Justia Education Law Opinion Summaries

A panel of the Ninth Circuit filed an amended opinion in this dispute regarding attorney’s fees. In the amended opinion, the panel affirmed in part and reversed in part the district court’s award of attorney’s fees and costs to Capristrano Unified School District as the prevailing defendant in an action brought by the mother of a special education student alleging violations of the Individuals with Disabilities Education Act (IDEA), the Americans with Disabilities Act (ADA), the Rehabilitation Act, and 42 U.S.C. 1983. The panel (1) agreed with the district court that the ADA and section 1983 claims were frivolous and affirmed the award of attorney’s fees and costs for representation relating to those claims; and (2) disagreed with the district court that the IDEA and Rehabilitation Act claims were frivolous and/or brought for an improper purpose and reversed the district court to the extent that it awarded attorney’s fees and costs related to the litigation of those claims. The cause was remanded. The panel also filed an order amending the opinion, denying a petition for rehearing and a suggestion for rehearing en banc, and directing the mandate to issue forthwith. View "C.W. v. Capistrano Unified Sch. Dist." on Justia Law

In 2000, California voters enacted Proposition 39, which provides that school districts must share their facilities with charter schools so that charter school students have access to facilities “reasonably equivalent” to facilities available to other public school students. Two years later, the State Board of Education issued regulations on how to implement this requirement. This action concerned the meaning of a Board regulation that governs the allocation of classrooms to charter schools. In allocating classrooms to charter schools, the Los Angeles Unified School District used “norming ratios,” which purported to establish throughout the District a uniform student/teacher ratio in a given grade level. The California Charter Schools Association (CCSA) sought declaratory relief, contending that the District violated the regulation governing the allocation of classrooms to charter schools by, inter alia, using these norming ratios rather than counting classrooms in comparison group schools to determine the allocation of classroom facilities. The Supreme Court agreed with CCSA and held that the District’s use of norming ratios, rather than counting classrooms in comparison group schools, violated the applicable regulation. In responding to future facilities requests, the District must count classrooms in a manner that conforms to the regulation. View "Cal. Charter Schs. Ass’n v. L.A. Unified Sch. Dist." on Justia Law

The issue before the Court of Appeal in this case was one of yoga: whether a school district's implementation of a yoga program as a component of its physical education curriculum was an impermissible establishment of religion in violation of the California Constitution. Appellants Stephen and Jennifer Sedlock (and their two minor children), filed suit against the Encinitas Union School District, the school's superintendent and the District's five governing board members, alleging that an Ashtanga yoga program violated various religious freedom provisions of the Constitution. The Sedlocks sought a writ of mandate and brought claims for injunctive and declaratory relief in which they requested that the court enjoin the District from continuing to implement its yoga program and declare the program unconstitutional. The Sedlocks were ultimately unsuccessful in having yoga declared unconstitutional, and they appealed that judgment. "While the practice of yoga may be religious in some contexts, yoga classes as taught in the District are, as the trial court determined, 'devoid of any religious, mystical, or spiritual trappings.'" The Court of Appeal concluded that the trial court properly determined the District's yoga program did not constitute an establishment of religion in violation of article I, section 4 of the California Constitution. View "Sedlock v. Baird" on Justia Law

After David Powers had completed three semesters as a part-time law school student at St. John’s University School of Law, the law school discovered that Powers had made material misrepresentations and omissions in his law school application regarding his criminal history. St. John’s subsequently rescinded Powers’s admission based on the application’s material omissions and misrepresentations. Powers subsequently brought this N.Y. C.P.L.R. 28 proceeding against the law school. The Appellate Division concluded that St. John’s determination to rescind Petitioner’s admission was not arbitrary and capricious and did not warrant judicial intervention. The Court of Appeals affirmed, holding that the law school’s penalty of rescission for Powers’s failure to truthfully and fully disclose his record was not excessive. View "Powers v. St. John's Univ. Sch. of Law" on Justia Law

Fifteen-year-old Abel Limones suddenly collapsed during a high school soccer game from a previously undetected underlying heart condition. Twenty-six minutes after Abel’s initial collapse, emergency responders revived him. Abel survived but suffered a severe brain injury due to a lack of oxygen over the time delay involved. Abel’s parents (Petitioners) filed this action against the School Board of Lee County (Respondent) alleging that Respondent breached both a common law and a statutory duty when it failed to apply an automated external defibrillator on Abel after his collapse. The trial court granted summary judgment for Respondent. The Second District Court of Appeal affirmed. The Supreme Court quashed the decision below and remanded for trial, holding that Respondent owed a common law duty to supervise Abel, and once Abel was injured, Respondent owed a duty to take reasonable measures and come to his aid to prevent aggravation of his injury. View "Limones v. Sch. Dist. of Lee County" on Justia Law

