Justia Education Law Opinion Summaries

Governor Linda Lingle filed an executive order unilaterally imposing three-day-per-month furloughs for all state employees and reducing the Department of Education's and University of Hawaii's spending accordingly. The Hawaii State Teachers Association and United Public Workers (collectively, Plaintiffs) brought this action, asserting several causes of action and moving for a temporary restraining order. The circuit court granted in part Plaintiff's motion for a temporary injunction and held for Plaintiffs. The Supreme Court vacated the circuit court's judgment, holding (1) the dispute in this case ultimately related to a prohibited practice pursuant to Haw. Rev. Stat. 89; and (2) the circuit court erred by deciding statutory issues over which the Hawaii Labor Relations Board had exclusive jurisdiction. View "State Teachers Ass'n v. Abercrombie" on Justia Law

Plaintiffs challenged the school district practice of giving preference to the boys' Friday and Saturday night basketball games, asserting that non-primetime games result in a loss of audience, conflict with homework, and foster feelings of inferiority. The district court dismissed the claims under Title IX of the Education Amendments of 1972, 20 U.S.C. 1681(a) and an equal protection claim, 42 U.S.C. 1983 on grounds of sovereign immunity. The Seventh Circuit vacated. Plaintiffs presented a genuine question of fact that such practices violate the statute. Defendants are "persons" within the meaning of section 1983, subject to suit under that statute.View "Parker v. Franklin Cnty. Cmty Sch. Corp." on Justia Law

Appellants are the parents of G.J., a child with autism and brain injuries. At issue was whether the ALJ and the district court properly evaluated appellants' claims that the MCSD did not comply with certain provisions of the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq., with respect to services it was to provide to G.J. The court held that the district court did not err in setting forth reasonable conditions for G.J.'s reevaluation and in determining that appellants were not entitled to either a private or publicly funded independent educational evaluation. The court also held that there was no basis for making a determination that any procedural failures with regard to the August 2008 and 2009 IEP meetings impacted the education received by G.J. to any substantive degree. Accordingly, the judgment was affirmed. View "G. J., et al. v. Muscogee Co. Sch. Dist." on Justia Law

The Montgomery County Board of Education (the Board), several of its members, and a teacher in the school system petitioned the Supreme Court for a writ of mandamus to direct the circuit court to vacated its order that denied their motion for summary judgment. Third-grade student "S.K." went to the restroom with two friends. Her teacher did not accompany them. S.K. claims that when she attempted to leave the restroom stall, the door jammed. She tried to climb over the door to get out of the stall but slipped and fell, cutting her face on a metal hanger on the back of the door. S.K. (by and through her mother Tetrina Capehart) sued the Board, its members individually and in their official capacities, and the teacher asserting negligence and wantonness claims, and sought compensatory and punitive damages. The Board and teacher argued that there were no genuine issues of fact, and that S.K. was contributorily negligent from "playing" in the restroom. The circuit court denied the Board's motion. Upon review, the Supreme Court concluded the Board demonstrated that under the state constitution, it had absolute immunity from suit for claims asserted against it. The Court granted the Board's petition and issued the writ to direct the circuit court to rule in the Board's favor. View "In re: S.K." on Justia Law

This case concerned the way by which the costs of financing the school district were apportioned among the city of New Bedford, the town of Dartmouth, and the town of Fairhaven, which were municipalities comprising the school district. Dartmouth commenced an action in the superior court against defendants challenging the funding obligations imposed on the member municipalities by the Education Reform Act of 1993, G.L.c. 70, section 6. Fairhaven filed a cross claim asserting that the funding obligations imposed by the Act were a disproportionate tax on property and income in violation of the state constitution. The court held that the complaint filed by Dartmouth and cross claim filed by Fairhaven were properly dismissed because Dartmouth and Fairhaven failed to state a claim on which relief could be granted. View "Town of Dartmouth v. Greater New Bedford Regional Vocational Tech. High Sch. Dist. & others" on Justia Law

Plaintiff, a teacher, filed this action against defendants, a superintendent and principal, pursuant to 42 U.S.C. 1983 claiming that he was terminated in retaliation for exercising his First Amendment rights. At issue was whether defendants were entitled to qualified immunity and whether plaintiff's First Amendment retaliation claims were barred by res judicata. The court held that plaintiff failed to present any precedent, and the court was aware of none, to suggest that a reasonable principal and superintendent armed with the knowledge they possessed, to include the unsatisfactory performance reviews, would know they could not recommend and/or adopt a recommendation to terminate plaintiff. Accordingly, defendants were entitled to qualified immunity and the court need not address the res judicata issue. View "Sherrod v. Johnson; Sherrod v. Crutchfield" on Justia Law

