Justia Education Law Opinion Summaries

Chad Jones petitioned the Supreme Court for a writ of mandamus to direct the Circuit Court to vacate its order denying his motion for a summary judgment in an action filed against him by Latonya Hall, individually and as mother and next friend of Demetrius Hall, a minor, and Maurice Caffie, individually (collectively referred to as "Hall"), and to enter a summary judgment in his favor on the basis of State-agent immunity. Jones was employed as a physical-education teacher at Gresham Middle School and Demetrius Hall and Michael Boyd were students. A fight between the young men broke out during a school basketball game. According to Demetrius, he was guarding Boyd tightly when Boyd became angry and threw the basketball at him, striking him in the face with the ball. Demetrius responded by pushing Boyd and throwing a punch. After the two exchanged insults, another student unexpectedly shoved Demetrius into Boyd, and Boyd responded by "slamming" Demetrius into some nearby metal stairs and striking him in the head. Demetrius was seriously injured as the result of the altercation. Jones contends that he was at the opposite end of the gym when the altercation occurred. Hall sued Jones, Sokol, and Sammy Queen, (another school physical-education teacher) asserting claims of negligence and wantonness and alleging that the defendants had breached their duty to reasonably supervise Demetrius and Boyd by leaving them unattended for an extended length of time. Concluding that Jones failed to demonstrate that he had a clear legal right to the relief sought, the Supreme Court denied his petition for a writ of mandamus. View " Hall v. Jones" on Justia Law

Plaintiffs, on behalf of their daughter, filed suit challenging the district's implementation of a new individualized education program (IEP) for their daughter under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq. Determining that the daughter's case was not moot, the court concluded that the court need not decide whether the various notice requirements were satisfied because whatever notice deficiencies there could have been in this case, they did not warrant relief; there was no error in requiring the parents to present a complaint and demand a due process hearing because they disagreed with the IEP team's decision; the district court correctly stated the Loren F. ex. rel. Fisher v. Atlanta Independent School System standard, fully reviewed the administrative record, and independently analyzed each of the parents' claims; the district court did not abuse its discretion when it issued the parents' proposed order and then decided the case on summary judgment; and the court held that 42 U.S.C. 1983 actions for denial of rights conferred by the IDEA were barred because the IDEA's comprehensive enforcement scheme provided the sole remedy for statutory violations and, therefore, the district court did not err in dismissing the parents' section 1983 claims. Accordingly, the court affirmed the judgment of the district court.View "K.A. v. Fulton County Sch. Dist." on Justia Law

Central States, an employee benefit plan governed by the Employee Retirement Income Security Act, provides health insurance for Teamsters and their families. Guarantee Trust provides sports injury insurance for student athletes. Each of 13 high school and college athletes, all children of Teamsters, holds general health insurance from Central and sports injury insurance from Guarantee. Each suffered an injury while playing sports (most often football) between 2006 and 2009, and sought coverage from both companies. Each time Guarantee refused to pay the athlete’s medical expenses, and each time Central paid the bill under protest. The district court entered a declaratory judgment under ERISA, 29 U.S.C. 1132(a)(3)(B), that, when coverage of student athletes overlap, Guarantee must pay, and ordered Guarantee to reimburse Central for the payouts to the 13 students. The Sixth Circuit, affirmed in part characterizing the case as a “you first” paradox, or ‘gastonette.” An ERISA plan may coordinate benefits with another policy, but may not redefine the coverage of another policy. Absent the Central plan, the Guarantee policy would cover the sports injuries at issue without question. An ERISA plan must keep doing what it would do in another plan’s absence. That amounts to coordinating benefits, not redefining coverage. View "Cent St, SE & SW Areas Health & Welfare Fund v. First Agency, Inc." on Justia Law

Charleston began his fourth year at the College of Medicine in 2010, having finished his Obstetrics and Gynecology clinical rotation in June. In September, Charleston’s preceptors submitted a complaint, asking that Charleston be required to repeat the rotation, alleging that Charleston had committed errors in written work (including plagiarism), did not complete quizzes until after the rotation’s conclusion, did not have required signatures in his case log, spent four weeks without a preceptor, and he did not perform well enough to pass. The Student Progress Committee held a meeting; Charleston was not permitted to attend, but submitted a letter. The Committee recommended that Charleston be assigned a mentor in the future. Without notice to Charleston, the complaint and Charleston’s letter were forwarded to the Executive Committee with a new letter from Hall, Associate Dean for Student Affairs for the College of Medicine, alleging that in 2008, Charleston had acted “unprofessionally” while serving as a teaching assistant. Charleston had no opportunity to address Hall’s allegation, which, he claims, was false. The Executive Committee decided that Charleston should be dismissed. Internal appeals failed. His suit under 42 U.S.C. 1983, claiming procedural due process, substantive due process, and equal protection violations, was dismissed for failure to plead sufficient facts to establish a protected property interest in his continued education, nor to demonstrate that the university singled him out for unfavorable treatment. The Seventh Circuit affirmed.View "Charleston v. Bd. of Trs. of the Univ. of IL" on Justia Law

