Justia Education Law Opinion Summaries

Plaintiffs sought a judicial determination that the 2011 legislative changes made to North Carolina's pre-kindergarten program failed to comply with the state's constitutional obligations recognized in Leandro v. State and Hoke County Board of Education v. State. After a hearing, the trial court found that some of the changes violated the State Constitution and mandating that the State not deny any eligible at-risk four-year-old admission to the North Carolina pre-kindergarten program. While the State's appeal was pending, the General Assembly amended the challenged statutory provisions. The court of appeals subsequently affirmed the trial court in part and dismissed the appeal in part. The Supreme Court dismissed the State's appeal as moot because the 2012 amendments constituted material and substantial changes to the provisions that the trial court found unconstitutional, and thus the questions originally in controversy between the parties were no longer at issue.View "Hoke Cnty. Bd. of Educ. v State" on Justia Law

Freeholders filed successfully filed petitions to move their property from the Prague Public School District to the Wahoo Public School District. East Butler County School District objected to the petitions because East Butler and the Prague District had a petition pending before the State Committee for the Reorganization of School Districts involving a proposed merger plan that encompassed the Freeholders' property. The Supreme Court concluded that East Butler had standing to appeal the Board's decision and remanded. On remand, the district court determined that the Board had jurisdiction over the Freeholders' petitions, thus rejecting East Butler's argument that the Reorganization Committee had exclusive jurisdiction to act in the matter under the "prior jurisdiction rule." The district court affirmed. The Supreme Court affirmed, holding that the prior jurisdiction rule, if adopted, did not apply to this case, and thus the Board had jurisdiction over the freeholder petitions.View "Butler County Sch. Dist. v. Freeholder Petitioners" on Justia Law

Plaintiff Stephen Dichiara, Jr. appealed a superior court order that granted summary judgment to defendants Sanborn Regional School District and Robert Ficker on municipal immunity grounds. Plaintiff tried out for the high school basketball team; Ficker was the team's coach. At the tryout, plaintiff played in a 'loose ball' drill when he collided with another player and suffered substantial injury to his arm. Plaintiff sued for negligence and respondeat superior liability of the school district. On appeal, plaintiff argued the trial court misinterpreted the applicable statute when it held that a municipality is only liable for negligence arising out of the ownership, occupation, maintenance or operation of a motor vehicle or premises. Essentially, the plaintiff maintained that, under RSA 507-B:2, a governmental unit is liable for bodily injuries “caused by its fault or by fault attributable to it,” regardless of any connection to a motor vehicle or premises. While most personal injury actions are unlikely to involve a nexus with a premises or vehicle, there are circumstances under which a plaintiff could recover for a personal injury under RSA 507-B:2. This case did not fall within that exception. Therefore the Supreme Court affirmed the superior court's grant of summary judgment.View "Dichiara, Jr. v. Sanborn Regional High School" on Justia Law

After unsuccessfully seeking reimbursement from the State Commissioner of Elementary and Secondary Education, Plaintiffs, a school district and school department, filed a complaint in the superior court alleging that the Commissioner and State Treasurer were required to reimburse them for the salary, fringe benefits, and travel expenses of the directors and guidance counselors in their vocational-technical programs. The superior court dismissed the complaint, concluding that Plaintiffs had an adequate remedy at law and that the Commissioner’s decision to deny Plaintiffs reimbursement was discretionary in nature, rather than ministerial. Plaintiffs subsequently sought a writ of mandamus. The Supreme Court affirmed the judgment of the superior court, holding that Plaintiffs did not have a clear legal right to be reimbursed for certain costs associated with the operation of their career and technical centers. View "Chariho Reg’l Sch. Dist. v. Gist" on Justia Law

The issue this case presented for the Supreme Court's review was the interpretation of the Commonwealth Charter School Law. Pursuant to the Charter School Law, the Walter D. Palmer Leadership Learning Partners Charter School was awarded a charter for a five-year term ending June 30, 2005. In late 2004, the Charter School filed a renewal application. On March 16, 2005, the School Reform Commission of the School District of Philadelphia (“SRC”) adopted a resolution that granted, “upon signing a new Charter Agreement,” the Charter School’s request for renewal of the charter for a second five-year period commencing on September 1, 2005. The SRC denied the Charter School's request for expansion of enrollment, and granted approval "to enroll a maximum of six hundred and seventy five (675) students and serve grades kindergarten through 8." The SRC and the Charter School then entered into, as of September 1, 2005, a legally binding agreement that incorporated the SRC Resolution in its entirety and extended the charter for five years ("the 2005 Charter"). The 2005 Charter explicitly referenced and incorporated the SRC Resolution, one provision of which capped student enrollment, explicitly mandated that the Charter School comply with the SRC Resolution; and explicitly constituted a legally binding, mutual agreement of five years duration, the terms of which could not be changed absent a written agreement signed by both parties. The legally binding nature of the terms of the 2005 Charter was mandated by a provision of the Charter School Law. Notwithstanding the terms of the 2005 Charter, the Charter School consistently enrolled more than the 675 students permitted by that Charter. For the 2007-2008 school year, the Charter School’s average daily enrollment was approximately 729 students; for 2008-2009 and 2009-2010, the average daily enrollment was approximately 732 and 765 students, respectively. In each school year, the School District of Philadelphia provided funding for 675 students based on the 2005 Charter. In July 2010, asserting that it had been underpaid by the School District, the Charter School requested that the Pennsylvania Department of Education withhold $1,678,579 from the School District's basic education subsidy allocation as payment to the Charter School for the students it had educated in addition to the 675 students permitted by the enrollment cap for school years 2007-2008, 2008-2009, and 2009–2010. The School District objected to the withholding and a hearing was held before the Department. The Secretary of Education determined that the Charter School had agreed and legally assented to the enrollment cap when it signed the 2005 Charter, and therefore, the Charter School was not entitled to payment for students enrolled above that cap in the 2007-2008 school year. However, with regard to the school years 2008-2009 and 2009-2010, the Secretary determined that the enrollment cap set forth in the 2005 Charter was no longer valid because of the enactment of an amendment to the Charter School Law which had become effective on July 1, 2008 (24 P.S. section 17-1723-A(d)). Based on his interpretation, the Secretary concluded that, to maintain the 2005 Charter’s enrollment cap subsequent to the effective date of the amendment, the School District was required to re-obtain the Charter School’s “legal assent” to the cap. Ultimately, the Secretary determined that the Charter School was entitled to payment by the School District for the education of all the students enrolled in the school for the years 2008-2009 and 2009-2010, including those enrolled beyond the cap. The School District appealed to the Commonwealth Court, which affirmed. The School District appealed to the Supreme Court, which reversed: "based on the plain text of 24 P.S. section 17-1723-A(d), we conclude that an enrollment cap is valid if agreed to by the parties as part of a written charter." View "Sch. Dist. of Philadelphia v. Dept. of Education" on Justia Law

