Justia Education Law Opinion Summaries

Antonio T., a seventeen-year-old high school student, was taken to the principal's office because he was suspected of being under the influence of alcohol. The assistant principal questioned Antonio about his possession of alcohol in the presence of a deputy sheriff. Antonio admitted that he had brought alcohol to school, where he drank it. At the principal's request, the deputy administered a breath alcohol test to Antonio, which was positive for alcohol. After administering the test, the deputy advised Antonio of his right to remain silent, and Antonio declined to answer the questions. Antonio was charged with the delinquent act of possession of alcohol by a minor. He filed a motion to suppress the statements he made to the assistant principal because his statements were elicited without a knowing, intelligent, and voluntary waiver of his right to remain silent. The district court denied his motion, which was affirmed by the Court of Appeals. The Supreme Court reversed both the district court and the Court of Appeals: although a school official may insist that a child answer questions for purposes of school disciplinary proceedings, any statements elicited by the official may not be used against the child in a delinquency proceeding unless the child made a knowing, intelligent, and voluntary waiver of his or her right to remain silent. Because the State failed to prove that Antonio effectively waived this right, his statements were inadmissible in the delinquency proceeding. View "New Mexico v. Antonio T." on Justia Law

Plaintiffs, the parents of a minor child with Asperger’s Syndrome, filed suit against the Commonwealth of Puerto Rico and the Puerto Rico Department of Education under a number of federal and state statutes for alleged retaliation and discrimination against their child. The Commonwealth moved to dismiss the claims against it pursuant to Fed. R. Civ. P. 12(b)(6) for failure to state a claim, which the district court granted. The First Circuit affirmed, holding (1) Plaintiffs did not sufficiently plead either discrimination or retaliation, and therefore, dismissal of their federal claims was proper; and (2) Plaintiffs’ argument that the Commonwealth waived its sovereign immunity under the Eleventh Amendment was waived for lack of development. View "Lebron v. Commonwealth of Puerto Rico" on Justia Law

In 1998, Jerry Lee Baldwin entered into a written agreement with the Board of Supervisors for the University of Louisiana System to serve as the head football coach at the University of Southwestern Louisiana, now University of Louisiana at Lafayette (UL). The contract provided that Baldwin’s employment with UL would last until January 31, 2003. By letter dated November 27, 2001, Baldwin was “relieved of [his] duties” as UL’s head coach effective November 26, 2001, after winning only six of twenty-seven games (an 18% win record). Baldwin continued to receive his full monthly salary and other employee benefits from UL including health insurance, accrual of leave time, and accrual of retirement credits for the remainder of the contract term. Baldwin sued the Board over the contract. Defendants sought review of the court of appeal’s determination that the coach’s contract had been terminated, which triggered a contractual obligation to provide notice. Interpreting the contract in its entirety, the Supreme Court found that the appellate court erred in finding that the failure of notice constituted a breach of contract under the facts of this case. Accordingly, the Court reversed the appellate court’s decision and reinstated the summary judgment rendered by the trial court, which dismissed the coach’s breach of contract claim against defendants. View "Baldwin v. Board of Supervisors for the University of Louisiana System" on Justia Law

The district court found that House Bill 974 of the 2012 Regular Session of the Louisiana Legislature, which was enacted as Act 1 of 2012 (Act 1), violated the single object requirement for legislative bills as provided for in La. Const. art. III, section 15(A). Act 1 of 2012 amended, reenacted and repealed various statutes in Title 17. Looking first at the title, and then to the body of Act 1, the Supreme Court concluded that the subject of the act is elementary and secondary education, and the object of the act was improving elementary and secondary education through tenure reform and performance standards based on effectiveness. After examining the numerous provisions of Act 1, the Court determined that "they all have a natural connection and are incidental and germane to that one object." In order to overturn a legislative enactment pursuant to the one-object rule, “the objections must be grave and the conflict between the statute and the constitution palpable.” In this case, the Supreme Court found that plaintiffs the Louisiana Federation of Teachers, East Baton Rouge Federation of Teachers, Jefferson Foundation of Teachers, Nellie Joyce Meriman, and Kevin Joseph DeHart, failed to establish that such a grave and palpable conflict existed between Act 1 and the one-object rule of La. Const. art. III, section 15. Because the district court pretermitted consideration of the other constitutional arguments raised by plaintiffs, i.e., that Act 1 violated due process rights pursuant to La. Const. art. I, section 2, and the Fifth and Fourteenth Amendments of the U.S. Constitution, the case was remanded for consideration of those issues. View "Louisiana Federation of Teachers v. Louisiana" on Justia Law

At issue in this case was whether the Education Law permits Nassau County to charge back to the Town of North Hempstead amounts the County paid on behalf of Town residents attending the Fashion Institute of Technology (FIT). The Town commenced this proceeding seeking a declaration that the County lacked authority to charge back FIT expenses to the Town. Supreme Court found that the County was entitled to collect chargebacks from the Town and that the County was entitled to offset the Town’s resulting liability by retaining the amount owed from the Town’s share of County sales tax revenue. The Appellate Division concluded that the County was required to adopt a formal resolution in order to authorize its treasurer to collect the chargebacks and that the County was not entitled to offset the amounts owed by the Town against the sales tax revenue. The Court of Appeals modified to uphold the County’s offsetting of the Town’s liability for FIT chargebacks from sales tax revenue, without requiring the issuance of a new resolution, and as so modified, affirmed. View "Matter of Town of N. Hempstead v. County of Nassau" on Justia Law