Kristin May was employed as a teacher at River Ridge High School, a public secondary school. In January 2011, May spoke with a former student, sixteen-year-old P. M., who no longer was enrolled as a student at River Ridge, and who recently had transferred to a school in the Fulton County School District. As they spoke, P. M. disclosed that she previously had a sexual relationship with Robert Morrow, a paraprofessional at River Ridge. May, however, did not make any report of the sexual abuse. When these circumstances later came to the attention of law enforcement, May was charged by accusation with a criminal violation of OCGA 19-7-5. May filed a demurrer and plea in bar, contending that the accusation charged no crime as a matter of law. When the trial court heard argument, the State and May stipulated to certain facts, namely that P. M. was no longer was a student at River Ridge when she spoke with May in 2011. Because P. M. was not then enrolled at River Ridge, May argued she had no duty under OCGA 19-7-5 (c) (1) to make a report. The trial court denied the demurrer and plea in bar, reasoning that a school teacher is required to report the abuse of any child, even one with whom the teacher has no relationship at all. After review, the Supreme Court concluded May had no legal obligation to report the sexual abuse, and the trial court erred when it sustained the accusation. View "May v. Georgia" on Justia Law

After the foreign language taught at Knott County Central High School was switched from French to Spanish, Grace Patton, the high school's French teacher, lost her job. Patton brought suit against Appellants - the Knott County Board of Education, individual Board members, the high school principal, the superintendent, and individual members of the school's Site-Based Decision-Making Council. Appellant's complaint did not specifically identify any particular claim or cause of action. The trial court granted summary judgment in favor of Appellants. The court of appeals reversed on the grounds that (1) Patton's complaint had stated a claim against the school board under the whistleblower statute, and the evidence precluded summary judgment; and (2) the individual Appellants were not subject to qualified official immunity because the actions taken to Patton's detriment were ministerial, not discretionary. The Supreme Court reversed, holding (1) Patton did not state a claim under the whistleblower act and had no claim under the act under the facts as alleged; and (2) the individual Appellants were engaged in the performance of discretionary duties covered by the qualified official immunity doctrine.View "Knott County Bd. of Educ. v. Patton" on Justia Law

Diadenko began working at Schurz High School in 2009 and became aware of practices relating to Individualized Education Plans for the school’s special education department that, in her opinion, were problematic. After voicing her concerns to school administrators, Diadenko wrote Chicago Mayor Daley His office forwarded her letter to the Board of Education. A Chicago Public School investigator looked into Diadenko’s allegations, but in the interim Diadenko was suspended twice for violating school policies. Diadenko and three others filed suit under 42 U.S.C. 1983, alleging violations of their rights under the First and Fourteenth Amendments and under Illinois law by retaliation for speaking out and for refusing to engage in illegal activity occurring within the school. The court granted the defendants summary judgment. The Seventh Circuit affirmed. Diadenko failed to present evidence that the principal was aware of her letter to the Mayor before taking disciplinary action against her. View "Diadenko v. Folino" on Justia Law

After a hearing, the Department of Children and Families substantiated allegations that Plaintiff, an elementary school teacher, emotionally abused one of his students and recommended that Plaintiff’s name be placed on the Department’s central registry of child abuse and neglect. The trial court affirmed, ruling that the ultimate finding of the administrative hearing officer was supported by substantial evidence. The Appellate Court reversed and ordered the Department to remove Plaintiff’s name from the central registry. The Supreme Court reversed, holding that the Appellate Court (1) failed properly to credit the factual findings and legal conclusions of the administrative hearing officer; and (2) improperly concluded that the definition of “abused” found in Conn. Gen. Stat. 46b-120(3) was void for vagueness as applied to the facts of this case. View "Frank v. Dep’t of Children & Families" on Justia Law

Plaintiff filed suit against the school district, claiming that he was retaliated against by the school district because he made public statements to the press regarding the accreditation investigation of the school district. Because plaintiff was not speaking pursuant to any official duties for the school district, bur rather was speaking in his capacity as president of the Georgia Association of Educators, the district court erred when it held that plaintiff's speech fell under the rule announced in Garcetti v. Ceballos. Accordingly, the court vacated the district court's order granting summary judgment in favor of the school district and remanded for further proceedings. View "Hubbard v. Clayton Co. Sch. Dist., et al." on Justia Law

Aaron Cannon, a student at Palmer College of Chiropractic, was blind and requested that Palmer make accommodations for his visual disability. Palmer denied the request, explaining that it could not provide the proposed accommodations and curricular modifications because they would fundamentally alter its educational program. Cannon eventually withdrew from the program. Cannon filed a complaint with the Davenport Civil Rights Commission, arguing that Palmer had discriminated against him on the basis of his disability. The Commission granted relief, finding that Palmer had failed to comply with the applicable federal and state disability laws. The district court reversed. The Supreme Court reversed, holding that the Commission did not erroneously interpret or irrationally apply the applicable law in concluding that Palmer failed to establish that Cannon’s suggested accommodations would fundamentally alter its curriculum. View "Palmer College of Chiropractic v. Davenport Civil Rights Comm’n" on Justia Law