Justia Education Law Opinion Summaries
King-Willmann v. Webster Groves Sch. Dist.
Jordan Danielle King-Willmann filed a petition seeking a writ of mandamus requiring the Webster Groves school district to enroll her in the district pursuant to Mo. Rev. Stat. 167.131.2. The school district contested certain material facts alleged by King-Willmann and asserted several defenses, including a claimed violation of Mo. Const. art. X, sec. 21, the Hancock amendment. The school district requested an evidentiary hearing, which the trial court did not hold. The court issued the writ granting King-Willmann relief. The Supreme Court reversed the judgment and remanded because contested issues of fact existed. On remand, the Court instructed the trial court not to consider the Hancock amendment claim as the school district had no standing to bring such a claim.
View "King-Willmann v. Webster Groves Sch. Dist." on Justia Law
Regents of the University of Colorado v. Students for Concealed Carry on Campus
The Students for Concealed Carry on Campus, LLC, with Martha Altman, Eric Mote, and John Davis (collectively, Students), filed a complaint against the University of Colorado's Board of Regents alleging that the Board's Weapons Control Policy 14-I (which prohibits the carrying of handguns on campus by all persons but certified law enforcement personnel) violates the Colorado Concealed Carry Act (CCA) and the Colorado Constitution's right to bear arms. The Board filed a motion to dismiss which the district court granted. The Students appealed, and the court of appeals reversed, holding that the Students stated a claim for relief because the CCA expressly applied to "all areas of the state." The court further concluded that the Students had stated a claim for relief under article II, section 13 of the Colorado Constitution, which affords individuals the right to bear arms in self-defense. The Supreme Court affirmed, finding the CCA's comprehensive statewide purpose, broad language, and narrow exclusions show that the General Assembly intended to divest the Board of Regents of its authority to regulate concealed handgun possession on campus. Accordingly, the Supreme Court agreed with the court of appeals that, by alleging the Policy violated the CCA, the Students stated a claim for relief.
View "Regents of the University of Colorado v. Students for Concealed Carry on Campus" on Justia Law
Va. Commonwealth Univ. v. Su
Su, a citizen of the People's Republic of China, was accepted by the Virginia Commonwealth University (VCU) after attending high school in Minnesota. At the time Su matriculated at VCU, he was classified as an out-of-state student for tuition purposes. Su subsequently sought to change his classification to in-state status and filed an application for in-state tuition benefits. VCU's residency appeals officer denied Su's application, finding that federal law prohibited an F-1 visa holder to establish Virginia domicile. VCU's residency appeals committee denied Su's appeal. The circuit court reversed, holding (1) VCU was incorrect in asserting that Su had no domicile and that he was an V-1 visa holder, rather than a permanent resident, when he matriculated; and (2) Su had established that he was domiciled in Virginia and had abandoned any previous domicile for at least one year prior o the date of entitlement. The Supreme Court reversed, holding that the circuit court erred in reversing VCU's decision denying Su's application for in-state tuition benefits and that VCU's decision could not reasonably be said to be contrary, capricious or otherwise contrary to law. View "Va. Commonwealth Univ. v. Su" on Justia Law
Cuccinelli v. Rector & Visitors of Univ. of Va.
This case arose from two civil investigative demands (CIDs) issued to the University of Virginia and the Rector and Visitors of the University of Virginia (collectively, UVA) by the attorney general, pursuant to the Virginia Fraud Against Taxpayers Act (FATA). The CIDs sought information relating to the research of a climate scientist that had taught at UVA, received a series of grants to fund his research, and, with other climate scientists, had allegedly falsified data to indicate an upturn in the earth's surface temperatures due to the use of fossil fuels. UVA petitioned the circuit court to set aside the CIDs, arguing that the attorney general had no statutory authority to serve CIDs upon agencies of the Commonwealth and that the CIDs were defective because they failed to state the nature of the conduct alleged. The circuit court granted the petition and set aside the CIDs, without prejudice. The Supreme Court affirmed the judgment of the circuit court, but, unlike the circuit court, set aside the CIDs with prejudice, holding that the University of Virginia, as an agency of the Commonwealth, did not constitute a "person" under the FATA and therefore could not be the proper subject of a CID. View "Cuccinelli v. Rector & Visitors of Univ. of Va." on Justia Law
Deer-Mt. Judea Sch. Dist. v. Beebe
Appellant school district filed an action on its own behalf and on behalf of its students and taxpayers to enjoin State actions in violation of state law and the Arkansas Constitution, asserting two claims for relief. The circuit court granted Appellant's motion to dismiss its second claim without prejudice. The court then entered an order dismissing Appellant's claims against all Appellees. Appellant appealed. The Supreme Court dismissed the appeal without prejudice, holding that the order from which Appellant appealed was not a final, appealable order, as the nonsuit of Appellant's second claim did not operate to make the circuit court's order final because the second claim could be refiled and the requirements of Ark. R. Civ. P. 54(b) had not been met.
View "Deer-Mt. Judea Sch. Dist. v. Beebe" on Justia Law
Pereira v. State Bd. of Educ.
