Justia Education Law Opinion Summaries

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

Felissa Jones, the mother of an elementary school student, reported to the Mississippi Department of Child Protection Services (MDCPS) that her son had suffered abuse and neglect by staff at his school. MDCPS responded that it does not investigate reports of abuse at school. Jones then sued MDCPS, seeking declaratory and injunctive relief related to MDCPS’s policy that the agency does not investigate allegations of abuse in out-of-home settings such as schools.The Hinds County Chancery Court denied Jones's motion for a judgment in her favor on the pleadings and granted MDCPS's motion for a judgment on the pleadings, dismissing Jones's complaint. The court ruled that Jones's request for declaratory relief related to MDCPS’s former intake policy was moot because the policy was no longer in effect. It also ruled that the current intake policy does not violate the relevant statutes, but instead conforms to the statutory mandate to refer allegations of child abuse in out-of-home settings to local law enforcement.In the Supreme Court of Mississippi, Jones appealed the lower court's decisions. The court affirmed the lower court's rulings, stating that MDCPS does not have a duty to investigate reports of abuse in out-of-home settings, such as schools, because children who are mistreated by school staff do not fall under the youth court’s limited jurisdiction. The court also found that Jones's claim for declaratory relief from the amended policy had no merit because the policy tracks the relevant statutes. View "Jones v. Department of Child Protection Services" on Justia Law

The Regents of the University of California (Regents) approved the construction of a new hospital at the University of California San Francisco (UCSF) Parnassus Heights campus. The proposed hospital was alleged to exceed local building height and bulk restrictions. The Parnassus Neighborhood Coalition (the Coalition), a group of property owners residing near the proposed hospital, sued to halt the construction, claiming it was a “threatened nuisance per se.” The Regents argued that as a state entity, they were immune from complying with local building and zoning regulations when engaging in a governmental activity such as constructing university buildings.The trial court disagreed with the Regents, concluding that their immunity depended on whether the proposed construction constituted a governmental or proprietary activity, a question of fact that could not be resolved on a demurrer. The Regents petitioned for a writ of mandate to vacate the trial court’s order.The Court of Appeal of the State of California First Appellate District Division Three reviewed the case. The court concluded that the proposed hospital would facilitate the provision of clinical services, thereby advancing UCSF’s academic mission and the Regents’ educational purpose, which is a governmental activity. The court held that the Regents are exempt from the local regulations at issue, and the demurrer should have been sustained. The court issued the writ of mandate, directing the trial court to vacate its order denying the Regents’ demurrer and to enter a new order sustaining the demurrer. View "The Regents of the University of California v. Superior Court" on Justia Law

The case revolves around Timothy Poole, a law graduate who failed the Kentucky Bar Examination five times. Poole claimed that the Kentucky Office of Bar Admissions (KYOBA) and its Executive Director, Valetta Browne, denied him necessary accommodations, leading to his repeated failures. He sought either retroactive admission to the Kentucky Bar Association or permission to retake the exam with all his accommodations.Previously, Poole had initiated a lawsuit in Fayette Circuit Court, alleging negligence on Browne's part regarding the October 2020 exam, which caused him emotional distress, loss of employment opportunities, and other damages. However, the complaint was dismissed, with the court ruling that individuals serving in a judicial capacity are immune from civil liability for their conduct and communications during their duties.The Supreme Court of Kentucky, after reviewing Poole's petition, his interactions with the KYOBA, and the accommodations offered, found that Poole was given appropriate accommodation and ample opportunities to pass the bar exam. The court noted that Poole voluntarily chose to sit for the exam twice without any accommodations, despite having inquired about them and allegedly possessing the required materials for his application. The court also pointed out that Poole never voiced any objection to the additional testing time allowance afforded to him and did not appeal that determination.The court also clarified that the rule limiting attempts to pass the bar exam to five, including attempts on the Uniform Bar Examination (UBE) taken in Kentucky or any other jurisdiction from February 2021 onwards, applies to all attempts, not just those after February 2021.The court concluded that Poole's application process and the exams were conducted in a fair and equitable manner, and any failure to approve and implement additional accommodations was due to Poole's failure to apply for them or seek appellate review of the accommodation granted. The court affirmed the KYOBA's determination that Poole had exhausted his attempts to pass the Kentucky Bar Exam and denied his requests for relief. View "Poole v. Browne" on Justia Law

