Sixth Circuit. The appellate court affirmed the district court’s dismissal of Stanley’s federal claims and the denial of Stanley’s motion for leave to amend his complaint. However, the court vacated the judgment in part and remanded to the district court to dismiss Stanley’s federal and state-law claims without prejudice. The court found that the district court lacked subject-matter jurisdiction to adjudicate Stanley’s ADA claims because the defendants were entitled to Eleventh Amendment immunity, and Stanley lacked standing to request injunctive relief from the individual defendants. The court also found that the district court lacked jurisdiction to decide Stanley’s state-law claims because it lacked subject matter jurisdiction over any federal issues. View "Stanley v. Western Michigan University" on Justia Law

A group of twenty states sued the U.S. Department of Education and other federal entities, challenging the Department's interpretation of Title IX to prohibit discrimination based on sexual orientation and gender identity in education programs receiving federal financial assistance. The states argued that the Department's interpretation, issued without undergoing the notice-and-comment process required for legislative rules under the Administrative Procedure Act (APA), was procedurally and substantively unlawful.The U.S. District Court for the Eastern District of Tennessee granted the states a preliminary injunction, halting the enforcement of the Department's interpretation. The Department appealed, arguing that the states lacked standing, the interpretation was unreviewable, and the district court abused its discretion in issuing the injunction.The U.S. Court of Appeals for the Sixth Circuit affirmed the district court's decision. The court found that the states had standing to sue, the Department's interpretation was reviewable, and the states were likely to succeed on their claim that the interpretation was a legislative rule that should have undergone the notice-and-comment process. The court also found that the states would likely suffer irreparable harm without the injunction, the balance of equities tipped in their favor, and the public interest favored the injunction. View "Tennessee v. Department of Education" on Justia Law

The case involves the Mackinac Center for Public Policy and the Cato Institute (Plaintiffs) who sued the U.S. Department of Education and its officials (Defendants) over a one-time account adjustment announced by the Department. The adjustment was intended to count months or years that student-loan borrowers spent in excessive forbearance status towards debt forgiveness. The Plaintiffs, being nonprofit, tax-exempt organizations and qualified public service employers under the Public Service Loan Forgiveness (PSLF) program, argued that this adjustment would harm their ability to recruit and retain employees.The case was initially heard in the United States District Court for the Eastern District of Michigan, where the court dismissed the Plaintiffs' complaint for lack of subject-matter jurisdiction, concluding that the Plaintiffs lacked standing. The Plaintiffs appealed this decision.The United States Court of Appeals for the Sixth Circuit affirmed the lower court's decision. The court held that the Plaintiffs failed to demonstrate that they suffered an injury in fact, a requirement for establishing standing. The court rejected the Plaintiffs' arguments that they had competitor standing and that they were deprived of a procedural right. The court found that the Plaintiffs' claims were speculative and unsupported by specific facts. Consequently, the court affirmed the dismissal of the Plaintiffs' complaint for lack of subject-matter jurisdiction. View "Mackinac Center for Public Policy v. Cardona" on Justia Law

A medical resident, Dr. Jacquelyn Mares, was dismissed from Wright State University’s (WSU) obstetrics and gynecology residency program due to ongoing complaints and escalating disciplinary actions related to her unprofessional behavior. Following her dismissal, Mares was also terminated from her position at Miami Valley Hospital, where she was employed during her residency. As a result, Mares sued WSU, the hospital, its owner-operator Premier Health Partners, and several WSU employees, alleging violations of her procedural and substantive due process rights, as well as various contract-based state law claims. The district court granted summary judgment to the defendants.In its ruling, the United States Court of Appeals for the Sixth Circuit held that WSU did not violate Mares' procedural due process rights when it dismissed her from the residency program. The court found that WSU had followed its internal procedures closely and that Mares was afforded more than enough process. Also, the court held that WSU did not violate Mares' substantive due process rights. It determined that WSU's decision to dismiss her was not arbitrary or capricious, nor was it conscience-shocking. Finally, the court held that Miami Valley Hospital did not breach its contractual duties when it terminated Mares after her dismissal from WSU’s residency program. The court concluded that the hospital acted within the scope of the employment contract. Therefore, the court affirmed the district court’s decision to grant the defendants' summary judgment. View "Mares v. Miami Valley Hospital" on Justia Law

The case involves a dispute between a family and a school district regarding the provision of special education services under the Individuals with Disabilities Education Act (IDEA). The student, Jeremy Holland, who suffers from various learning impediments, had an individualized education plan developed by the Kenton County School District. This plan included special education teachers accompanying Jeremy to some of his classes at his high school and providing him with behavioral instruction at the end of the school day. For his senior year, Jeremy's family decided to enroll him full-time at a local community college and argued that the IDEA required the school district to provide the same level of support and special education services at the college. The school district disagreed, contending that the IDEA did not impose such an obligation.The United States Court of Appeals for the Sixth Circuit held in favor of the school district. The court determined that the IDEA does not require a school district to provide special education services at the post-secondary level after a student graduates from high school, nor does it require the school district to provide the same services to high school students when they enroll in dual-credit courses offered at post-secondary institutions. The court found that Jeremy's education at the community college was post-secondary, not secondary, and therefore the IDEA did not apply. Additionally, the court found that the school district did not violate the terms of Jeremy's individualized education plan, as the plan did not indicate that Jeremy would receive services at any place other than his high school. The court affirmed the district court's granting of summary judgment in favor of the school district. View "Holland v. Kenton Cnty. Public Schs." on Justia Law