David Alba was appointed to serve as principal of an elementary school in Cranston, Rhode Island. Alba and the Cranston School Committee subsequently entered into an employment contract. Later, after a hearing, the Committee rejected a recommendation to renew Alba’s employment contract. Alba appealed the Committee’s decision. The Commissioner of Education denied and dismissed Alba’s appeal, concluding that Alba had received all the process to which he was entitled under the contract and the School Administrators’ Rights Act. The Board of Regents affirmed the Commissioner’s decision. The Supreme Court affirmed, holding (1) the Committee acted within its authority when it voted against the recommendation to renew Alba’s contract; and (2) the Committee’s nonrenewal of Alba’s contract did not deprive Alba of his rights under the Administrators’ Rights Act. View "Alba v. Cranston Sch. Comm." on Justia Law

Plaintiffs filed an action alleging that the practice by which the Nation’s pledge of allegiance is recited each morning in Defendants’ public schools violated (1) Plaintiffs’ equal protection rights under the Massachusetts Constitution because the pledge included the words “under God,” and (2) Mass. Gen. Laws ch. 76, 5, which prohibits discrimination in Massachusetts public school education. The superior court granted summary judgment in favor of Defendants and the intervenors. The Supreme Judicial Court affirmed, holding that the recitation of the pledge, which no student is required to recite, does not violate the Constitution or the statute. View "Doe v. Acton-Boxborough Reg’l Sch. Dist." on Justia Law

The Peoria School District employs 26 full-time and part-time individuals who work as security agents and guards. No other Illinois school district has this type of employee. These employees were represented by a union certified by the Illinois Educational Labor Relations Board since 1989. The last collective-bargaining agreement expired in June, 2010. In July, 2010, a statutory amendment, Public Act 96-1257, purported to remove these employees from the oversight of the Illinois Educational Labor Relations Board and redefine them as “public employees” subject to the Illinois Public Labor Relations Act and the jurisdiction of the Illinois Labor Relations Board. The School District sought a declaration that its labor disputes with these employees were governed by the statute concerning educational employees, rather than by the one concerning public employees, challenging the enactment as invalid “special legislation,” forbidden by the Illinois Constitution. The circuit court dismissed. The appellate court reversed. The Illinois Supreme Court reversed without remand, holding that the challenged statute is invalid as forbidden special legislation because its language does not apply prospectively to school districts which may, after its effective date, employ peace officers. Although a general law could have been passed which would have affected a generic class of individuals, here, the affected class was closed on the effective date of the enactment. View "Bd. of Educ. of Peoria Sch. Dist. No. 150 v. Peoria Fed'n of Support Staff" on Justia Law

While attending Wolf Point High School, Dalton Gourneau committed suicide in his home. Roxanne Gourneau, acting individually and on behalf of Dalton, filed a complaint against Wolf Point, the State, and the District Superintendent, alleging that Dalton's death was the direct and proximate result of Wolf Point's negligence. The district court granted summary judgment in favor of Wolf Point. The Supreme Court affirmed, holding that the record did not substantiate Roxanne's speculation that Wolf Point reasonably should have known Dalton's state of mind or that its conduct created a reasonable possibility of harm, and thus, Wolf Point owed no legal duty because Dalton's suicide was unforeseeable by Wolf Point.View "Gourneau v. Wolf Point Sch. Bd." on Justia Law

Plaintiffs, school committees of Woonsocket and Pawtucket and unnamed students, parents, and the superintendents from both districts, brought suit against the legislative and executive branches of Rhode Island’s state government challenging the state’s school funding formula. Specifically, Plaintiffs alleged violations of the Education Clause as well as violations of their substantive due process and equal protection rights because the formula failed to allocate adequate resources to less affluent communities. The superior court granted Defendant’s motion to dismiss the complaint. The Supreme Court affirmed, holding (1) prior case law as well as the separation of powers doctrine warranted dismissal of Plaintiffs’ Education Clause claim; and (2) Plaintiffs’ complaint was insufficient to establish potential substantive due process claims. View "Woonsocket Sch. Comm. v. Chafee " on Justia Law