In 1989, Wheatley plaintiffs filed suit against the District alleging on-going violations of the Voting Rights Act, 42 U.S.C. 1971 et seq., and the Fourteenth Amendment. In 1990, the district court confirmed a settlement between the parties. In 2012, the District filed a motion to modify or terminate the settlement decree, seeking an order permitting the District to relocate the middle school grades from the Wheatley campus to the Palestine campus. The district court granted the motion and the Wheatley plaintiffs appealed. The court concluded that the district court properly applied the standards for modifying a consent decree when changed circumstances have caused it to be unjust under Rufo v. Inmates of the Suffolk County Jail. In this case, the district court did not abuse its discretion in approving the modification, which was directly related to the evidence of changed circumstances the District presented. Further, it is apparent from the face of the consent decree that many of its eleven contractual commitments were premised on continued use of two school campuses and, therefore, these provisions were effectively terminated. Other provisions in the decree do not require functioning schools in both communities. The district court did not intend that its order terminate the entire consent decree, and the court so construed its order. Accordingly, the court affirmed the district court's order. View "Smith, et al. v. Palestine-Wheatley Sch. Dist, et al." on Justia Law

Sallie Mae, real party in interest, appealed an order awarding plaintiffs attorney fees and costs after plaintiffs successfully opposed Sallie Mae's motion to quash a business records subpoena seeking electronically stored information regarding student loans. The court concluded that the trial court did not err by concluding that Sallie Mae lacked substantial factual justification for refusing to comply with the second subpoena. Therefore, the award of attorney fees was not an abuse of discretion and the court affirmed the judgment. View "Vasquez v. CA School of Culinary Arts" on Justia Law

Anita Cooper, who was employed as principal of the Oark, Arkansas schools, was removed from her duties as principal. The Superintendent of the Jasper School District No. 1 of Newton County listed nine reasons as bases for the termination. The District’s Board of Directors then terminated Cooper’s employment. The circuit court reversed the Board’s decision, reinstated Cooper to her position, and awarded Cooper $64,998 in damages. The Superintendent and District appealed. The Supreme Court affirmed, holding (1) the circuit court did not err in finding that Defendants failed to comply with the Teacher Fair Dismissal Act; (2) the circuit court did not err in concluding that the contract in the case at bar created a property right in Cooper’s position as principal of the Oark schools; and (3) the circuit court’s award to Cooper was neither excessive nor amounted to an award of “double retirement.” View "Jasper Sch. Dist. No. 1 v. Cooper" on Justia Law

Daniel Berman appealed a judgment denying his petition for writ of mandate against the Regents of the University of California. He wanted to overturn a two-quarter suspension from the University of California San Diego (UCSD), which was imposed against him for hitting another student in the head with sufficient force to knock the other student to the ground and to cause that other student to lose consciousness, sustain a concussion and require medical attention. Berman did not challenge the factual finding he violated UCSD's Student Conduct Code, rather, he argued the Code did not authorize either the student conduct officer responsible for his case (who is also a Dean of Student Affairs) or the Council of Deans of Student Affairs to impose suspension as a sanction when the student conduct review board did not recommend suspension. The Court of Appeal reviewed the case, disagreed with Berman's arguments and affirmed the suspension. View "Berman v. Regents of UCSD" on Justia Law

Plaintiffs filed a class action against Sweetwater, alleging unlawful sex discrimination under Title IX of the Education Amendments of 1972 (Title IX), 20 U.S.C. 1681 et seq. Plaintiffs alleged that Sweetwater intentionally discriminated against female student athletes when they failed to provide equal treatment and benefits as compared to male athletes. On appeal, Sweetwater challenged the district court's grant of declaratory and injunctive relief to plaintiffs on their Title IX claims. The court concluded that Sweetwater has not fully and effectively accommodated the interests and abilities of its female athletes; the district court did not err in its award of summary judgment to plaintiffs on their Title IX unequal participation claim; and the court affirmed the grant of injunctive relief to plaintiffs on that issue. The court rejected Sweetwater's claims of evidentiary errors; the district court's ruling that plaintiffs have Article III standing and its decision to deny Sweetwater's motion to strike that claim were not error; plaintiffs stated a prima facie case of Title IX retaliation; the district court correctly could find that a coach was fired in retaliation for plaintiffs' Title IX complaints, not for any of the pretextual, non-retaliatory reasons that Sweetwater has offered; and the district court did not abuse its discretion in granting permanent injunctive relief to plaintiffs on their claims. Accordingly, the court affirmed the judgment and rejected Sweetwater's attempt to relitigate the merits of its case. View "Ollier v. Sweetwater Union High Sch. Dist." on Justia Law