Justia Education Law Opinion Summaries

When Jane Doe was in second grade, she began receiving special education under the Individuals with Disabilities Education Act based on her deficiency in reading fluency. More than six years later, an administrative hearing officer determined that Jane was no longer eligible to receive special education. The district court affirmed. The First Circuit vacated and remanded the case, holding (1) the district court erred in relying on evidence of Jane’s overall academic performance without regard to how it reflected her reading fluency skills; and (2) the district court did not make an independent judgment as to the additional evidence submitted by Jane’s parents and afforded excessive deference to the hearing officer’s determinations in weighing the relevant reading fluency measures. View "Mr. & Mrs. Doe v. Cape Elizabeth Sch. Dist." on Justia Law

A School District expelled Student for six weeks after finding a pocketknife in a purse in her locker. The Commissioner of the Department of Education affirmed. The court of appeals reversed, concluding (1) Student did not willfully violate the District’s weapons policy when she unintentionally carried the pocketknife to school, and (2) the pocketknife’s presence in Student’s locker did not bring Student or others into danger. The Supreme Court affirmed, holding (1) the record did not support the conclusion that Student deliberately and intentionally violated the District’s weapons policy; and (2) the record did not contain substantial evidence that Student exposed anyone to actual or even probable harm. View "In re Expulsion of A.D. from United S. Central Pub. Schs." on Justia Law

Plaintiff, a Columbia University student, appealed the dismissal of his amended complaint for failure to state a claim. Plaintiff alleged that the University violated Title IX of the Education Amendments of 1972, 20 U.S.C. 1681 et seq., and state law, by acting with sex bias in investigating him and suspending him for an alleged sexual assault. The court concluded that the complaint meets the low standard described in Littlejohn v. City of New York, by alleging facts giving rise to a plausible minimal inference of bias sufficient to survive a motion to dismiss, which the court held applies to Title IX cases. In this case, the complaint alleged that both the investigator and the panel declined to seek out potential witnesses plaintiff had identified as sources of information favorable to him; the investigator and the panel failed to act in accordance with University procedures designed to protect accused students; and the investigator, the panel, and the reviewing Dean reached conclusions that were incorrect and contrary to the weight of the evidence. Accordingly, the court vacated and remanded. View "Doe v. Columbia University" on Justia Law

Plaintiff, on behalf of her minor son D.H., filed suit under 42 U.S.C. 1983 against school officials, including Assistant Principal Tyrus McDowell, and others, alleging that defendants deprived D.H. of his rights to privacy, to be secure in his person, and to be free from unreasonable searches and seizures. On appeal, McDowell challenged the district court’s interlocutory order denying his motion for summary judgment based on qualified immunity. The district court found that McDowell’s strip search of D.H., a minor student, violated clearly established constitutional law. The court concluded that McDowell violated D.H.'s constitutional rights. Furthermore, a reasonable official in McDowell’s position would not have believed that requiring D.H. to strip down to his fully naked body in front of several of his peers was lawful in light of the clearly established principle that a student strip search, even if justified in its inception, must be “reasonably related to the objectives of the search and not excessively intrusive in light of the age and sex of the student and the nature of the infraction.” Accordingly, the court affirmed the district court’s denial of McDowell’s motion for summary judgment based on qualified immunity. View "D. H. v. McDowell" on Justia Law

Plaintiffs filed suit alleging that defendants violated students' constitutional rights when they detained the students for breathalyzer tests prior to entering their Junior/Senior Prom. The district court granted summary judgment for defendants. The court concluded that plaintiffs have not established an actual or reasonable expectation of privacy in the party bus, which they had abandoned once they had exited for the Prom; the bus driver had apparent authority to consent to search the party bus; and therefore, the search of the party bus did not violate plaintiffs' Fourth Amendment rights. The court also concluded that the initial waiting period for the breathalyzer mouthpieces and a trained individual to administer the breathalyzer tests was reasonable, because it was necessary for the testing; detaining a student after he or she was found to be alcohol free was not “reasonably related” to the reason for the detention “in the first place” of determining if the student passengers on the party bus had been drinking; the individual school defendants are entitled to qualified immunity because there was no binding clearly established law at the time; and claims against the remaining defendants have been abandoned or have no merit. The court rejected plaintiffs' remaining claims. Because plaintiffs have not established that they should succeed on any of their allegations concerning their Fourth, First, and Fourteenth Amendment claims, the court affirmed the judgment. View "Ziegler v. Martin Cnty. Sch. Bd." on Justia Law

