Justia Education Law Opinion Summaries

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

In this school-funding dispute, a school district (District) filed an action on its own behalf and on behalf of its taxpayers to enjoin state actions in violation of state law and the Arkansas Constitution. The District alleged two claims against Appellees. The District then voluntarily nonsuited the special-and-local legislation claim so it could immediately appeal the adequacy claim in the "Beebe" case. The District brought the special-and-local-legislation claim as a separate case in the "Kimbrell" case. The Supreme Court dismissed the appeal of the Beebe case for a lack of finality. The circuit court subsequently consolidated the Beebe case and the Kimbrell case. After the circuit court decided the cases, the District appealed. The Supreme Court affirmed in part, reversed and remanded in part, and mooted in part, holding (1) the circuit court abused its discretion in ruling that some of the District's claims in the Beebe case were barred by res judicata but did not err in dismissing the District's other claims as barred by res judicata; (2) the circuit court did not err in striking the District's amended and supplemental complaint; and (3) the District's claims in the Kimbrell case were moot.View "Deer-Mt. Judea Sch. Dist. v. Kimbrell" on Justia Law

Sjöstrand graduated magna cum laude from Ohio State University in only two and a half years. She applied to the school’s Ph.D program in School Psychology, where her grade-point average (3.87) was tied for highest in the applicant pool and her GRE scores (combined 1110) exceeded OSU requirements. Sjöstrand suffers from Crohn’s disease. She claims that, in interviews, two of the program’s professors focused on her disease. Of seven applicants interviewed by the school, only Sjöstrand was rejected. She was initially told only that she did “not fit the program.” She sued under Title II of the Americans with Disabilities Act, 42 U.S.C. 12132, and the Rehabilitation Act, 29 U.S.C. 701. The district court granted OSU summary judgment. The Sixth Circuit reversed, finding that jury questions remained regarding whether she was rejected because of her disability.View "Sjostrand v. Ohio St. Univ." on Justia Law

A student athlete asked for a permanent injunction against the Oklahoma Secondary School Activities Association (OSSAA) to block it from enforcing its sanctions against the athlete following its determination that the student athlete, school, and others violated the OSSAA's rules and policies. The athlete appealed, challenging the applicable standard of review and alleging that the OSSAA's actions were arbitrary and capricious. In 2012, the OSSAA received a copy of a newspaper article concerning the school's successes attracting the attention of college football recruiters. Based on comments made in the article, the OSSAA became concerned that the school might have violated what the OSSAA considered to be its long-standing prohibition on member schools paying for their student-athletes to attend individual athletic camps. The OSSAA notified the school of its concerns and asked for confirmation as to whether it had paid for selected students to attend individual camps. The OSSAA alleges it received no response prior. Upon review, the Supreme Court concluded the trial court applied the incorrect standard of review, and that under any standard, the OSSAA's actions were arbitrary and capricious.View "Scott v. Oklahoma Secondary School Activities Ass'n" on Justia Law

In 2000, Arizona voters approved a referendum that statutorily directed the Legislature to annually increase the base level of the revenue control limit for K-12 public school funding. The measure was codified as Ariz. Rev. Stat. 15-901.01. For several years, the Legislature adjusted the base level and transportation support level annually for inflation, but the 2010-11 budget (HB 2008) included an adjusted to the transportation support level only. Subsequent budgets likewise did not include base level adjustments. Several school districts and other parties sued the State Treasurer and State, alleging that HB 2008 amended or repealed a voter-approved law in violation of the Voter Protection Act (VPA). The superior court dismissed the complaint for failing to state a claim, ruling that section 15-901.01 was not mandatory and that voters "cannot require the legislature to enact a law that provides for the appropriation" prescribed in the statute. The court of appeals reversed. The Supreme Court affirmed, holding that no constitutional impediment existed to the electorate's directive, and legislative adjustments to section 15-901.01's funding scheme are limited by the VPA. View "Cave Creek Unified Sch. Dist. v. Ducey" on Justia Law

Appellants filed four separate cases stemming from the Arkansas Department of Education's (ADE) administrative supervision of the Pulaski County Special School District (PCSSD) after the district was found to be in fiscal distress. In each of the cases, ADE filed a motion to dismiss, asserting that Appellants' claims for relief were barred by sovereign immunity because the complaints were brought against ADE regarding matters allegedly done in furtherance of ADE's official duties. The circuit court granted the motion in each of the four cases. Appellants appealed, asserting, inter alia, that the circuit court erred in dismissing ADE from their actions because the complaints alleged exceptions to the doctrine of sovereign immunity. The Supreme Court affirmed, holding that the circuit court did not err in granting ADE's motions to dismiss, as none of the recognized exceptions to the sovereign immunity doctrine applied in these cases.View "Fitzgiven v. Dorey" on Justia Law

The Atlanta Independent School System (APS) and the Atlanta Board of Education deducted a $38.6 million unfunded pension liability expense before calculating the amount of local revenue funds to be distributed to start-up charter schools within APS. The stated purpose for the change in funding was APSÕs need to pay down a large, unfunded pension liability for current and former APS employees that has been accruing since the 1980s. In response, start-up charter schools filed a petition for writ of mandamus seeking to compel appellants4 to distribute local revenue to the start-up charter schools without any deduction for APSÕs unfunded pension liability. The trial court granted the requested mandamus relief, finding the statutory funding formula set out by statute did not authorize appellants to subtract the $38.6 million from its calculation of local revenue. Finding no error in the trial court's grant of mandamus relief, the Supreme Court affirmed.View "Atlanta Independent School System v. Atlanta Neighborhood Charter School, Inc." on Justia Law

The Louisiana legislature established the Scholarship Program in 2012 to provide funding to low-income parents with children in failing schools so that they may have the option of sending them to better schools, including private schools, of their own choosing. Parents seek to intervene in this litigation between Louisiana and the federal government over the state's voucher program. The court concluded that the parents met the requirements for intervention as of right and reversed the district court's denial of their motion to intervene. View "Brumfield, et al. v. Dodd, et al." on Justia Law