Justia Education Law Opinion Summaries

This appeal arose out of allegations that AKC, a child with autism, suffered abuse at school by her special-education teacher, Vickie Cantrell. AKC’s parents, Ted and Bella Carroll, filed suit in federal district court against Cantrell, the school district, and others, seeking damages under the Americans with Disabilities Act (the ADA), Section 504 of the Rehabilitation Act, and a variety of state-law theories. The district court dismissed the Carrolls’ federal claims, concluding the Carrolls had not exhausted their administrative remedies before filing suit as required by the Individuals with Disabilities Education Act (the IDEA). The district court then dismissed the Carrolls’ complaint, declining to exercise supplemental jurisdiction over their state-law claims. The Carrolls appealed. The single issue on appeal before the Tenth Circuit was whether the district court erred in determining the Carrolls’ federal claims were subject to the IDEA’s exhaustion requirement. Because the Court concluded the Carrolls’ complaint alleged educational injuries that could have been redressed to some degree by the IDEA’s administrative remedies, it agreed with the district court that exhaustion of those remedies was required before the Carrolls could file suit. View "Carroll v. Lawton Independent School" on Justia Law

Plaintiff filed suit under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq., seeking attorneys' fees after she proved in an administrative hearing that a school district had violated her child’s right to a free appropriate public education by repeatedly placing him in isolation during school hours. The court concluded that the district court erred in applying section 1415(i)(2)(B)’s limitations period to this action for attorneys’ fees under the IDEA by a party that prevailed at the administrative level. Because the statute contains no limitations period for such actions, the district court should have borrowed one from state law. The court held that the limitations period for such an action does not begin to run until the time for seeking judicial review of the underlying administrative decision passes, and that plaintiff’s action was timely under any limitations period that could be borrowed. Accordingly, the court reversed the district court's grant of summary judgment and remanded for further proceedings. View "D.G. v. New Caney Indep. Sch. Dist." on Justia Law

The DOJ filed a motion for further relief in this 40-year-old case in order to gain oversight and some level of control over Louisiana’s school voucher program. The district court granted the DOJ’s motion for further relief and thus mandated annual reporting requirements for Louisiana’s school voucher program. Appellants moved to vacate the district court's order under Federal Rules of Civil Procedure 59(e), 60(b)(4), and 60(b)(5). The district court denied the motion. The court held that the order concerning the voucher program is beyond the scope of the district court’s continuing jurisdiction in this case and is therefore void for lack of subject matter jurisdiction. The district court should have granted the Rule 60(b)(4) motion. The order is reversed and the injunction is therefore dissolved. View "Brumfield v. Louisiana State Bd. of Edu." on Justia Law

After Respondent was terminated as Superintendent of Schools she challenged her termination from employment by filing suit in the circuit court, naming as Defendants the West Virginia Board of Education and its former president (collectively, Petitioners). Respondent alleged in her complaint that her due process rights under the state Constitution were violated and asserted claims for breach of contract, defamation, and false light. Petitioners filed a motion to dismiss, asserting that qualified immunity barred each of Respondent’s claims. The circuit court denied Petitioners’ motion to dismiss. The Supreme Court reversed and dismissed Respondent’s complaint, holding that Respondent’s complaint failed to allege a cause of action sufficient to overcome Petitioners’ discretion to terminate her, and therefore, qualified immunity barred each of Respondent’s claims. View "W. Va. Bd. of Educ. v. Marple" on Justia Law

The government filed suit to collect unpaid federally reinsured student loans from defendant. The Higher Education Technical Amendments of 1991 (HETA) eliminated all statutes of limitations on actions to recover on defaulted federally guaranteed student loans. The court concluded that HETA did not violate defendant's due process rights because HETA’s elimination of the limitations period for actions to collect on federally guaranteed student loans does not result in a denial of due process. In this case, the government established a prima facie case through certificates of indebtedness, which were signed under the penalty of perjury, showing that defendant executed promissory notes to secure loans, defaulted on the loans, and owed the United States certain amounts after offsets from various sources. Defendant failed to present sufficient evidentiary facts to raise a genuine issue of material fact or a question as to liability for the alleged indebtedness. Accordingly, the court affirmed the district court's judgment in favor of the government. View "United States v. Falcon" on Justia Law

