Justia Education Law Opinion Summaries

This case is about a dispute between Richard Roe and St. John’s University (SJU) and Jane Doe. Roe, a male student at SJU, was accused of sexually assaulting two female students, Doe and Mary Smith, on separate occasions. SJU's disciplinary board found Roe guilty of non-consensual sexual contact with both Doe and Smith and imposed sanctions, including a suspension and eventual expulsion. Roe then sued SJU, alleging that his rights under Title IX of the Education Amendments of 1972 and state contract law had been violated. He also sued Doe for allegedly defaming him in an anonymous tweet accusing him of sexual assault. The United States District Court for the Eastern District of New York dismissed Roe's Title IX and state law claims, and declined to exercise jurisdiction over his defamation claim. On appeal, the United States Court of Appeals for the Second Circuit affirmed the district court's decision, holding that Roe's complaint failed to state a plausible claim of sex discrimination under Title IX. The court found that, while Roe had identified some procedural irregularities in SJU's disciplinary proceedings, these were not sufficient to support a minimal plausible inference of sex discrimination. Furthermore, the court ruled that Roe's hostile environment claim was fatally deficient, as the single anonymous tweet at the center of his claim was not, standing alone, sufficiently severe to support a claim of a hostile educational environment under Title IX. View "Roe v. St. John's University" on Justia Law

In the case before the Supreme Court, State of Wyoming, the Petitioners, Kenneth Carson and Anna Leigh Anderson, parents of two children living in a remote family ranch in Wyoming, sought to compel the Albany County School District Board of Trustees, the Superintendent of Schools for Albany County, and the Superintendent of Public Instruction for the State of Wyoming (collectively, Respondents) to establish a rural school, named "The Buckle School," on their ranch. The proposal for this school was initially approved by the Albany County School District Board of Trustees and the Director of the State Construction Department. However, the State Superintendent of Public Instruction later denied the approval, citing the cost-effectiveness of the proposed school and the availability of virtual education options for the children.The Petitioners then filed a petition for a writ of mandamus in the district court, which was dismissed. Upon appeal, the Supreme Court, State of Wyoming, affirmed the lower court's decision. The court held that the Petitioners failed to demonstrate that the Respondents had a ministerial duty to form the school. A ministerial duty is a duty that is absolute, clear, and indisputable, involving merely execution of a specific duty arising from fixed and designated facts. The court found that the relevant statutes provided the Respondents with discretionary judgment, not a ministerial duty to approve or deny the formation of a rural school. The court further noted that the Petitioners had not shown that they had requested or were denied any transportation or maintenance payments, which the relevant statutes provide for in lieu of establishing a school. Therefore, the court concluded that the Petitioners had failed to state a claim upon which mandamus relief could be granted. View "Carson v. Albany County School District #1 Board of Trustees" on Justia Law

In a dispute arising from a contract for refurbishing an elementary school, the Supreme Court of Louisiana ruled that no unfair trade practices claim could be stated against the State of Louisiana, Department of Education, Recovery School District (the “State”). The plaintiff, Advanced Environmental Consulting, Inc. (“AEC”), had subcontracted to perform asbestos abatement services for Law Industries, LLC, the general contractor. When the State terminated the contract due to unsatisfactory asbestos remediation progress, AEC amended its answer to Law Industries' breach of contract suit to include a claim of unfair trade practices under the Louisiana Unfair Trade Practices and Consumer Protection Act (“LUTPA”). The State had objected to this claim, arguing that AEC had no cause of action and that the claim was perempted (time-barred). The Supreme Court of Louisiana held that AEC had failed to state a valid LUTPA cause of action against the State. It concluded that the State's actions were in furtherance of its governmental function of providing safe educational facilities for schoolchildren. The State, in this case, was a consumer of construction services, not a participant in "trade or commerce" as defined in the LUTPA, and was therefore not subject to a LUTPA claim. The court remanded the case to the district court for further proceedings consistent with its ruling. View "LAW INDUSTRIES, LLC VS. STATE" on Justia Law

The Maine Supreme Judicial Court ruled in favor of the University of Maine System (UMS) in a case involving Robert Bocko, who claimed that UMS failed to pay him wages on time as mandated by Maine law. Bocko, who was employed by UMS to teach law courses, argued that UMS violated the state's wage payment laws by not paying him at intervals not exceeding 16 days. UMS countered that Bocko was exempt from these requirements as he was a salaried employee. The court agreed with UMS, ruling that Bocko was indeed exempt from the wage payment requirements as he was compensated on a fee basis for teaching each course, rather than on a regular salary basis. The court found that the payment Bocko received for teaching each course met the salary-basis requirement when converted to an annual rate. Therefore, the court affirmed the Superior Court's judgment in favor of UMS. View "Bocko v. University of Maine System" on Justia Law

In the case before the Supreme Court of Alabama, Emma Louie, Garry Rice, and Toice Goodson, employees of the Greene County Board of Education, sought a writ of mandamus directing the Greene Circuit Court to enter a summary judgment in their favor, asserting that they are protected by State-agent immunity. The claims against them were brought by Ester Eaton and Anthony Eaton, who alleged negligence and loss of consortium after Ester Eaton, a substitute teacher, was attacked while supervising a classroom of students in the Alternative Program and in-school suspension (ISS). The defendants argued that their supposed violations of school policies were in fact based on discretionary decisions, not violations of specific, mandatory rules, thus entitling them to State-agent immunity.The Supreme Court of Alabama agreed with the defendants, ruling that the school guidelines in question were not specific, nondiscretionary rules, but rather allowed for administrative discretion. As such, the court found that the defendants' actions fell within the scope of their discretion as state agents, and they were therefore entitled to State-agent immunity. Consequently, the court granted the petition for a writ of mandamus and directed the trial court to enter a summary judgment in favor of the defendants. View "Ex parte Louie" on Justia Law

