Justia Education Law Opinion Summaries

N.L. met Nicholas Clark at school track practice. She was 14, and he was 18. Both were students in the Bethel School District. Neither N.L. nor any responsible adult on the field knew that Clark was a registered sex offender who had previously sexually assaulted a younger girl who had been about N.L. 'sage at the time. The Pierce County Sheriff's Department had informed Clark's school principal of his sex offender status, but the principal took no action in response. Clark persuaded N.L. to leave campus with him and raped her. N.L. sued the district, alleging negligence. The issue this case presented for the Washington Supreme Court’s review centered on whether the School District’s duty to N.L. ended when she left campus and whether its alleged negligence, as a matter of law, was not a proximate cause of her injury. The Court answered both questions “no,” affirming the Court of Appeals’ judgment reversing the trial court’s dismissal of this case on summary judgment. View "N.L. v. Bethel Sch. Dist." on Justia Law

Plaintiffs, two high-profile medical researchers that held faculty appointments at Harvard Medical School and were intimately involved with a research laboratory at Brigham and Women’s Hospital, were investigated for alleged research misconduct. Responding to allegations that Plaintiffs used manipulated research data in articles reporting on studies supported by government funds, Harvard and Brigham triggered a unique federal statutory and regulatory scheme. Without awaiting the outcome of the administrative proceedings, Plaintiffs filed suit in federal court against the institutional defendants, alleging, inter alia, tortious interference with business relations, invasion of privacy, and unfair and deceptive business practices. The district court dismissed the action, concluding that the suit was premature because Plaintiffs had not exhausted their administrative remedies. The First Circuit affirmed as modified, holding (1) the district court correctly applied the doctrine of administrative exhaustion; but (2) on remand, the district court is directed to convert its order of dismissal to an order staying the case pending the timely resolution of administrative proceedings. View "Anversa v. Partners Healthcare Sys., Inc." on Justia Law

Plaintiffs appealed the district court's order granting the District's motion to approve the closure of Wilmot Elementary School and to modify the gifted and talented (GT) requirements for the District. In 1988, plaintiffs filed suit under 42 U.S.C. 1983, alleging race discrimination and other claims. The parties negotiated a settlement and, in 1991, the district court entered a Consent Order disposing of issues remaining in the complaint. In this case, the district court approved closure of Wilmot and modification of the GT program as the proper modification of the Consent Order due to the significant changed circumstances. The court concluded that such modification is suitably tailored where the modifications sought by the school district in light of the (1) demographic changes, (2) decrease in enrollment, (3) cost savings, and (4) educational considerations are in line with the initial Consent Order. Accordingly, the court held that the district court did not abuse its discretion in granting the District's motion to approve closure of Wilmot and to modify the GT requirements. The court affirmed the judgment. View "Mays v. Hamburg Sch. Dist." on Justia Law

Plaintiff, a high school student, was suspended from school for conduct that took place outside of school grounds. The suspension - which was mistakenly ordered on the ground that Plaintiff had been charged with a felony - lasted an entire semester, and Plaintiff was unable to graduate with her class. Plaintiff commenced this action asserting that her suspension was unlawful. The judge allowed Defendants’ motion to dismiss on the ground that Plaintiff failed to exhaust her administrative remedies under Mass. Gen. Laws ch. 72, 37H1/2 before filing her complaint. The Supreme Judicial Court reversed, holding that because the tort recovery a student may seek under Mass. Gen. Laws ch. 76, 16 provides a separate and distinct remedy from that available under section 37H1/2, Plaintiff was not obligated to exhaust the statute’s administrative remedies before pursuing a tort claim under Mass. Gen. Laws ch. 76, 16. View "Goodwin v. Lee Public Schools" on Justia Law

After the school districts sought termination of the Garland County School Desegregation Case Comprehensive Settlement Agreement and relief from the district court’s 1992 order enforcing it, the district court denied the school districts' Rule 60(b)(5) motion. The district court rejected the school districts' argument that the Agreement is no longer just or equitable to give the 1992 order or the Agreement prospective application in light of the repeal of the Arkansas School Choice Act of 1989 (School Choice Act), Ark. Code Ann. 6-18-206 (repealed 2013). The court concluded that the school districts have presented no evidence that they have either fully complied or that there have been changed circumstances in those other areas of the Agreement. Therefore, termination of the entire Agreement would be supported by nothing more than the notion that it is no longer convenient to live with. The court affirmed the judgment. View "W.T. Davis v. Cutter Morning Star Sch." on Justia Law

