Justia Education Law Opinion Summaries

Plaintiff initiated this proceeding in the district court alleging that the Board violated the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq., by failing to reasonably accommodate her hearing disability. Plaintiff's complaint sought back pay, future pay, compensatory damages of $1,000,000, punitive damages of $1,000,000, plus attorney's fees and costs. The Board subsequently appealed the district court's partial rejection of the Board's assertion of immunity. The court held that the district court properly adhered to the Bd. of Educ. of Balt. Cnty. v. Zimmer-Rubert decision in ruling that the immunity provision effected a waiver of the Board's Eleventh Amendment immunity for claims of $100,000 or less. View "Lee-Thomas v. Prince George's County Public Sch." on Justia Law

The issue before the Supreme Court was the overall adequacy of state funding for K-12 education under the Washington State Constitution. "The legislature must develop a basic education program geared toward delivering the constitutionally required education, and it must fully fund that program through regular and dependable tax sources." The Court found that the State failed to meet its duty under the constitution by consistently providing school districts with a level of resources that fell short of the actual costs of the basic education program. The legislature enacted reforms to remedy the deficiencies in the funding system, and the Court deferred to the legislature's chosen means of discharging its duty. However, the Court retained jurisdiction over the case to help ensure progress in the State's plan to fully implement education reforms by 2018. The Court directed the parties to provide further briefing to the Court addressing the preferred method for retaining jurisdiction. View "McCleary v. Washington" on Justia Law

This case involved a longstanding dispute over who bore the burden of paying the educational costs for the children of St. Basil, a child car institution located within the boundaries of the school district and housed primarily Greek Orthodox children whose parents were unable to care for them due to certain circumstances. The court concluded that the Education Law specified that children living in such institutions were not deemed residents of the school district in which the institution was located purely by reason of their presence in the institution; the issuance of a license to operate a child care institution did not change the residence of the children living there; and there is nothing to suggest that the Legislature intended the local school district to bear the entire financial burden for those children living in a child care institution. Therefore, the court held that a school district was not obligated to provide a tuition-free education to those children determined to be nonresidents of the school district. View "Board of Educ. of the Garrison Union Free School Dist. v Greek Archdiocese Inst. of St. Basil" on Justia Law

The Association sought extraordinary writ relief from the court, arguing that two measures intended to stabilize school funding by reducing or eliminating the diversion of property tax revenues from school districts to the state's community redevelopment agencies, was unconstitutional. At issue was whether the state Constitution (1) redevelopment agencies, once created and engaged in redevelopment plans, have a protected right to exist that immunized them from statutory dissolution by the Legislature; and (2) redevelopment agencies and their sponsoring communities have a protected right not to make payments to various funds benefiting schools and special districts as a condition of continued operation. Answering the first question "no" and the second "yes," the court largely upheld Assembly Bill 1X 26 and invalidated Assembly Bill 1X27. The court held that Assembly Bill 1X 26, the dissolution measure, was a proper exercise of the legislative power vested in the Legislature by the state Constitution. The court held that Assembly Bill 1X 27, the measure conditioning further redevelopment agency operations on additional payments by an agency's community sponsors to state funds benefits schools and special districts, was invalid. View "Cal. Redevelopment Assoc., et al. v. Matosantos, et al." on Justia Law

This case involved A.S., a California minor, who was eligible for special education services under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq. At issue was which California agency was responsible for funding A.S.'s educational placement in an out-of-state residential treatment facility. The court held as a matter of California law that the California agency responsible for funding A.S.'s education at an out-of-state residential treatment facility was the school district in which the student's parent, as defined by California Education Code section 56028, resided. The court held that A.S. had no parent under the 2005 version of section 56028 and thus, from July 28, 2006, when A.S. was placed at the out-of-state facility, until October 9, 2007, when an amended version of section 56028 took effect, California law did not designate any educational agency as responsible for A.S.'s education. The California Department of Education (CDE) was therefore responsible by default. The court held that A.S. did have a parent under the 2007 and 2009 versions of section 56028. CDE therefore was not responsible for A.S.'s out-of-state education after October 10, 2007, when the 2007 version of section 56028 took effect. Accordingly, the court affirmed in part and reversed in part the district court's judgment. View "Orange County Dept. of Educ. v. CA Dept. of Educ., et al" on Justia Law

