Justia Education Law Opinion Summaries

The American Federation of Teachers, its St. Louis affiliate, and individual representatives appealed the trial court's summary judgment declaring that the board of education of the Construction Career Center Charter School District and the individual members of the board had no duty to "meet and confer" or to bargain collectively in good faith with the union. The Supreme Court reversed, holding that because Mo. Const. art. I, 29 provides that all employees, public and private, have a right to organize and to bargain collectively, it necessarily requires the board to meet and confer with the union, in good faith, with the present intention to reach an agreement. Remanded.View "Am. Fed'n of Teachers v. Ledbetter" on Justia Law

The City of St. Louis appealed the trial court's holding that the prohibition against special laws contained in Mo. Const. art. III, 40 was not violated by Mo. Rev. Stat. 320.097. That statute exempted certain veteran firefighters who lived in areas with unaccredited or provisionally accredited school districts from any local laws requiring them to live in their home district. The State also appealed, alleging (1) the trial court erred in holding that section 320.097 violated what the trial court believed was the "broad measure of complete freedom from State legislative control" given to constitutional charter cities by the Missouri Constitution, and (2) the trial court erred in holding that the statute violated the equal protection clauses of the Missouri and U.S. constitutions because it was not rationally related to any legitimate purpose. The Supreme Court (1) affirmed the trial court's holding that the statue was not a special law in violation of the Missouri Constitution; (2) reversed the trial court's holding that the statute violated the state constitution because it interfered with the City's right to set its employees' and officers' powers, duties and compensation; and (3) reversed the trial court's holding that the statute violated equal protection guarantees. View "City of St. Louis v. State" on Justia Law

Plaintiffs brought suit against Defendant, the Cranston School Department, seeking grievance arbitration of adverse actions taken against them as to their respective coaching positions at Cranston West High School. Plaintiffs, both of whom were teachers at Cranston West, separately filed grievances against Defendant in accordance with the collective bargaining agreement (CBA) that was in place between the Cranston Teacher's Alliance and the school department. Defendant responded that the CBA did not apply to Plaintiffs in their capacity as coaches, and it refused to submit to arbitration. Plaintiffs filed suit, seeking a declaratory judgment that they were entitled to binding arbitration as guaranteed by the CBA. The superior court ruled in favor of Defendant, determining that Plaintiffs, in their capacity as coaches, were not entitled to avail themselves of the CBA's grievance procedures. The Supreme Court affirmed, holding (1) the trial justice was correct in determining that Plaintiffs' coaching positions were contractually distinct from their teaching positions and did not constitute professional employment; and (2) Plaintiffs in their coaching capacities had no right to pursue relief based on the rights bargained for by the alliance on behalf of its teacher-members and as contained in the CBA.View "Sacco v. Cranston Sch. Dep't" on Justia Law

The parents of fourteen Jefferson County schoolchildren brought this action claiming Ky. Rev. Stat. 159.070 grants their children a statutory right to attend the public school nearest their home. The Jefferson County Board of Education and the Kentucky School Boards Association asserted the student assignment within a school district in Kentucky was a matter that the legislature has committed to the sound discretion of the local school board. The circuit court agreed and dismissed the complaint for failure to state a claim upon which relief can be granted. The court of appeals reversed. The Supreme Court reversed the court of appeals and reinstated the ruling of the circuit court, holding that Kentucky public school students have no statutory right to attend a particular school. View "Jefferson County Bd. of Educ." on Justia Law

After injuring another student, a public high school student was cited for an infraction of the student conduct rule proscribing reckless endangerment. The principal's decision to suspend the student for ten days was upheld by a hearing board and the director of schools. Thereafter, the student and his family sought judicial review of the disciplinary decision. The trial court concluded (1) the school officials had violated the student's procedural due process rights because one official had performed both prosecutorial and decision-making functions and because this official was biased against the student; and (2) the evidence did not support the conclusion that the student's conduct amounted to reckless endangerment. Accordingly, the court directed the school system to expunge the student's record and awarded the student and his family attorneys' fees and costs. The court of appeals reversed. The Supreme Court affirmed, holding (1) the student received the required due process protections before he was suspended; (2) the hearing process after the student was suspended as applied did not render the proceedings fundamentally unfair; and (3) the court of appeals did not err by overturning the trial court's conclusion that the school officials acted arbitrarily and illegally.View "Heyne v. Metro. Nashville Bd. of Pub. Educ." on Justia Law

The Maryland Dream Act seeks to exempt certain students from paying out-of-state tuition rates at higher education institutions in Maryland. Following the enactment of the Act, MDPetitions.com petitioned to refer the Act to Maryland's 2012 general election ballot. The State Board of Elections certified the petition for referendum. In response to the Board's certification, Appellants, representing a group of individuals supporting the Act, challenged its referability and sought to remove the Act from consideration on the November 2012 ballot. The trial court entered summary judgment against Appellants, finding that the Act was a proper subject for referendum. The Supreme Court affirmed, holding that the Act was not a law "making any appropriation for maintaining the state government" within the meaning of Md. Const. art. XVI, 2, and therefore was not exempt from referendum.View "Doe v. Bd. of Elections" on Justia Law