In the case involving a high school student, Jacob Bradley, and his parents, the United States Court of Appeals for the Sixth Circuit concluded that the Individuals with Disabilities Education Act (IDEA) does not require states to provide special education services to students participating in dual-credit or dual-enrollment programs offered at postsecondary institutions.Jacob Bradley, a gifted student with several physical and cognitive conditions, was enrolled in the Craft Academy for Excellence in Science and Mathematics, a state-run dual-credit program located at Morehead State University. His parents sought reimbursement for special education support accommodations provided at Craft under IDEA. However, the district court ruled that IDEA, which offers federal funds to states to provide free appropriate public education to students with disabilities, does not apply to Craft because its dual-credit classes provide postsecondary rather than secondary school education.The Court of Appeals affirmed this decision, holding that the IDEA’s obligation to provide a "free appropriate public education" applies to "secondary," not postsecondary, education. The court also noted that, under Kentucky law, Craft is considered a postsecondary school because it delivers a college-level course of study on a college campus.The court also concluded that the state and federal agencies' interpretation of the IDEA and the state law, which excluded dual-credit courses at postsecondary institutions from IDEA’s mandate, was correct. The court emphasized that the IDEA is a spending clause legislation that operates as a contract between the federal government and states, and states need to comply only with clearly written terms in the Act, not uncertain or ambiguous ones.Additionally, the court affirmed the dismissal of the Bradleys' claims under the Americans with Disabilities Act and Section 504 of the Rehabilitation Act, as they failed to demonstrate how the Commonwealth separately violated the provisions of these distinct Acts.In conclusion, the court held that the IDEA does not obligate Kentucky school districts to provide special education services to a student participating in dual-credit classes offered at a postsecondary institution. The court also affirmed the dismissal of the Bradleys' claims under the Americans with Disabilities Act and Section 504 of the Rehabilitation Act. View "Bradley v. Jefferson Cnty. Public Schs." on Justia Law

Bradley Peterson, a former professor at Ohio State University, claimed his procedural-due-process rights were violated when the university stripped him of his emeritus status without adequate process. Following a sexual harassment complaint against him, the university conducted an investigation, concluded that Peterson violated the university's Sexual Misconduct Policy, and subsequently revoked his emeritus status. Peterson argued that he had a property interest in his emeritus status and its related benefits. The United States Court of Appeals for the Sixth Circuit, however, affirmed the district court's decision to dismiss Peterson's complaint. The court held that Peterson failed to establish a constitutionally protected property interest in his emeritus status. The court noted that emeritus status was an honorific title, and Peterson did not show that he lost pay or tangible benefits from Ohio State when his emeritus status was revoked. The court also noted that Peterson's claim of harm to his professional reputation was akin to a liberty interest claim, and he did not request a name-clearing hearing, which was a prerequisite for asserting such a claim. View "Peterson v. Johnson" on Justia Law

S.C., a high school freshman, was unwillingly video-recorded engaging in non-consensual sexual activity with a male student on school property. The video was shared online and other students began to harass S.C. Students then began harassing and threatening S.C. and her family. S.C. and her mother met with Detective, Carrigan, who assumed the video-recording and sexual encounter were consensual and repeatedly rejected S.C.’s statements and information about the threats, suggesting that S.C. had participated in producing child pornography. Following another meeting, Principal Kessler denied being informed that the encounter was not consensual or of any harassment, although a list of students making threats was found in Kessler’s file. Kessler suspended S.C., after which she was expected to return to school. The Assistant Principal also declined to address the threats. S.C. entered an in-patient facility and continued coursework remotely. Because the threats continued, her family moved to a different county. S.C.'s grades dropped substantially, she began abusing drugs and alcohol, and she engaged in self-harm. Before the incident, the district already had “a widespread problem of students circulating sexual pictures and videos of themselves and their peers.” The district was aware of the problem.S.C. alleged deliberate indifference to student-on-student harassment before she was assaulted; deliberate indifference during the investigation; and Fourteenth Amendment equal protection claims. S.C.’s Title IX “before” claim was dismissed. The court found the district liable for emotional distress and other damages on the Title IX “after” claim, but not liable under section 1983. The Sixth Circuit vacated and remanded the Title IX and Section 1983 “before” claims and affirmed that the district is liable on S.C.’s Title IX “after” claim. View "S.C. v. Metropolitan Government of Nashville & Davidson County" on Justia Law

In 1970, Michigan voters approved Proposal C, amending Article VIII, section 2 of Michigan’s constitution: “No public monies or property shall be appropriated or paid or any public credit utilized, by the legislature or any other political subdivision or agency of the state directly or indirectly to aid or maintain any private, denominational or other nonpublic, pre-elementary, elementary, or secondary schools.” The plaintiffs allege that Proposal C was spurred by the legislature’s passage of 1970 PA 100, which “allowed the Department of Education to purchase educational services from nonpublic schools in secular subjects,” and authorized $22 million in spending during the 1970-71 school year. Plaintiffs allege that “nonpublic schools” meant “religious schools”; opposition to 1970 PA 100 resulted in Proposal C. In 2000, Michigan voters rejected a ballot initiative that would have amended the section to authorize “indirect” support of non-public school students and create a voucher program for students in underperforming public school districts to attend nonpublic schools.Plaintiffs brought unsuccessful free exercise claims, alleging they have funded Michigan Education Savings Program plans and wish to use those plans to pay for their children’s religious school tuition. The Sixth Circuit affirmed the dismissal of their equal protection claim that section 2, while facially neutral, creates a political structure that unconstitutionally discriminates against religion because religious persons and schools cannot lobby their state representatives for governmental aid or tuition help without first amending the state constitution. View "Hile v. State of Michigan" on Justia Law