After a year of bullying and intimidation by a small group of students, Yahenacy Smith was beaten and severely injured while riding the school bus home. Smith sued the Leake County School District, alleging negligence and negligence per se. The circuit court found that the school district was entitled to discretionary-function immunity and granted the school district’s motion for summary judgment. Smith appealed. Finding that the broad governmental function of the school district here was ministerial, the Mississippi Supreme Court reversed the circuit court’s grant of summary judgment and remanded the case to the circuit court for Smith to proceed with her claims. View "Smith v. Leake County School District" on Justia Law

Defendant, National Heritage Academies, Inc., was a company that owned and operated a number of public, independently operated schools, including Linden Charter Academy (LCA) located in Flint, Michigan. Plaintiff, Craig Hecht, was a white teacher who had been employed by defendant at LCA for approximately eight years, most recently serving as a third-grade teacher. The student body at LCA was predominantly black. This race discrimination case came about over the color of a computer table: an aide returned a brown table to plaintiff's classroom. Upon noticing her mistake, the aide asked plaintiff whether he'd prefer to have the brown table she brought, or the white table that had previously been in the room. Whether or not plaintiff's next statement in response to the computer table question was a "tasteless joke" with no racial animas ultimately lead to plaintiff's termination with defendant. Plaintiff sued under Michigan's Civil Rights Act (CRA), claiming that the employer's reason for firing him was racially motivated. The issue this case presented for the Supreme Court's review was whether the trial court erred by denying defendant’s motion for judgment notwithstanding the verdict (JNOV). After review, the Supreme Court held that the Court of Appeals did not err by affirming the trial court’s denial of defendant’s motion for JNOV on plaintiff’s claim of discrimination under the Civil Rights Act (CRA), "[t]his case turned on circumstantial evidence, on the credibility of plaintiff’s proofs that suggested there were racial reasons for his treatment and on the credibility of defendant’s nonracial justifications for firing him." The Court concluded based on the evidence presented and all the inferences that could be reasonably drawn from that evidence in favor of the jury’s liability verdict, that a reasonable jury could have concluded that defendant violated the CRA. The Court found error in the calculation of future damages and reversed the trial court on that ground. The Court remanded the case for further proceedings. View "Hecht v. National Heritage Academies, Inc." on Justia Law

Byrne & Jones Enterprises, Inc. filed an action against Monroe City R-1 School District alleging that it was denied a fair and equal opportunity to compete in the bidding process for a public works contract to build an athletics stadium. The trial court dismissed the petition, concluding that Byrne & Jones, as an unsuccessful bidder, lacked standing to challenge the school district’s award of the contract to another bidder because it did not bring the action in the interest of the public or as a taxpayer. The Supreme Court affirmed, holding (1) Byrne & Jones had standing to challenge the award of the contract to another bidder; but (2) the trial court did not err in dismissing the petition because Byrne & Jones was not entitled to the relief requested in the petition. View "Byrne & Jones Enters., Inc. v. Monroe City R-1 Sch. Dist." on Justia Law

Plaintiff-Appellant A.M. filed this action under 42 U.S.C. 1983 on behalf of her minor child, F.M., against two employees of the Albuquerque Public Schools: Cleveland Middle School (“CMS”) Principal Susan LaBarge and Assistant Principal Ann Holmes. A.M. also filed suit against Officer Arthur Acosta of the Albuquerque Police Department (“APD”). A.M. brought several claims stemming from two school-related events: (1) the May 2011 arrest of F.M. for allegedly disrupting his physical-education class, and (2) the November 2011 search of F.M. for contraband. Holmes and LaBarge sought summary judgment on the basis of qualified immunity, and the district court granted their respective motions. The court also denied A.M.’s motion for summary judgment on her claims pertaining to Officer Acosta after determining that Officer Acosta was entitled to prevail on qualified-immunity grounds too. On appeal, A.M. argued that the district court erred in awarding qualified immunity to all of the defendants. The Tenth Circuit consolidated these matters for review, and found o reversible error in the district court's grant of qualified immunity. View "A.M. v. Holmes" on Justia Law

Pursuant to 2011 amendments to statutes addressing collective bargaining for teachers and their employees, when parties failed to reach a collective bargaining agreement (CBA) regarding salaries and wages, the Indiana Education Employment Relations Board (IEERB) appoints a mediator. If the mediation fails, the parties must exchange their last best offers (LBOs). A factfinder appointed by the IEERB then selects which side’s LBO to adopt as the CBA. In this case, a teachers association appealed a factfinder’s decision to adopt a school’s LBO. The IEERB affirmed the factfinder’s decision. The Supreme Court affirmed, holding that the adopted LBO was collectively bargained and lawful. View "Jay Classroom Teachers Ass’n v. Jay School Corp." on Justia Law