For some years, the Board of Education of Baltimore County belonged to a governmental group purchasing consortium, which competitively bid a roofing services contract on behalf of its members. The Board relied on that contact to fulfill its needs for roofing repair services. Appellant Building Materials Corporation of America, a nationwide manufacturer of roofing materials, questioned the Board's authority for that practice under the pertinent statutes. The circuit court granted summary judgment in favor of the Board. The Court of Appeals affirmed, holding that when viewed in the context of the entire education law and regulations promulgated under that law, the competitive bidding statute did not bar the Board from using its membership in an intergovernmental purchasing consortium for the procurement of roofing repair services.View "Bldg. Materials Corp. of Am. v. Bd. of Educ." on Justia Law

In this appeal, the Supreme Court reviewed a court of appeals' opinion in "Churchill v. Univ. of Colo. at Boulder," whereby the underlying civil action involved claims brought by Professor Ward Churchill pursuant to 42 U.S.C. 1983 after his tenured employment was terminated by the Board of Regents of the University of Colorado. Churchill alleged that the Regents violated his constitutionally protected free speech rights by initiating an investigation into his academic integrity and by terminating his tenured employment in retaliation for his publication of a controversial essay. Churchill sought both compensatory and equitable relief. The court of appeals affirmed the trial court's dismissal of Churchill's termination claim on grounds that the Regents' quasi-judicial actions were entitled to absolute immunity. It also affirmed the trial court's dismissal of Churchill's claim for equitable remedies because it concluded that such remedies were not available in a Section 1983 action against quasi-judicial officials. Lastly, based on its determination that allegedly retaliatory employment investigations are not actionable under Section 1983, the court of appeals affirmed the trial court's directed verdict in favor of the University on Churchill's bad faith investigation claim. Upon review, the Supreme Court affirmed, but on different grounds: (1) the Court held that the Regents' decision to terminate Churchill's employment was a quasi-judicial action functionally comparable to a judicial process, and that the Regents were entitled to absolute immunity concerning their decision; (2) the trial court did not abuse its discretion when it ruled that Churchill was not entitled to the equitable remedies of reinstatement and front pay; and (3) Churchill’s bad faith investigation claim was barred by qualified immunity because the Regents' investigation into Churchill's academic record does not implicate a clearly established statutory or constitutional right or law.View "Churchill v. University of Colorado at Boulder" on Justia Law

Plaintiffs were sexually abused by their teacher, White, at an Urbana school. Before working in Urbana, White was a teacher in the McLean County school district. Plaintiffs filed suit against White, Urbana, individual administrators, the McLean County district, and individual McLean administrators. Plaintiffs alleged that between 2002 and 2005, McLean administrators acquired actual knowledge of White’s teacher-on-student sexual harassment, sexual abuse, or sexual “grooming” of minor female students, but never recorded these incidents in White’s personnel file or employment record, failed to make timely mandated reports of abuse by White, and failed to investigate parental complaints. According to the complaint McLean disciplined White for “sexual harassment, sexual grooming, and/or sexual abuse” of minor female students, then entered into a severance agreement with White which concealed his sexual abuse of students and created a falsely positive letter of reference for White. The trial court dismissed with respect to the McLean defendants, finding they owed no duty. The appellate and supreme courts ruled in favor of plaintiffs. The state sovereign immunity law does not extend to conduct that is willful or wanton, 745 ILCS 10/2-202; the alleged fact are sufficient to establish that, having undertaken the affirmative act of filling out White’s employment verification form,defendants had a duty to use reasonable care in ensuring that the information was accurate.View "Jane Doe-3 v. McLean Cnty. Unit Dist. No. 5 Bd. of Dirs." on Justia Law

The Bridgewater State University Foundation owns three buildings and three undeveloped parcels. One building is occupied by foundation offices and the university's alumni office; another houses the university's political science department; and the third is used by the university and the foundation for receptions and fundraising. The undeveloped parcels are used by students for recreation. None of the properties is used exclusively by the foundation. The foundation permits the university to use all the properties free of charge. The Appellate Tax Board decided that the foundation was entitled to the charitable exemption from local property taxes, G.L. c. 59, Sect. 5; the Appeals Court reversed. The Massachusetts Supreme Court concluded that the foundation is entitled to the exemption. The foundation is a public charitable trust, and it is "organized and operate[s] exclusively for the benefit of" Bridgewater State University under G.L. c. 15A, sect. 37. The foundation has qualified as a tax-exempt organization under section 501(c)(3) of the Internal Revenue Code. The university is an institution of public higher education and certifies that the foundation is operating "in a manner consistent with" the university's goals and policies and uses its money and assets solely for the benefit of the university.View "Bridgewater State Univ. Found. v. Bd. of Assessors of Bridgewater" on Justia Law