In 2007, Plaintiff Helen Barton was injured while watching a high school football game in Barrow when a player ran out of bounds during a play and collided with her, breaking her leg. Plaintiff sued the North Slope Borough School District, alleging in part that the football field had not been designed or built with a proper "run-off" area along the sidelines and that spectators had improperly been allowed to stand in the run-off area during the game. Plaintiff retained expert landscape architect Juliet Vong who proposed to testify that she used a particular manual in designing sports fields "to help ensure the appropriate dimensions and design criteria are met for a given sport and level of play." The School District filed a motion in limine to exclude Vong's testimony because it did not provide an admissible expert opinion. The superior court agreed with the District and excluded Vong's report and testimony. At a jury trial in August 2010, the District was found not negligent. Plaintiff appealed, arguing that the superior court should not have excluded Vong's testimony and that doing so was prejudicial to Plaintiff's case. Upon review, the Supreme Court concluded that although it was error to exclude Vong’s testimony, the error was harmless. View "Barton v. North Slope Borough School District" on Justia Law

Defendant filed a due process hearing complaint with California's Office of Administrative Hearings (OAH), alleging that he was being denied the free appropriate public education (FAPE) that he was entitled to under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq. The court certified the following question to the California Supreme Court: Does California Education Code 56041 - which provided generally that for qualifying children ages eighteen to twenty-two, the school district where the child's parent resides is responsible for providing special education services - apply to children who are incarcerated in county jails? The case was withdrawn from submission and further proceedings were stayed pending final action by the Supreme Court of California. View "Los Angeles Unified Sch. Dist. v. Garcia" on Justia Law

Hosanna-Tabor, a member congregation of the Lutheran Church-Missouri Synod, operated a small school in Michigan offering a "Christian-centered education" to students in kindergarten through eighth grade. The Synod classified its school teachers into two categories: "called" and "lay." "Called" teachers, among other things, were regarded as having been called to their vocation by God. To be eligible to be called from a congregation, a teacher must satisfy certain academic requirements. "Lay" or "contract" teachers, by contrast, were not required to be trained by the Synod or even to be Lutheran. "Called" teacher, Cheryl Perich filed a charge with the EEOC, claiming that her employment had been terminated in violation of the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq. The EEOC brought suit against Hosanna-Tabor, alleging that Perich had been fired in retaliation for threatening to file an ADA lawsuit. Perich intervened. Invoking what was known as the "ministerial exception," Hosanna-Tabor argued that the suit was barred by the First Amendment because the claims concerned the employment relationship between a religious institution and one of its ministers. The Court held that the Establishment and Free Exercise Clauses of the First Amendment barred suits brought on behalf of ministers against their churches, claiming termination in violation of employment discrimination laws. Because Perich was a minister within the meaning of the ministerial exception, the First Amendment required dismissal of this employment discrimination suit against her religious employer. View "Hosanna-Tabor Evangelical Lutheran Church and School v. EEOC" on Justia Law

In an underlying civil case, Appellant filed a notice of dismissal, voluntarily dismissing the case without prejudice. Minutes later, a deputy clerk responsible for processing the queue of electronically transmitted documents clicked on the court of common pleas judge's journal entry granting summary judgment in favor of the respondents, which had been transmitted earlier that day. The judge subsequently struck Appellant's notice of dismissal and held that the summary judgment was the final judgment on the merits of the case. Appellant requested a writ of prohibition and a writ of mandamus, which the court of appeals denied. The Supreme Court reversed in part, holding that the court of appeals erred in denying Appellant's request for (1) a writ of prohibition to prevent the judge from proceeding on the merits of the underlying case where the judge lacked jurisdiction because, pursuant to Ohio R. Civ. P. 58(A), the entry of summary judgment was not effective until after Appellant's notice of dismissal; and (2) a writ of mandamus to compel the judge to vacate her entry striking the notice of dismissal and her entry of summary judgment in the underlying case and to compel the judge to reinstate her notice of dismissal. View "State ex rel. Engelhart v. Russo" on Justia Law