The local board of education of the City of Bridgeport passed a resolution requesting the state board of education to authorize the commissioner of education to reconstitute the local board. The state board voted to authorize the commissioner to reconstitute the local board. In three separate actions, former local board members and residents and electors of the City filed actions against the state board, local board, and others, alleging state statutory and constitutional violations. The trial court reserved the action for the advice of the Supreme Court. At issue was (1) whether the failure of the state board to require the local board to undergo and complete training, as mandated by Conn. Gen. Stat. 10-223e(h), rendered void the state board's authorization; and (2) whether the local board's resolution requesting that the state board authorize reconstitution resulted in a waiver of the state board's obligation to require training. The Supreme Court concluded (1) the state board's failure to require training rendered void its authorization of reconstitution under section 10-223e(h); and (2) the local board's resolution had no effect on the operation of the statute. View "Pereira v. State Bd. of Educ." on Justia Law
Sanders v. Lee County Sch. Dist. No. 1, et al.
An Arkansas jury found in favor of plaintiff on her Title VII claims of race discrimination and constructive discharge against the school district and individual members of the County's Board of Education and awarded her compensatory damages, wage and fringe benefits, and punitive damages. Plaintiff subsequently appealed the district court's judgment. The court held that, under the circumstances, it believed that plaintiff presented sufficient evidence for a reasonable jury to conclude defendant was constructively discharged. Therefore, the court reversed the district court's decision to grant the Rule 50 motion on that claim. The court held that the jury was not instructed to consider whether the individual Board members affirmatively proved ignorance of federal law when discriminating against defendant on the basis of her race. Therefore, the court reversed the district court's Rule 50 motion vacating the punitive damage award, but remanded this issue to the district court. Because the court's resolution of the constructive discharge claim and the punitive damage awards directly affected the degree of success plaintiff obtained in her civil rights action, the court remanded the issue of attorneys' fees. View "Sanders v. Lee County Sch. Dist. No. 1, et al." on Justia Law
Hawkeye Foodservice Distrib., Inc. v. Iowa Educators Corp.
Hawkeye Foodservice Distribution filed a petition for declaratory and injunctive relief against the Iowa Educators Corporation (IEC) and ten Area Education Agencies (AEAs) comprising IEC, seeking (1) a declaration that the operation of IEC was in violation of Iowa Code 273 and 28E; (2) equitable relief enjoining the AEAs and IEC from further operation in violation of Iowa law; and (3) injunctive and declaratory relief on the ground that the AEAs and IEC operate in violation of Iowa Code 23A. The district court granted Defendants' motion to dismiss, concluding (1) Hawkeye lacked standing to bring the chapter 273 and 28E claims; and (2) Hawkeye failed to allege sufficient facts demonstrating it was entitled to relief under chapter 23A. The court of appeals reversed. The Supreme Court vacated the court of appeals and reversed the district court, holding that the district court erred in (1) dismissing Hawkeye's chapter 273 and 28E claims for lack of standing, as Hawkeye's petition alleged facts that gave it standing to challenge the actions of the AEAs and IEC; and (2) dismissing the action, as the factual allegations set forth in the petition, if proved, stated statutory claims sufficient to defeat a motion to dismiss. View "Hawkeye Foodservice Distrib., Inc. v. Iowa Educators Corp." on Justia Law
Pace v. State
The mother of a kindergarten student, who suffered a serious allergic reaction after consuming peanut butter given to her under her school's free lunch program, brought suit against the State and its agents (collectively, Defendants), alleging that the State's obligations under the National School Lunch Act (NSLA) imposed upon Defendants a statutory duty of care to ensure that children with food allergies are not served lunches containing allergens. The trial court granted the State Defendants' motion to dismiss, concluding that the NSLA simply establishes a subsidized lunch program to benefit children at participating schools and does not impose a specific statutory duty of care towards children with food allergies. The court of special appeals affirmed. The Supreme Court affirmed, holding that the NSLA does not impose a statutory duty on the State Defendants to exercise a greater degree of care for students with food allergies than the general level of care the State Defendants exercise for all students in public schools. Because Petitioner could not maintain a suit in negligence, the complaint was properly dismissed. View "Pace v. State" on Justia Law
Doe v. Bd. of Regents
John Doe filed a lawsuit arising from the termination of his enrollment as a medical student at the University of Nebraska Medical Center (UNMC) against the Board of Regents of the University of Nebraska and several faculty members (Defendants). During the pendency of the case, all causes of action except the claim for breach of contract were dismissed. The district court determined that Doe's dismissal was not in violation of a contract between Doe and UNMC regarding the conditions of Doe's continued enrollment. The court then sustained Defendants' motion for summary judgment, dismissing Doe's cause of action for breach of contract and thereby dismissing the case. The Supreme Court affirmed, holding that UNMC did not breach its contract with Doe when it terminated his enrollment, and although the Court's reasoning differed from that of the district court, the court did not err when it sustained Defendants' motion for summary judgment. View "Doe v. Bd. of Regents" on Justia Law