Justia Education Law Opinion Summaries

An organization called Students for Fair Admissions, Inc. (SFFA) brought this lawsuit challenging Harvard College’s consideration of race in its undergraduate admissions decision. An opposing group of current and prospective Harvard students (“Students”) sought to intervene, over both parties’ objection, to advocate for the defeat of SFFA’s claims. The district court denied Students’ motion to intervene. Students appealed. The First Circuit affirmed, holding that the district court did not err in finding that Students failed to show that no existing party would adequately represent Students’ interest and thus that Students’ participation as a party was not needed. View "Students for Fair Admissions, Inc. v. President and Fellows of Harvard College" on Justia Law

Linn State's Board of Regents adopted a mandatory drug screening policy. Plaintiffs filed suit challenging the drug screening policy. In Barrett v. Claycomb, a panel of this court reviewed an interlocutory appeal, discussing, and ultimately reversing, the grant of a preliminary injunction in favor of plaintiffs on their facial challenge to the drug testing policy. On remand, plaintiffs clarified their claims to assert an as-applied challenge to the very same policy. The district court, in part, permanently enjoined Linn State from conducting any further collection, testing, or reporting. On appeal, Linn State challenged the district court's grant of a permanent injunction and subsequent grant of attorneys' fees in favor of plaintiffs. The court concluded that, on balance, testing the entire student population entering Linn State is reasonable and hence constitutional and an effective means of addressing Linn State's interest in providing "a safe, healthy, and productive environment for everyone who learns and works at LSTC by detecting, preventing, and deterring drug use and abuse among students." Accordingly, the court reversed and remanded for dismissal of the case. View "Kittle-Aikeley v. Claycomb" on Justia Law

In 2009, a first grade student complained to a teacher that her genitals hurt and the teacher sent her to the school nurse who visually inspected the girl. Plaintiff, the girl's mother, filed a money-damages action against the nurse and the school district for conducting a search in violation of her child’s Fourth and Fourteenth Amendment rights. The district court subsequently issued an injunction that required the school system to train its nurses more effectively to prevent incidents of this sort from happening again. The court reversed the injunction because: (1) the mother did not seek such an injunction; (2) the undisturbed (and now unappealed) jury verdict that no constitutional violation occurred eliminated the factual predicate for such an injunction; and (3) the mother (and daughter) lacked standing to obtain such an injunction anyway. The court directed the district court to enter judgment in favor of the school district. View "Hearring v. Sliwowski" on Justia Law

ACT, Inc. and The College Board (collectively, Defendants) are national testing agencies that administer the ACT and SAT college entrance exams. When a student applies to take a test, Defendants obtain some of the student’s personally identifiable information (PII). As part of the examination process, some students authorize Defendants to share certain PII with participating educational organizations through an information exchange program. In 2014, a group of former information exchange program participants (collectively, Plaintiffs) filed a putative class action complaint against Defendants, alleging that they were harmed because the testing agencies did not disclose that the students’ PII was actually sold to the educational organizations for profit. The district court dismissed the complaint for lack of subject matter jurisdiction under Fed. R. Civ. P. 12(b)(1), concluding that Plaintiffs failed to establish standing under Article III of the Constitution. The Seventh Circuit affirmed, holding that Plaintiff’s factual allegations failed to establish a plausible claim of Article III standing. View "Silha v. ACT, Inc." on Justia Law

In a first appeal, the court reversed summary judgment in favor of the Board, holding that material fact issues surrounded the discriminatory purpose and effect of the Board’s adoption of a redistricting plan that concentrated economically disadvantaged students in a majority-nonwhite school district. On remand, the district court entered judgment for the Board. The court affirmed the judgment, concluding that the district court did not err in concluding that Option 2f does not make express racial classifications and so is not subject to strict scrutiny on that basis. Option 2f employed several means to shift the student population among the east bank schools. The court rejected plaintiff's alternative theory that, despite Option 2f’s facial neutrality, the redistricting plan’s funneling feature is nevertheless subject to strict scrutiny because it had both a discriminatory purpose and a discriminatory effect. The court agreed with the district court's conclusion that rational basis review is satisfied as to the equal protection claim and the court rejected plaintiff's remaining claims. Accordingly, the court affirmed the district court's grant of summary judgment for the Board. View "Lewis, Sr. v. Ascension Parish Sch. Bd." on Justia Law

