Justia Education Law Opinion Summaries

Relator, Angela Dawson, requested a writ of mandamus to compel Respondent, a local school district, to provide her with access to (1) itemized invoices of law firms providing services to the district in matters pertaining to Dawson and her children, and (2) communications from the school district's insurance carrier identifying the district's legal representative and describing the liability and exposure of the district and insurance company related to a case filed against the district by Dawson on behalf of one of her children. The Supreme Court denied the writ, holding that the requested records were exempt from disclosure under the Public Records Act because the school district met its burden of establishing the applicability of the attorney-client privilege to the requested records. View "State ex rel. Dawson v. Bloom-Carroll Local Sch. Dist." on Justia Law

The Supreme Court granted review to determine whether a public school district was obligated to fund a kindergarten program offered by a cyber charter school for a four-year-old student when the district exercised its discretion not to offer such a program in its public schools. In 2006, the Secretary of Education notified Appellant Slippery Rock Area School District that funds had been deducted from the district's state subsidy and made payable to Appellee Pennsylvania Cyber Charter School. The Secretary deducted funds because Slippery Rock failed to pay Cyber School for numerous students residing in the district who were attending Cyber School. Slippery Rock objected to the withholding of $1,716.63 for a four-year-old female student enrolled in Cyber School’s kindergarten program. Slippery Rock averred that while it operates a discretionary kindergarten program for five-year-old children, the student at issue did not meet the age requirements for admission into the district’s kindergarten program, Slippery Rock argued that it was not obligated to "assume the costs or obligation of this individual’s enrollment into [Cyber School]." The Secretary concluded that Slippery Rock could not deny payment to Cyber School simply because Slippery Rock did not have a four-year-old kindergarten program. Subsequently the Secretary granted Cyber School's motion to dismiss Slippery Rock's objection. The Commonwealth Court affirmed the Secretary, but the Supreme Court reversed the Commonwealth Court and the Secretary: "[t]o hold that Slippery Rock is obligated to fund educational opportunities for students not yet eligible to attend the district’s public schools would allow those students who enroll in Cyber School to receive greater benefits than a similarly-situated student who chooses to attend the public school." View "Slippery Rock Area Sch. Dist. v. Pa. Cyber Charter Sch." on Justia Law

A jury awarded compensatory and punitive damages under 42 U.S.C. 1983 and 20 U.S.C. 1681 for failure by defendant,a middle school principal, to prevent sexual abuse of several female students by their band teacher. The band teacher pled guilty to multiple counts of aggravated kidnapping and aggravated criminal sexual abuse. The Seventh Circuit affirmed the awards. The awards of compensatory damages reflected consideration of the harm to each individual plaintiff; the award of punitive damages was justified in light of defendant's failure to act. View "G.G. v. Grindle" on Justia Law

Plaintiff, a teacher with professional teacher status, was dismissed by the superintendent of the school district for multiple instances of conduct unbecoming a teacher. On appeal, plaintiff argued that G.L.c. 71, section 42, which compelled arbitration of a wrongful dismissal claim made by a public school teacher with professional teacher status, violated art. 30 of the Massachusetts Declaration of Rights because it impermissibly delegated to a private individual (an arbitrator) a judicial function and denied meaningful judicial review. The court concluded that this statute's provision authorizing arbitration of a principal or superintendent's dismissal decision did not interfere with core judicial functions and that the scope of judicial review set forth in the statute did provide for meaning judicial review such that there was no art. 30 violation. Plaintiff also contended that, pursuant to G.L.c. 150C, section 11, the arbitration award should be vacated because the arbitrator acted in excess of her authority, engaged in misconduct, and exhibited bias against him. The court concluded that the judge properly concluded that the arbitrator did not exceed her authority or act in manifest disregard for the law. The court also rejected plaintiff's claims that the arbitrator engaged in misconduct and exhibited bias. Accordingly, the judgment was affirmed. View "Atwater v. Commissioner of Education" on Justia Law