The Supreme Court of Mississippi examined whether a school district was entitled to funds recovered by a county from the bankruptcy proceedings of a delinquent taxpayer. The taxes, if collected normally, would have been used to fund the school district. However, the county board of supervisors had anticipated the delinquency and adjusted the levy of ad valorem taxes to compensate, ensuring the school district did not experience a shortfall. The school district argued it was entitled to its original portion of the recovered bankruptcy funds, but the county claimed that this would result in a double recovery outside the statutory scheme for public school funding. The Supreme Court of Mississippi found in favor of the county, ruling that the recovery of delinquent taxes through bankruptcy proceedings is outside the statutory funding scheme for public school districts in Mississippi. The court found that the school district was not entitled to receive delinquent taxes recovered years later in bankruptcy proceedings and reversed and remanded the lower court's award to the school district. View "Clarke County, Mississippi v. Quitman School District" on Justia Law

In 2023, the Texas Legislature passed the Restricting Explicit and Adult-Designated Educational Resources Act (READER), which requires vendors selling books to Texas public schools to issue sexual-content ratings for all library materials they have ever sold or will sell. Certain Texas bookstores, trade associations, and a legal defense organization sued for injunctive relief, alleging that READER violates their First and Fourteenth Amendment rights. The district court granted a preliminary injunction, which Texas appealed. The United States Court of Appeals for the Fifth Circuit affirmed the grant of the preliminary injunction against the Commissioner of the Texas Education Agency, vacated the preliminary injunction against the Chairs of the Texas State Library and Archives Commission and the Texas State Board of Education, and remanded the case to the district court with instructions to dismiss the suit against them. The court held that the plaintiffs were likely to succeed on their claim that READER unconstitutionally compels speech. The court also found that the plaintiffs would suffer irreparable harm if the injunction was not granted, the balance of equities tipped in their favor, and an injunction was in the public interest. View "Book People, Inc. v. Wong" on Justia Law

In this case, Jeffrey L. Cruce, the former head football coach and athletic director for Berkeley High School, filed a lawsuit against the Berkeley County School District (the District) for wrongful termination and defamation. The defamation claim was based on an email circulated by an athletic trainer questioning the integrity of student athlete files maintained by Cruce. The court of appeals had ruled that Cruce was a public official for the purposes of defamation law, and thus required to prove actual malice to win his defamation claim, which the South Carolina Tort Claims Act (SCTCA) grants the District immunity from.The Supreme Court of South Carolina disagreed, stating that being a public employee and enjoying media attention does not make Cruce a public official, as he did not have any official influence or decision-making authority about serious issues of public policy or core government functions. The court also rejected the District's claim that Cruce was a public figure, stating that the controversy over Cruce's coaching tactics did not affect large segments of society and was unrelated to the defamation claim. The court ruled that Cruce was not a public official, not a public figure, and that his defamation claim was supported by evidence, reversing the decision of the court of appeals and reinstating the jury's damages award. View "Cruce v. Berkeley County School Dist" on Justia Law

In this case, Alyssa Reid, a former faculty member at James Madison University (JMU) in Virginia, was accused of violating JMU’s Title IX policy against non-consensual relationships based on her past relationship with a graduate student. JMU and its officials investigated the accusation and held a hearing, leading to a decision that Reid violated the policy. Reid appealed the decision to JMU’s provost, who denied her appeal. Subsequently, Reid sued JMU and several officials, raising three due process claims under both 42 U.S.C. § 1983 and the Virginia Constitution, as well as a sex discrimination claim under Title IX.The United States District Court for the Western District of Virginia held that Reid’s claims accrued when the dean made his decision, and thus they were barred by the applicable two-year statute of limitations. Reid appealed this decision, arguing that her claims accrued not when the dean issued his decision, but when the provost denied her appeal.The United States Court of Appeals for the Fourth Circuit agreed with Reid. The court found that Reid did not have a complete and present cause of action until JMU reached a final decision in her Title IX proceedings. The court determined that JMU did not make clear that the dean’s decision was its official position. Rather, JMU’s official position was made clear to Reid when the provost denied her appeal with a “final,” non-appealable decision. Therefore, Reid’s due process and Title IX claims were not barred by the applicable two-year statute of limitations, and the court reversed the district court's dismissal of Reid’s claims and remanded for further proceedings. View "Reid v. James Madison University" on Justia Law

In a dispute between Timothy Towne and the Unified School District No. 259, the Supreme Court of the State of Kansas reversed the lower courts' rulings, finding that self-insured school districts are not exempt from regulation under the Kansas Insurance Code. Towne, an employee of the school district, was injured in a car accident and received benefits from the school district's self-funded medical benefit plan. After Towne recovered funds from a third party, the school district required him to reimburse the plan. Towne claimed that the plan's subrogation clause, which allowed for this reimbursement, was unenforceable under Kansas regulations. The district court and Court of Appeals held that the school district's plan was exempt from the Kansas Insurance Code, thereby making the subrogation clause enforceable. However, the Supreme Court reversed, holding that the medical benefit plan offered by the school district is a "health benefit plan" and the school district is a "health insurer" under Kansas law, making the school district subject to the anti-subrogation regulation. The case was remanded for further proceedings. View "Towne v. U.S.D. 259" on Justia Law