Valerie Addis left her position as supervisor of food services with the Missoula County Public Schools (Schools) after the Schools conducted an investigation of Addis into whether she had engaged in fraudulent or illegal financial transactions. Certain media organizations (Respondents) requested that the Schools release documents related to Addis’ termination. The Schools, in order to avoid being sued by either the media outlets or Addis, commenced the present action in district court seeking an in camera review of the Addis documents and a determination as to whether they should be released. After conducting an in camera examination of the Schools’ records, the district court concluded (1) Addis had a right of privacy in some of the documents and they, therefore, should not be released; but (2) six documents relating to misuse of public money, misuse of public facilities, and careless management practices should be released. The Supreme Court affirmed, holding that the district court properly determined that the six disputed documents should be released. View "Missoula County Pub. Schs. v. Addis" on Justia Law

David Quolke, the president of the Cleveland Teacher’s Union, requested from the Strongsville City School District Board of Education the names and identification numbers of all teachers and replacement teachers employed by the Board during a teachers’ strike. The Board claimed that many of the records were not subject to disclosure, asserting that the names of the replacement teachers were not considered public record because of the threat of harm to those teachers. Quolke sued in mandamus in the court of appeals for the records. The court of appeals found for Quolke and ordered the Board to produce the names. The Supreme Court affirmed, holding that, while there may have been a genuine threat to the replacement teachers’ well-being during the strike, the Board presented little evidence that there was any remaining threat to the teachers now that the strike was over. View "State ex rel. Quolke v. Strongsville City Sch. Dist. Bd. of Educ." on Justia Law

The Professional Massage Training Center (PMTC) filed suit against the Accreditation Alliance of Career Schools and Colleges (ACCSC) after ACCSC denied PMTC’s application for re-accreditation. The district court entered judgment in favor of PMTC, finding that ACCSC had violated the school’s due process rights. The court awarded the school more than $400,000 in damages and ordered ACCSC to fully reinstate its accreditation. The Supreme Court reversed in part and affirmed in part, holding (1) the district court erred in conducting a de novo approach to the accreditation process; (2) judged by the correct standard of review, the accreditation decision was well supported and not arbitrary or capricious; and (3) the district court correctly dismissed PMTC’s state law claims for breach of contract, negligence, and tortious interference. Remanded. View "Prof’l Massage Training v. Accreditation Alliance of Career Schs." on Justia Law

In 2010, due to a large budget deficit, Franklin Township Community School Corporation voted to discontinue transportation services for the majority of students attending its public schools. Parents of students who attend public schools in Franklin School Corporation brought a class action suit seeking a declaratory judgment that discontinuing transportation is prohibited under the Education Clause of the Indiana Constitution. The trial court granted summary judgment in favor of Franklin School Corporation. The Supreme Court affirmed, holding that the Indiana Constitution does not mandate school corporations to provide transportation to and from school, and therefore, Franklin School Corporation did not violate a constitutional mandate. View "Hoagland v. Franklin Township Cmty. Sch. Corp." on Justia Law

Lyons, a part-time lecturer at the University of Missouri at Kansas City, gave a student athlete a grade of “F” in the Fall 2010 semester. The student appealed. Lyons’s supervisor determined the student should be allowed to submit a second paper. Lyons complained to Dean Vaught, who referred the appeal to the Academic Standards Committee, which also determined the student should be allowed to write a second paper. Vaught upheld the ruling. The student submitted a second paper. An appointed committee gave it a 75% grade; Vaught instructed the registrar to change the student’s course grade to D. Lyons then met with Chancellor Morton, claiming preferential academic treatment for student athletes. Morton did not take action. Lyons continued to pursue the matter. He received no advance notice that his course would be eliminated for the Spring 2012 semester. Lyons sued for First Amendment retaliation, 42 U.S.C. 1983. The defendant-administrators unsuccessfully moved to dismiss, alleging that Lyons failed to state a claim and they were entitled to qualified immunity. The Eighth Circuit reversed. Lyons failed to allege plausibly that his only constitutionally protected speech could have been a substantial or motivating factor in defendants’ alleged adverse employment action. View "Lyons v. Vaught" on Justia Law