The case involves the Edmond Public Schools (the Petitioner) and the State of Oklahoma, the State Board of Education, and the State Superintendent of Public Instruction (the Respondents). The Petitioner filed an application for the Supreme Court to prevent the enforcement of rules by the Respondents. These rules were to be used in enforcement proceedings against the school district before the State Board. The Petitioner argued that the State Board lacked the authority to supervise, examine, and control a local school board's discretion in supplying books for a school library that meet local community standards.The State Board of Education had publicized proposed rules for school library media programs, which included prohibitions on pornographic and sexualized content for books and other media. The Board adopted these rules, citing the Oklahoma Constitution and state statutes as their authority. However, the Oklahoma Attorney General issued an opinion stating that the proposed rules were not based on a specific grant of legislative authority, which was necessary for the Board to create these rules. The Legislature passed a resolution that did not expressly approve or disapprove the State Board's new rules. The Governor later issued a Declaration stating that the proposed rules for the State Department of Education were not subject to the joint resolution and approved these proposed rules as permanent rules for the State Department of Education.The Supreme Court of the State of Oklahoma assumed original jurisdiction, in part, over the controversy. The court held that state statutes give a local school board power and a type of statutory discretion to supply books for a school library that meet local community standards. The court also held that no statute gives the State Board of Education, State Department of Education, and Superintendent of Public Instruction the authority to supervise, examine, and control a local school board's exercise of this discretion when the local school board applies local community standards for books it supplies for a local school library. The court issued a writ of prohibition to prevent additional enforcement proceedings against the school district based on the respondents' objection to the presence of certain books in the local school library. The court denied the petitioner's request for declaratory and injunctive relief. View "INDEPENDENT SCHOOL DISTRICT NO. 12 v. STATE" on Justia Law

A minor, L.M., represented by his father and stepmother, sued the Town of Middleborough, Massachusetts, the Middleborough School Committee, and various school officials, alleging that his First Amendment rights were violated when he was prohibited from wearing a t-shirt that read "There Are Only Two Genders" at his public middle school. The United States District Court for the District of Massachusetts denied L.M.'s motion for a preliminary injunction and granted final judgment in favor of the defendants.On appeal, the United States Court of Appeals for the First Circuit affirmed the District Court's rulings. The Court of Appeals held that the school officials reasonably interpreted the message on L.M.'s t-shirt as demeaning to the gender identities of other students. The court also found that the school officials reasonably forecasted that the t-shirt's message would negatively affect the psychology of students with the demeaned gender identities and disrupt the learning environment. The court concluded that the school's actions were permissible under the "material disruption" limitation of the Supreme Court's decision in Tinker v. Des Moines Independent Community School District, which allows schools to regulate student speech that materially disrupts classwork or involves substantial disorder.The Court of Appeals also rejected L.M.'s facial challenges to the school's dress code, finding that he lacked standing to challenge one provision and that the other provision was not unconstitutionally vague or overbroad. View "L. M. v. Town of Middleborough, Massachusetts" on Justia Law

The case involves two former faculty members at the University of California, Los Angeles (UCLA), who were accused of serious misconduct. An independent law firm was hired to investigate the allegations, and the resulting report concluded that the professors had engaged in improper activities. The professors resigned their positions as part of a settlement agreement, with no findings of misconduct or admissions of liability. A former UCLA employee requested the report under the California Public Records Act (CPRA), and the professors objected, leading to a series of legal actions known as "reverse-CPRA" actions.The Superior Court of Los Angeles County denied the professors' petitions to withhold the report, concluding that the public interest in disclosure outweighed the professors' privacy interests. The court found that the allegations of misconduct were serious and substantial, and that the public had a strong interest in knowing how the university handled such complaints. The professors appealed this decision.While the appeal was pending, the Los Angeles Times made its own CPRA request for related documents, including the investigation report and the settlement agreements. The professors sought a preliminary injunction to prevent the release of these documents, but the trial court denied their request. The court found that the professors were unlikely to succeed on the merits of their claim, as the analysis for the disclosure of these documents was the same as for the investigation report. The professors appealed this decision as well.The Court of Appeal of the State of California, Second Appellate District, affirmed the trial court's decision. The appellate court agreed with the trial court's analysis and found no reason to delay a decision on a matter concerning public transparency. The court concluded that the professors had not established a likelihood of success on the merits of their claim and were therefore not entitled to injunctive relief. View "Doe v. The Regents of the University of California" on Justia Law