California Education Code 56346(f) requires school districts to initiate a due process hearing if the school district determines that a portion of an Individualized Education Program (IEP) to which a parent does not consent is necessary to provide a child with a Free Appropriate Public Education (FAPE) under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400–1450. The ALJ concluded that the district offered an appropriate placement but Mother's refusal to consent prevented the district from implementing and providing a FAPE. I.R. appealed, but the district court affirmed. The court concluded that the district court erred in concluding that the district could not initiate a due process hearing to address Mother's refusal to the IEP's recommended placement. In this case, the district waited a year and a half before initiating a hearing, which the court determined was too long a period of time. Therefore, to the extent that I.R. lost an educational opportunity and was deprived of educational benefits for an unreasonably prolonged period, the district can be held responsible for denying her a FAPE for that unreasonably prolonged period. The court reversed and remanded. View "I.R. v. L.A. U.S.D." on Justia Law

Plaintiff collapsed with exertional heatstroke while practicing as a member of the Towson University football team. Plaintiff was in a coma for nine days, almost died, and suffered multi-organ failure, requiring a liver a transplant and numerous additional surgeries. Plaintiff subsequently recovered and pursued his plan to return to playing football. However, the Team Physician, a board-certified sports medicine doctor, concluded that allowing plaintiff to participate in the football program at the University presented an unacceptable risk of serious reinjury or death. Plaintiff filed suit against the University, alleging that its decision to exclude him from the football program amounted to a violation of Title II of the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq., and Section 504 of the Rehabilitation Act, 29 U.S.C. 701 et seq. The district court entered judgment against the University. The court reversed, concluding that plaintiff was not “otherwise qualified” to participate fully in the University’s football program because the University reasonably applied its Return-to-Play Policy. The court was required to give deference to the University's judgment. The court did not reach the University's challenge to the district court's evidentiary rulings. View "Class v. Towson Univ." on Justia Law

The New Mexico Department of Public Education’s (Department) Instructional Material Bureau purchases non-religious instructional materials selected by public or private schools, with funds appropriated by the Legislature and earmarked for the schools, and lends these materials to qualified students who attend public or private schools. The question this case presented for the New Mexico Supreme Court’s review centered on whether the provision of books to students who attend private schools violated Article XII, Section 3. The Court concluded that the plain meaning and history of Article XII, Section 3 forbade the provision of books for use by students atte View "Moses v. Skandera" on Justia Law

During the 2011-2012 school year, Plaintiff was a continuing contract teacher who worked for the Laramie County School District No. One. In spring of 2012, the District Superintendent gave Plaintiff notice that he proposed that Kinstler be terminated. On September 4, 2012, a hearing officer recommended that the District accept the Superintendent’s proposal. On September 17, 2012, the District’s Board of Trustees voted to accept the recommendation. Kinstler was paid his normal salary from August 15, 2012, the date he would have started to work, through the date that the Board acted on the recommendation to terminate him. Kinstler subsequently sued the District, asserting that the District failed to pay him the salary and value of benefits allegedly owed him for the 2012-2013 academic year. The district court partially granted Kinstler’s motion for summary judgment and entered an order with respect to his salary and benefits claim. The Supreme Court reversed and vacated the award, holding that because Kinstler’s termination was effective at the end of the 2011-2012 school year, he had no statutory right to compensation following that date. View "Laramie County Sch. Dist. v. Kinstler" on Justia Law

Petitioners - four residents of the Westwood Valley Addition to Sioux Falls, which is a part of the Tea Area School District (TASD) - submitted a petition to the Tea Area School Board requesting that the TASD’s boundary be changed to exclude their residences, which would instead be annexed by the Sioux Falls School District. After a publicly noticed meeting at which none of Petitioners appeared, either personally or through counsel, the Board denied the petition. One petitioner appealed. The Supreme Court affirmed, holding (1) Petitioner’s appeal was properly before the Court; and (2) the Board’s denial of the petition for a minor boundary change was not arbitrary, capricious, or an abuse of discretion. View "Schaefer v. Tea Area Sch. Dist." on Justia Law