In 2013, Vaughn School District received a petition requesting the transfer of a specific portion of territory from Vaughn School District to the Power School District. A panel of three county school superintendents dismissed the school territory transfer petition on the ground that the transfer territory was located within three miles of an operating school - the Hillcrest Hutterite Colony Attendance Center. Power School District petitioned for judicial review of the superintendent panel’s decision. The district court affirmed. The Supreme Court affirmed, holding that the district court correctly held that the superintendent panel (1) did not act unreasonably in concluding that the attendance center operates as any public school in the state of Montana; and (2) did not abuse its discretion or err as a matter of law in interpreting the governing statutes. View "In re Vaughn Elementary School Petition" on Justia Law

In 2014, the Arkansas State Board of Education (State Board) classified six schools within the Little Rock School District as being in academic distress. In 2015, the State Board voted to immediately remove all members of the District’s board of directors and to direct the commissioner of education to assume the authority of the Board of Directors for the governance of the District. Appellees, three former members of the District board of directors and a parent whose children attend school in the District - filed an amended complaint for declaratory relief, writ of prohibition, writ of mandamus, and injunctive relief, alleging that the State Board’s actions were unconstitutional, ultra vires, arbitrary, capricious, and wantonly injurious. Appellants moved to dismiss the complaint, arguing that the action was barred by sovereign immunity. The trial court denied the motion to dismiss. Appellant subsequently filed this interlocutory appeal. The Supreme Court reversed and dismissed Appellees’ complaint, holding (1) the allegations in the complaint did not establish a sovereign-immunity exception; but (2) Appellees failed to establish in their complaint that the State Board acted arbitrarily, capriciously, or in bad faith in assuming control of the District. View "Key v. Curry" on Justia Law

At issue in this case was whether settlement agreements between a public school and the parents of a public school student who requires special education are public records subject to disclosure. Plaintiff requested from Defendant school district copies of such agreements where Defendant “limited its contribution to education funding or attached conditions for it for out of district placements” for certain school years. The school district denied the request. The superior court declared that the agreements were public records and were not exempt from disclosure. The Supreme Judicial Court vacated the judgment of the superior court and remanded, holding (1) the settlement agreements regarding placement of students in out-of-district private educational institutions are not “public records” under Mass. Gen. Laws ch. 4, 7; but (2) the settlement agreements may be redacted to remove personally identifiable information, after which they become subject to disclosure under Mass. Gen. Laws ch. 66, 10, the Massachusetts public records law. View "Champa v. Weston Public Schools" on Justia Law

Plaintiffs filed suit against the school district and its employees, alleging claims related to the sexual molestation of A.W. by her teacher. The district court dismissed the claims under Rule 12(b)(6) as time-barred. At issue is the Texas statute of limitations that applies to Title IX of the Education Act of 1972, 20 U.S.C. 1681 et seq., and 42 U.S.C. 1983 claims involving sexual abuse. The court concluded that the district court did not err in finding that plaintiffs’ Title IX and section 1983 claims are time-barred because plaintiffs' claims accrued more than two years prior to their filing suit and the equitable tolling principles they have identified do not apply. Accordingly, the court affirmed the judgment and did not reach the remaining issues raised on appeal. View "King-White v. Humble Indep. Sch. Dist." on Justia Law

Plaintiffs filed suit challenging a hearing officer's conclusion that the School Board had provided O.S. with a free and appropriate education (FAPE). The district court affirmed the hearing officer's decision. At issue was whether the standard for a FAPE under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq., has changed since Board of Education v. Rowley. The court held that it has not and that, in evaluating whether a school provides a FAPE, the court still looks to whether the individualized education program (IEP) provides some education benefit to the student. Applying that standard to this case, the court concluded that the district court did not err in finding that the School Board met that requirement. Accordingly, the court affirmed the judgment. View "O.S. v. Fairfax Cnty. Sch. Bd." on Justia Law