Justia Education Law Opinion Summaries

In a declaratory judgment action, the parties appealed the circuit court's order authorizing Storm M. H. ("Student"), who resided in Berkeley County, to enroll in the Academic Magnet High School ("AMHS") located in the Charleston County School District ("CCSD") provided she purchase real property in the CCSD with a tax-assessed value of $300 or more. Student resided with her parents in Berkeley County. In January 2010, she applied for admission to the 9th grade class at the AMHS for the following academic year. In her application, Student identified her Berkeley County address. Student was accepted by the AMHS and required to confirm her intention to enroll by January 28, 2010. The Confirmation Form requested a "Charleston County Residence Address." After seeing this request, Student's mother, Gayla S. L. McSwain ("Parent"), spoke with someone at the AMHS and explained that Student could not provide a Charleston County address because she did not "live in Charleston County yet." As a result of this conversation, Parent completed the Confirmation Form by indicating that she would "provide [a Charleston County residence address] prior to enrollment." The circuit court held that the CCSD's policy of requiring domicile for a child to attend a CCSD magnet school violated section 59-63-30(c) because "domicile" by a child and that child's parent or guardian was not required by the statute only property ownership. Both parties appealed the circuit court's order to the court of appeals. Subsequently, Student purchased real property in Charleston County and enrolled in the AMHS on August 18, 2010. Upon review, the Supreme Court concluded that CCSD's policy of excluding all non-resident children from attendance at its magnet schools was contrary to the plain language of section 59-6330, and the Student was entitled to continue attending AMHS. "We are not unsympathetic to the Board's argument that allowing non-resident children to attend its magnet schools displaces other qualified resident children. However, we are constrained to interpret the unambiguous language of section 59-63-30. . . . As the statute is written, the Board does not have the authority to unilaterally exclude children who qualify to attend its schools." View "Storm M. H. v. Charleston County Board of Trustees" on Justia Law

Plaintiff, who was employed as a school bus driver, broadcasted that the bus she was driving, which was full of elementary-school children, had been struck by gunfire and that panic had spread among the children. Displeased with the manner in which Plaintiff handled the situation, the Town of Johnson school department requested that Plaintiff no longer be assigned to transport Johnson students. Eventually, Plaintiff left her employment. Plaintiff subsequently filed suit for wrongful termination against members of the Johnson public schools (Defendants), alleging that Defendants wrongfully requested that Plaintiff be terminated from her employment. In response to the trial justice's remarks, Plaintiff moved to amend her complaint to include a claim of tortious interference, which the trial justice denied. Thereafter, the superior court granted summary judgment against Plaintiff. The Supreme Court vacated the judgment of the superior court, holding that the court abused its discretion in denying Plaintiff's motion to amend her complaint without specific findings. Remanded.View "Lomastro v. Iacovelli" on Justia Law

Citizens, unhappy with how public education is funded in Illinois, sought a declaratory judgment, alleging that the funding system requires taxpayers in school districts with low property values to pay property taxes to fund local public schools at a higher rate than similarly situated taxpayers in school districts with higher property values, in violation of the equal protection clause of the Illinois Constitution. The circuit court dismissed; the appellate court affirmed. The Illinois Supreme Court held that the complaint was properly dismissed for lack of standing. The funding statute is not a taxing statute; plaintiffs failed to establish that the inequalities alleged are a direct result of the enforcement of the education funding statute or are fairly traceable to defendants’ actions. It is entirely within the discretion of the school districts to determine the actual rate of local property taxes, and the funding statute does not require school districts to tax at a certain rate. Although a district might decide that more local property tax revenues are required in order to provide students with a sufficient education, that decision is left to the school district and is not compelled or required by the educational funding statute. View "Carr v. Koch" on Justia Law

This case concerned an employment discrimination dispute between Portland State University (PSU) and Portland State University Chapter of the American Association of University Professors (the Association). Those entities entered into a collective bargaining agreement that included a dispute resolution process for alleged violations of the agreement. That dispute resolution process included a "Resort to Other Procedures" (ROP) provision that permitted PSU to decline or discontinue a grievance proceeding if an Association member brought a claim regarding the same matter in an agency or court outside of PSU. PSU invoked that provision to halt a grievance proceeding after an Association member filed discrimination complaints with two outside agencies. The Association subsequently filed a complaint with the Oregon Employment Relations Board (ERB), alleging in part that PSU had engaged in an unfair labor practice by discontinuing the contractual grievance proceeding. ERB concluded that PSU's invocation of the ROP clause constituted unlawful discrimination. It therefore declined to enforce the ROP clause and ordered PSU to submit to the grievance process. On PSU's appeal, the Court of Appeals determined that ERB erred by applying the wrong legal standard in ordering PSU to submit to the grievance process, and it therefore reversed and remanded the case for ERB's reconsideration. The Association sought review of that decision. Upon review, the Supreme Court reversed the Court of Appeals's decision, concluding that ERB correctly held that the ROP clause at issue in this case imposed a form of employer retaliation for protected conduct that reasonably would impede or deter an employee from pursuing his or her statutory rights. "The resulting harm is neither theoretical nor trivial, but qualifies as a substantive difference in treatment. The ROP provision is therefore facially discriminatory . . . Accordingly, ERB properly declined to enforce that illegal contract provision. " View "Portland St. Univ. Ass'n of Univ. Professors v. Portland St. Univ." on Justia Law

This appeal stemmed from issues involving the school-funding system and the disbursement of uniform rate of tax (URT) revenues to Arkansas's public-school districts. Appellees, school districts and their taxpayers ("School Districts"), filed a complaint seeking a declaration that any attempt by Appellants, the commissioner of the department of education and the state treasurer ("ADE"), to demand URT revenues in excess of the foundation-funding amount from Appellees was unconstitutional. The circuit court enjoined ADE from (1) seeking repayment of any portion of the URT revenues assessed for purposes of school funding from Appellees, and (2) withholding monies belonging to Appellees for the repayment of the URT revenues required for school funding from state or federal monies owed to the districts. The Supreme Court affirmed on direct appeal and reversed on cross-appeal, holding that the circuit court (1) correctly found that ADE was not authorized by the legislature to recoup and redistribute any URT revenues received from the School Districts that were in excess of the foundation-funding amount; (2) did not err in finding that ADE lacked the authority to withhold monies from the School Districts; and (3) erred in finding that the revenues generated by the URT were state-tax revenues. View "Kimbrell v. McCleskey" on Justia Law

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