Justia Education Law Opinion Summaries

In 1970, the district court determined that the City and the Board were operating racially segregated schools and directed them to submit desegregation plans that would establish a nonracial, unitary school district. This appeal stemmed from the district court's two desegregation orders. Plaintiffs moved to enjoin the implementation of the Board's 2011-2012 student assignment plan because it failed to move the school district toward unitary status. The district court denied relief. The court vacated the district court's ruling, holding that the district court erred when it failed to place the burden on the Board to show that the 2011-12 student assignment plan moved the school district toward unitary status. Subsequently, the district court granted the Board's motion requesting that the district court declare the school district unitary and the district court dismissed plaintiffs' request for an injunction as moot. The court affirmed, concluding that the district court acted within its discretion in choosing to address the Board’s motion for declaration of unitary status before ruling on plaintiffs’ motion for injunctive relief. Further, the district court did not clearly err in determining that the school district is unitary. View "Everett v. Pitt Cnty. Bd. of Educ." on Justia Law

Kansas developed a school financing scheme that sought to avoid “mak[ing] the quality of a child’s education a function of his or her parent’s or neighbors’ wealth.” Displeased with the outcome of school finance litigation in state court, plaintiffs, parents of students in the relatively wealthy Shawnee Mission School District (“SMSD”), sought federal intervention to upend decades of effort toward establishing an equitable school finance system in Kansas. Adopting a "kitchen-sink approach," they claimed that aspects of the state’s school financing regime violated their rights to free speech, to petition the government, to associate, to vote, to education, to equal protection of the laws, to direct the upbringing of their children, and to dispose of their property. Upon review of plaintiffs' "novel and expansive claims," the Tenth Circuit found no support and affirmed the district court’s orders denying plaintiffs’ motion for a preliminary injunction, granting in part defendants’ motions to dismiss, and denying reconsideration. View "Petrella v. Brownback" on Justia Law

Plaintiff filed suit challenging a noncompetitive bid contract between Fresno Unified and Contractor for the construction of a middle school, alleging that the project should have been competitively bid because the lease-leaseback arrangement did not create a true leaseback or satisfy the criteria for the exception in section 17406 of the Education Code. The trial court sustained demurrers filed by Fresno Unified and Contractor. The court concluded that the competitive bidding process required by section 17417 is subject to the exception contained in section 17406 and plaintiff adequately alleged three grounds for why section 17406’s exception did not apply to the lease-leaseback arrangement. The court also concluded that Government Code section 1090’s prohibition of such conflicts extends to corporate consultants. Plaintiff has stated a violation of Government Code section 1090 by alleging facts showing Contractor, as a consultant to Fresno Unified, participated in the making of a contract in which Contractor subsequently became financially interested. Accordingly, the court reversed the judgment. View "Davis v. Fresno Unified Sch. Dist." on Justia Law

After Ereck Plancher, a University of Central Florida (UCF) football player, collapsed and died during football practice conditioning drills, Ereck’s parents (the Planchers) filed a negligence action against UCF and UCF Athletic’s Association, Inc. (UCFAA). A jury found UCFAA, the statutorily authorized direct-support organization responsible for administering UCF’s athletics department, liable and awarded the Planchers $10 million in damages. The Court of Appeal reversed, concluding that UCFAA was entitled to limited sovereign immunity. The Planchers appealed, arguing that UCF did not have sufficient control over UCFAA’s day-to-day operations to entitle UCFAA to limited sovereign immunity. The Supreme Court affirmed, holding that UCFAA was entitled to limited sovereign immunity under Fla. Stat. 768.28 because it primarily acts as an instrumentality of the state. Remanded for entry of a judgment corresponding to the jury’s award of damages but limiting UCFAA’s liability to $200,000. View "Plancher v. UCF Athletics Ass’n, Inc." on Justia Law

Plaintiff filed suit under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq., seeking an order requiring DCPS to provide her son with compensatory education. The district court dismissed the suit as moot because the school system responded to the complaint by offering an individualized education plan that is adequate to keep the child on track going forward. The court concluded, however, that the district court failed to address whether the child was entitled to compensatory education, which is a remedy that remains available. Accordingly, the court reversed the judgment of the district court and remanded for further proceedings. View "Boose v. District of Columbia" on Justia Law

At issue before the Supreme Court in this case was a Superior Court's grant of summary judgment to defendants, Fairwinds Church and Fairwinds Christian School (collectively, “Fairwinds”), in an action brought by former student Kimberly Hecksher under the Child Victim‟s Act. Hecksher sued Fairwinds under the Act, arguing that Fairwinds, a small, religious school, was grossly negligent for failing to prevent sexual abuse by Ed Sterling (her foster father and her teacher at Fairwinds), that occurred while she was a student. Hecksher alleged that Sterling's wife and fellow-Fairwinds employee, Sandy Sterling, observed Sterling abusing Hecksher on school property, and that Sandy's knowledge of and tortious failure to report the abuse should have been imputed to Fairwinds. Hecksher also argued that Fairwinds was grossly negligent for failing to have a sexual abuse prevention policy in place and for not responding to red flags that Sterling posed a serious risk to Fairwinds students. The Supreme Court disagreed with the Superior Court's grant of summary judgment, finding several instances where reasonable jurors could have found differently than did the Superior Court. The Supreme Court therefore concluded material issues of fact remained, specifically as to whether Sandy's knowledge and conduct could be imputed to Fairwinds, and whether Fairwinds was grossly negligent for failing to have any sexual abuse prevention and detection policies in place and for failing to act on red flags that Sterling posed a serious risk to female students. Accordingly, the grant of summary judgment was reversed and the case remanded for trial. View "Hecksher v. Fairwinds Baptist Church, Inc., et al." on Justia Law