The case involves a group of plaintiffs, including the Health Freedom Defense Fund, Inc. and California Educators for Medical Freedom, who challenged the COVID-19 vaccination policy of the Los Angeles Unified School District (LAUSD). The policy, which was in effect for over two years, required employees to get the COVID-19 vaccination or lose their jobs. The plaintiffs argued that the policy interfered with their fundamental right to refuse medical treatment.The case was initially dismissed by the United States District Court for the Central District of California, which applied a rational basis review under Jacobson v. Massachusetts, concluding that the policy served a legitimate government purpose. The court held that even if the vaccine did not prevent transmission or contraction of COVID-19, it furthered the purpose of protecting LAUSD students and employees from COVID-19.The plaintiffs appealed to the United States Court of Appeals for the Ninth Circuit. During the appeal, LAUSD rescinded its vaccination policy. LAUSD then asked the court to dismiss the appeal, arguing that the case was now moot. The plaintiffs objected, arguing that LAUSD withdrew the policy because they feared an adverse ruling.The Ninth Circuit held that the case was not moot, applying the voluntary cessation exception to mootness. The court found that LAUSD's pattern of withdrawing and then reinstating its vaccination policies, particularly in response to litigation risk, was enough to keep the case alive.On the merits, the Ninth Circuit held that the district court misapplied the Supreme Court’s decision in Jacobson v. Massachusetts. The court found that Jacobson did not apply because the plaintiffs had plausibly alleged that the COVID-19 vaccine does not effectively prevent the spread of COVID-19. The court vacated the district court’s order and remanded the case for further proceedings under the correct legal standard. View "HEALTH FREEDOM DEFENSE FUND, INC. V. ALBERTO CARVALHO" on Justia Law

In this case, Laurie Barton, a third-year law student at the University of Idaho, was accused of violating the university's honor code by committing academic misconduct during a final examination. Despite denying the allegations, she was sanctioned with degree denial after a series of Honor Court proceedings. Barton exhausted her administrative review options, including an appeal to the Idaho State Board of Education, and then petitioned for judicial review. The district court denied her petition. Instead of appealing this decision, Barton sued the Board of Regents of the University of Idaho and Idaho State Board of Education, alleging nine causes of action, all of which the district court dismissed at summary judgment.The district court's judgment was affirmed by the Supreme Court of the State of Idaho. The Supreme Court found that Barton had failed to raise a genuine issue of material fact that the University violated its duty of good faith and fair dealing or that it made a specific promise that induced her action. The court also found that Barton's motion for a protective order was implicitly denied and moot, as the case was resolved on summary judgment. The court concluded that Barton's appeal was pursued frivolously, unreasonably, and without foundation, and awarded attorney fees and costs to the University. View "Barton v. Board of Regents" on Justia Law

The case involves Kari Schwartz, a high school teacher, who was found guilty of sexual exploitation by a school employee. The charges stemmed from her relationship with a 17-year-old student, A.S., in her art class. Schwartz began spending more time with A.S., both in and outside of school, and started sharing personal, intimate stories. She also made comments about A.S.'s physical appearance and initiated physical contact, including hugging. Schwartz also sent multiple messages to A.S., expressing her love and inviting her to do things outside of school. The most serious incident occurred when Schwartz touched A.S. inappropriately in a school stairwell.The case was first heard in the Iowa District Court for Buchanan County, where Schwartz was found guilty. She appealed her conviction and sentence, raising four challenges. The Iowa Court of Appeals affirmed the conviction and sentence. Schwartz then sought further review from the Supreme Court of Iowa.The Supreme Court of Iowa affirmed the decisions of the lower courts. The court found substantial evidence supporting Schwartz's conviction, including her systematic conduct towards A.S. and the sexual nature of her actions. The court also rejected Schwartz's challenge to the jury instruction, which included hugging as a form of sexual conduct. The court held that the instruction was a correct statement of the law and that the jury was not misled by it. The court concluded that Schwartz was not prejudiced by the instruction and affirmed her conviction and sentence. View "State of Iowa v. Schwartz" on Justia Law