Justia Education Law Opinion Summaries

Plaintiff, a tenured professor at the University-defendant, was arrested by campus police and charged with stalking and disorderly conduct after unleashing an expletive-filled tirade against a colleague whom he suspected of causing him to receive a parking ticket. Plaintiff was temporarily banned from campus, removed as department head, and required to attend an anger-management class. Although the charges were later dismissed, Collins sued for false arrest, defamation, and violation of his due process rights. The district court granted judgment for the defendants. The First Circuit affirmed, first rejecting an argument that the arrest was illegal because the "violation" was civil in nature. The warrant was supported by probable cause. Suspension with pay for two months was a minimal deprivation that did not entitle plaintiff to pre-deprivation process. Plaintiff was allowed to visit campus several times during the ban and was given adequate process for the minimal deprivation of liberty. An email indicating that plaintiff's presence on campus should be reported was not defamatory. View "Collins v. Univ. of NH" on Justia Law

The District, which operates six elementary schools and two very highly-rated high schools set goals for redistricting, including: equalizing enrollment of the high schools and middle schools; operating elementary schools at or under capacity; not increasing the number of buses required; giving 2010 graduates the choice to either follow the redistricting plan or stay at the high school of their previous year; and basing decisions on current and expected future needs, not on past practices. The district court concluded that the plan required strict scrutiny because race was a factor in the formation of the plan, but concluded that the plan is constitutional because it does not use race impermissibly. The Third Circuit affirmed, holding that strict scrutiny did not apply, simply because decision-makers discussed race. The plan neither classifies on the basis of race nor has a discriminatory purpose. The plan met the rational basis test.View "Student Doe 1 v. Lower Merion Sch. Dist." on Justia Law

Plaintiff, an Arab Muslim, served as an associate professor at a state from 2001 to 2006. His performance record was consistently sub-par, and he frequently sparred with policy decisions made by his supervisor. Informed that his contract would not be renewed, he filed suit, alleging that that the school refused to renew his contract based on his race, national origin, and religion, and in retaliation for several claimed instances of complaining about discrimination, all in violation of Title VII. The district court entered judgment for the school. The Seventh Circuit affirmed. There was no direct or circumstantial evidence that plaintiff was treated differently than similarly situated individuals outside his protected class, nor did plaintiff establish retaliation. View "Abuelyaman v. IL State Univ." on Justia Law

Plaintiff brought suit under 42 U.S.C. 1983, alleging that defendants had retaliated against her for exercising her rights under the First Amendment. The district court granted summary judgment to defendants, holding that the speech on which plaintiff based her claim was not protected under the First Amendment and that the individual defendants had qualified immunity from suit. The district court held, alternatively, that summary judgment would have been appropriate if the speech had been protected, because the school district would have fired plaintiff even in the absence of the speech. Plaintiff appealed. The court held that plaintiff had made a prima facie showing of retaliation for speech protected by the First Amendment; that appellees' rebuttal was subject to credibility questions and hence could not be resolved as a matter of law; and that appellees were not, at this stage of the proceedings, entitled to qualified immunity. View "Nagle v. Marron" on Justia Law

Parents "Madeline P." and "Rex P." challenged a school district's actions regarding their child's educational program under the Individuals with Disabilities Education Act (IDEA). A hearing officer found an IDEA violation but awarded less compensatory education services for the child than the parents requested. On appeal, the superior court affirmed the IDEA violation finding and the compensatory education award. The parents appealed, arguing that more compensatory education services should have been awarded; the school district cross-appealed, arguing that no compensatory education services should have been awarded. The Supreme Court affirmed the superior court's findings regarding the school district's violation of the IDEA's procedural and substantive requirements and the compensatory education award. View "Madeline P. v. Anchorage School District" on Justia Law

Plaintiff sued defendant, alleging that defendant had unlawfully discriminated against her in violation of the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq. Plaintiff, a medical student who was diagnosed with dyslexia and a mild processing-speed disorder, contended on remand that the district court erred by failing to apply the 2008 amendments to the ADA and in relying on her prior academic achievement in assessing whether she suffered from a disability under the ADA. The court held that because plaintiff failed to show legal or clear factual error by the district court, the judgment was affirmed. View "Singh v. GW Univ. School of Medicine, et al." on Justia Law

The Supreme Court granted a writ application to determine whether a school board had tort liability for expelling a high school student after a fifth-sized bottle of whiskey fell from the student's backpack and broke on the classroom floor. The student claimed he was denied due process in the disciplinary proceedings that resulted in his expulsion. The district court agreed and awarded the student $50,000. Upon review of the trial court record, the Supreme Court found that the student presented no evidence whatsoever of being denied due process at the school board hearing. Finding the student failed to carry his burden of proof to show a denial of due process by the school board, the Court reversed the judgment of the district court. View "Christy v. McCalla" on Justia Law

Plaintiff, who had a history of depression and bipolar disorder, filed a complaint against the Board when she was terminated from her position when she failed to complete at least six semester hours of professional development training to renew her certificate. At issue was whether a disabled teacher was a "qualified individual with a disability" under the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq. The court held that because plaintiff did not allege that the Board's legal authorization requirement was itself discriminatory, her failure to satisfy such requirement rendered her unqualified and the Board was not required to accommodate her disability. Accordingly, the judgment was affirmed. View "Johnson v. Board of Trustees of the Boundary County Sch., et al." on Justia Law

Unable to maintain a satisfactory academic record in a state dental school, plaintiff was dismissed. He unsuccessfully petitioned school committees and administrators to overturn the decision, then filed a complaint alleging First Amendment, equal protection, and procedural due process violations. The district court dismissed. The Seventh Circuit affirmed, holding that petitioner received ample process. He had ample notice, having been on academic probation, he was given several opportunities to remediate, and was allowed to appeal.View "Hlavacek v. Boyle" on Justia Law

The District of Columbia appealed the denial of its motion to vacate a preliminary injunction pursuant to Rule 60(b)(5) of the Federal Rules of Civil Procedure. The injunction was issued in 1995 in response to a class action complaint alleging that the District of Columbia was violating the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq., by failing to timely pay private providers of special education services and thereby jeopardizing students' special education placements. The district court denied the motion on two grounds: (1) dissolving the injunction and subsequent payment orders "would be disruptive to the status quo" and "counter-productive to the goal" of settling the case "in short order," and (2) the District of Columbia had "overstated both the relevance and the significance" of the Supreme Court's recent decision in Horne v. Flores. The court held that the district court failed to address changed circumstances, as Flores instructed, and reversed and remanded the case to the district court to determine whether, in view of changed circumstances, the District of Columbia's Rule 60(b)(5) motion should be granted. View "Petties, et al. v. District of Columbia, et al." on Justia Law