In consolidated appeals regarding continuing school desegregation efforts in the Little Rock, Arkansas area, NLRSD and PCSSD each appealed the district court's denial of their petitions for a declaration of unitary status. In addition, NLRSD and PCSSD joined with LRSD, several local teachers' unions, and a union member in appealing the district court's decision to terminate certain funding obligations of the State arising from a previous settlement agreement in this case. The court reversed the denial of unitary status for NLRSD in the area of staff recruitment where NLRSD had maintained levels of black teacher employment that exceeded the percentages in the relevant labor market, when viewed in light of NLRSD's good-faith efforts, which suggested that the vestiges of past discrimination have been eliminated to the extent practicable in the area of recruitment. The court affirmed, however, the denial of unitary status for PCSSD in the area of student assignment, advanced placement, discipline, school facilities, scholarships, special education, staff, student achievement, and monitoring. The court vacated the portion of the district court's order terminating the State's funding obligations under the 1989 Settlement Agreement. View "Little Rock Sch. Dist. v. State of Arkansas, et al.; Joshua, et al. v. Pulaski County Special Sch. Dist.; Armstrong, et al. v. North Little Rock Sch. Dist.; North Little Rock Classroom Teachers Assoc., et al. v. State of Arkansas, et al." on Justia Law

Plaintiff appealed the district court's grant of summary judgment dismissing her 42 U.S.C. 1983 suit against the Dean of the University of Iowa's College of Law. Plaintiff alleged that the Dean discriminated against her in violation of her First Amendment rights of political belief and association when plaintiff was not hired to be a full-time instructor or part-time adjunct instructor. The court held that plaintiff had presented sufficient evidence for a fact finder to infer that the Dean's repeated decisions not to hire her were in part motivated by her constitutionally protected First Amendment rights of political belief and association; the facts viewed in the light most favorable to plaintiff were sufficient to establish a violation of her First Amendment rights where it was apparent that a dispute existed regarding a material issue of fact, namely whether the Dean would have made the same hiring decisions in the absence of plaintiff's political affiliations and beliefs; the Dean had not shown that a reasonable university dean in her position would have believed that failing to hire plaintiff was lawful in light of clearly established law; and the district court erred in finding that qualified immunity protected the Dean from liability in her individual capacity. Accordingly, the court reversed the grant of summary judgment and remanded for further proceedings. View "Wagner v. Jones" on Justia Law

Plaintiff, a minor who had been diagnosed with autism, appealed the district court's affirmance of the Hawaii Department of Education (DOE) hearing officer's decision that plaintiff's free and appropriate public education placement complied with the Individuals with Disabilities Act (IDEA), 20 U.S.C. 1400 et seq. Plaintiff also claimed that his tuition reimbursement request for the 2007-2008 school year was timely, and that Loveland Academy was his "stay put" placement. The court held that Loveland Acadamy was not plaintiff's stay put placement because the DOE only agreed to pay tuition for the limited 2006-2007 school year and never affirmatively agreed to place plaintiff at Loveland Academy. The court also concluded that plaintiff's tuition reimbursement claim for the 2007-2008 school year was time-barred and that the district court did not err in finding that the 2007 and 2008 individualized education programs complied with IDEA requirements. Accordingly, the court affirmed the decision of the district court. View "K. D. v. Dept of Education" on Justia Law

Parents disagreed with the school system's assessment of appropriate services for their four-year-old, who had suffered traumatic brain injuries. The Indiana Board of Special Education Appeals affirmed on most points, concluded that the parents failed to show that any procedural violation significantly impeded their opportunity to participate in the decision-making process or caused a deprivation of educational benefits, and confirmed that the child did not require a full-time kindergarten program in order to receive a free appropriate public education. The district court entered summary judgment in favor of the school district. The Seventh Circuit affirmed. The child's rights under the Individuals with Disabilities Education Act, 20 U.S.C. 1400-1491 were not affected by any procedural errors. The record supports the conclusion that the child was making progress toward his Individual Education Plan goals Because the school conducted its evaluation of the child within 60 instructional days of receiving parental consent, it fully complied with its "child find" obligations. The parents were not entitled to reimbursement for their costs of placing the child in a private school or for attorney fees. View "Damian Berns, et al v. Hamilton Southeastern Schools, et al" on Justia Law

Plaintiff challenged his expulsion from Weston High School for allegedly possessing and distributing a "marijuana cookie" on school property. The court held that the judge abused his discretion where the record did not suggest that the judge either considered the proper legal standards for the allowance of a motion for a preliminary injunction or evaluated the factual circumstances relevant to plaintiff's alleged misconduct. Therefore, the order regarding plaintiff's motion for a preliminary injunction was vacated in its entirety and the matter remanded. View "Doe v. Superintendent of Schools of Weston" on Justia Law