S.D. suffers from “multiple medical problems including chronic sinusitis with frequent acute exacerbations, allergic rhinitis, and intermittent asthma” that allegedly “substantially limit him in . . . the life activity of learning.”. S.D.’s doctor concluded that these medical problems “make it likely that he will have frequent school absence[s] due to acute [and] underlying chronic illness,” and suggested that S.D. “should qualify for [Section] 504 plan modifications for school” under the Rehabilitation Act, 29 U.S.C. 794(a). Dissatisfied with the school’s plan, which involved Saturday sessions and a summer course, his parents sued, citing the Rehabilitation Act, the Americans with Disabilities Act, 42 U.S.C. 12101–12213, the First and Fourteenth Amendments (42 U.S.C. 1983), and New Jersey’s Law Against Discrimination. The district court dismissed for failure to exhaust the administrative process provided for by the Individuals with Disabilities Education Act, 20 U.S.C. 1400–1482. The Third Circuit affirmed. While the claims alleged discrimination and retaliation for enforcement of the child’s rights under a non-IDEA statute, the alleged injuries are educational in nature and implicate services within the purview of the IDEA, so administrative remedies must be exhausted. View "S. D. v. Haddon Heights Bd. of Educ." on Justia Law

New Public School District #8 appealed a judgment affirming the State Board of Public School Education's decision approving annexation of certain real properties to the Williston School District. New Public School District argued the State Board erred in approving the petition for annexation because the property to be annexed was not contiguous to the Williston School District before the petition was heard. Finding no reversible error, the Supreme Court affirmed. View "New Public Sch. Dist. #8 v. North Dakota Bd. of Public Sch. Edu." on Justia Law

Named plaintiffs, 2008-2011 graduates of the Widener School of Law, claim that Widener violated the New Jersey and Delaware Consumer Fraud Acts by intentionally publishing misleading statistics, reporting that in 2005-2011, 90-97% of graduates were employed. In reality, only 50-70% of Widener graduates secured full-time legal positions. The school included non-legal and part-time positions without reporting the breakdown. In 2011, Widener improved its reporting, but allegedly continued to gather unreliable information by crediting secondhand accounts of employment and avoiding responses from unemployed graduates. The plaintiffs claim that publishing misleading statistics enabled Widener to inflate tuition. The plaintiffs moved to certify a class of “persons who enrolled in Widener University School of Law and were charged full or part-time tuition within the statutory period.” The district court denied class certification, finding that the plaintiffs could not meet FRCP 23(b)(3)’s requirement that common questions “predominate” over individual questions because they had not shown that they could prove damages by common evidence. The court noted differences in class members’ employment outcomes and that New Jersey has rejected a “fraud-on-the-market” theory outside the securities fraud context. Plaintiffs could not meet Rule 23(a)(3)’s requirement that the named plaintiffs’ claims be “typical” of the claims of the proposed class; students who enrolled in 2012 and later, after Widener improved its reporting, might prefer not to have Widener’s reputation tarnished by the lawsuit. The Third Circuit affirmed. The plaintiffs’ theory was insufficiently supported by class-wide evidence. View "Harnish v. Widener Univ. Sch. of Law" on Justia Law

Plaintiff filed suit alleging that defendants violated her constitutional rights when she was required to participate in a mock performance of the Mexican Pledge of Allegiance. The district court entered summary judgment on some of plaintiff's claims and, after trial, entered judgment as a matter of law for defendants. The court concluded that, because plaintiff has graduated from high school, her only surviving claim is for nominal damages arising from the alleged violation of her rights; plaintiff failed to demonstrate the existence of an official policy or that the District had knowledge of the assignment, and thus judgment as a matter of law was proper for the District on municipal liability for any constitutional violation that may have arisen from the assignment or subsequent actions; the court's ruling also applies to the claims against the District for retaliation and violation of Equal Protection; qualified immunity was properly granted to Defendants Santos and Cavazos on the claim they violated plaintiff's First Amendment rights when they removed plaintiff from class; and, likewise, plaintiff's equal protection claim fails. Accordingly, the court affirmed the judgment. View "Brinsdon v. McAllen I.S.D." on Justia Law

In 1956, the New Kensington Eagles donated to Valley High School a six-foot granite monument inscribed with the Ten Commandments, an eagle, an American flag, the Star of David, the Chi-Rho symbol, a Masonic eye, and Hebrew and Phoenician lettering. It is near the gymnasium entrance, which is accessible from the student parking area. In 2012, FFRF, an organization dedicated to promoting separation of church and state, unsuccessfully requested the monument's removal. Schaub saw a story on television and contacted FFRF. Schaub had visited Valley and seen the monument while taking her daughter to a karate event, picking the girl up from the swimming pool, and dropping off her sister, whose child attends Valley. Schaub’s daughter was to attend Valley beginning in August 2014. Schaub views the monument as “commanding” students and visitors to worship “thy God,” brands her as “an outsider because [she] do[es] not follow the particular religion or god that the monument endorses,” and makes her “stomach turn.” She wishes to raise her daughter without religion. While a suit under 42 U.S.C. 1983 was pending, Schaub’s daughter began attending a different high school. The district court granted the District summary judgment. The Third Circuit reversed. Schaub has standing to seek nominal damages and injunctive relief, and her request for injunctive relief was not moot. With respect to FFRF’s claims, the court remanded for consideration of whether Schaub was an FFRF member when the complaint was filed. View "Freedom From Religion Found. v. New Kensington Arnold Sch. Dist." on Justia Law