Sheridan Newspapers, Inc. filed a petition requesting release of minutes reflecting discussion by the Board of Trustees of Sheridan County School District #2 of a proposed multi-purpose recreational facility during executive sessions. In response, the Board asserted that the executive sessions were allowed under the Wyoming Public Meetings Act (WPMA), and the minutes were confidential. After reviewing the minutes in camera the district court entered an order granting summary judgment for the Board, concluding that all issues discussed by the Board during executive session were within the framework of what may be kept confidential pursuant to the WPMA. The Supreme Court reversed, holding that the minutes were so vague as to reveal virtually nothing about the Board’s discussions during executive sessions, and therefore, the minutes were not entitled to confidential treatment. Remanded. View "Sheridan Newspapers, Inc. v. Bd. of Trs." on Justia Law

The Belcourt School District operates within the Turtle Mountain Indian Reservation. The North Dakota Constitution requires that the District provide education to children who are Indians or reside on Indian reservations. The Tribe and School District have agreed to share responsibility for educating students, both Indian and non-Indian, residing on the Reservation, and entered into agreements in 2006 and 2009 that provided the District with exclusive authority to administer "day-to-day operations" at Turtle Mountain Community High School, including supervision and employment of staff. Tribe members sued, alleging defamation, excessive use of force, and multiple employment-related claims. The Tribal Court dismissed for lack of jurisdiction over the District and its employees for claims related to the employees' performance of their official duties. The Tribal Court of Appeals reversed, reasoning that the District signed the agreements, subjecting itself to Tribal jurisdiction. The federal trial court concluded that the Tribal Court had jurisdiction, based on the agreements. The Eighth Circuit reversed and held that the Tribal Court did not have jurisdiction, reasoning that the District was clearly acting in its official capacity, in furtherance of its obligations under the state constitution, when it entered into the agreements, View "Belcourt Pub. Sch. Dist. v. Davis" on Justia Law

Fort Yates School District operates within the Standing Rock Indian Reservation. The North Dakota Constitution requires that the District provide education to children who are Indians or reside on reservations. In 2003, the District and the Tribe entered into an Agreement, providing that both the Standing Rock and the Fort Yates School Boards would govern the school system; that all property or equipment purchased under the Agreement would generally be joint property; and that it "neither diminishes nor expands rights or protections afforded … under tribal, state or federal law." After a fight between two students, A. was suspended and C. obtained a restraining order against A. A. allegedly violated the restraining order by verbally harassing C. at school. The school suspended A. for 10 additional days. Murphy sued on behalf of her daughter, C., a Tribe member, in the Tribal Court, which held that it had jurisdiction. The District did not appeal to the Standing Rock Supreme Court, but filed suit in federal court against Murphy and the Tribal Court. The district court dismissed and remanded to the Tribal Court. The Eighth Circuit reversed with respect to Tribal Court jurisdiction, but affirmed dismissal of the Tribal Court on sovereign immunity grounds. View "Fort Yates Pub. Sch. Dist. v. Murphy" on Justia Law

The DeSoto County School District entered into a contract with a private entity called the Mississippi High School Activities Association (“MHSAA”). The terms of the contract allowed MHSAA to decide whether School District students were eligible to play high school sports. In making its decisions, MHSAA applied its own rules and regulations, and neither the School District nor its school board had input into the process. In 2012, R.T. was a star quarterback for Wynne Public School in Wynne, Arkansas. His parents, the Trails, decided that a change of school districts would be in R.T.’s best interests, so in January 2013 they bought a house in Olive Branch and enrolled R.T. in Olive Branch High School. Their daughter was to remain in Wynne until the school year ended. MHSAA determined that R.T. was eligible to compete in spring sports and allowed R.T. to play baseball. MHSAA conditioned R.T.’s continuing eligibility on the Trails’ daughter also enrolling in the School District at the start of the 2013-2014 school year. But, because the Trails’ daughter did not want to leave her friends behind in Arkansas, the family decided that one parent would stay in Arkansas with their daughter, as they had done during the spring semester, and the other parent would move to Mississippi and remain with R.T. On the eve of the 2013 football season, MHSAA notified the school and R.T. that, under its interpretation of its rules and regulations, R.T. was ineligible to play because it had determined that his family had not made a bona fide move to the School District. Neither the School District nor Olive Branch High School appealed through MHSAA’s internal procedure, so the Trails immediately filed a petition for a temporary restraining order (TRO) and preliminary injunction in the DeSoto County Chancery Court. The chancellor signed an ex-parte order granting the TRO and revoking MHSAA’s adverse eligibility determination. "While it generally is true that high school students have no legally protected right to participate in high school athletics,25 once a school decides to create a sports program and establish eligibility rules, the school—or as in this case, MHSAA—has a duty to follow those rules; and it may be held accountable when it does not do so. . . . And where, as here, the school delegates its authority to control student eligibility through a contract with a private entity, we hold that students directly affected by the contract are third-party beneficiaries of that contract. For us to say otherwise would run contrary to the very reason for extracurricular activities, which is to enrich the educational experience of the students." R.T. had standing to challenge MHSAA's eligibility decision that prevented him from playing high school sports. The Court affirmed the chancery court in this case, and remanded the case for further proceedings. View "Mississippi High School Activities Association, Inc. v. R.T." on Justia Law