Brett Nelson entered into contracts with the Arkansas Rural Medical Practice Student Loan and Scholarship Board and the rural community Forrest City pursuant to the state's community-match program that loaned Nelson money for his medical schooling and obliged him to practice medicine full time in Forrest City for four years upon the completion of his residency. Nelson began serving his four-year commitment in Forrest City, but when the hospital he was employed with did not renew his employment contract the next year, Nelson left Forest City to practice medicine in another state. The Board filed a complaint against Nelson for breach of contract and, alternatively, unjust enrichment. Nelson answered, asserting several affirmative defenses and making several counterclaims. The circuit court granted the Board's motion for summary judgment and entered judgment against Nelson in the amount of $133,152. The Supreme Court (1) reversed the grant of summary judgment to the Board on its breach of contract claim because questions of fact remained as to Nelson's counterclaims and defenses; and (2) otherwise affirmed. Remanded. View "Nelson v. Ark. Rural Med. Practice Loan & Scholarship Bd." on Justia Law

Petitioners were fifteen employees of the county Board of Education, who filed a grievance regarding changes made to the subsequent year's extracurricular coaching contracts, claiming they were entitled to receive notice and a hearing prior to the adoption of the changes and that they received neither. The ALJ and the circuit court denied the grievance. Petitioners appealed, contending that W. Va. Code 18A-2-7 gave them the right to receive a hearing before the Board could unilaterally alter the terms of the coaching contracts. The Supreme Court affirmed the circuit court's denial of Petitioners' grievance, holding that the circuit court's decision was not clearly wrong nor was it arbitrary, capricious, an abuse of discretion, or contrary to law. View "Martin v. Barbour County Bd. of Educ." on Justia Law

Respondent, a 36-year-old tenured high school teacher, was the subject of disciplinary charges pursuant to Education Law 3020-a as a result of her improper conduct with respect to a 15-year-old male student. Petitioner commenced this proceeding pursuant to CPLR 7511 to vacate the arbitration award, arguing that the penalty imposed was irrational and contrary to the public policy of protecting children. The court held that the arbitration award did not violate public policy where the award, on it's face, was neither prohibited by statute nor common law. The court also held that the award was not arbitrary, capricious, or irrational where the hearing officer engaged in thorough analysis of the facts and circumstances, evaluated respondent's credibility, and arrived at a reasoned conclusion that a 90-day suspension and reassignment was the appropriate penalty. Accordingly, the judgment was affirmed. View "City School Dist. of the City of New York v McGraham" on Justia Law

In this equal protection case, plaintiff appealed from a grant of summary judgment in favor of the School Board. The district court rejected plaintiff's claim that the School Board's student assignment plan, formulated to address school population changes while "maintaining the district's unitary status," was impermissibly race-based and discriminatory against minority elementary, middle, and high school students zoned for East Ascension High School. At issue on appeal was whether child A had standing; prescription of plaintiff's claims based upon the 2002 feeder plan modification; and whether Option 2f violated the Fourteenth Amendment's equal protection clause. The court held that because it remanded on other grounds, the court vacated the district court's ruling on whether plaintiff had standing to pursue claims on behalf of child A and remanded for reconsideration by the district court in the first instance as to whether to permit plaintiff to cure his defective allegations of capacity. The court also held that the district court correctly held that the 2002 feeder plan modifications claims were time-barred. The court finally held that because factual questions existed as to whether Option 2f had both a racially discriminatory motive and a disparate impact, and the district court misapprehended the significance of the evidence before it, that court erred in awarding summary judgment under a rational basis test. Accordingly, further factual development was required. View "Darrin Lewis, Sr. v. Ascension Parish School Board" on Justia Law

Defendants the Colbert County Board of Education ("the Board"); and the individual members of the Board and members of the Colbert County High School appealed a trial court's judgment that granted Plaintiff Felecia James's motion for a preliminary injunction. On or about May 21, 2010, an incident occurred at Colbert County High School (CCHS) involving J.H., Plaintiff's minor child, and another minor enrolled in CCHS. The details of the incident were disputed, but they led the assistant principal of the school to suspend both students for three days for allegedly fighting on school property during school hours. Plaintiff appeared before the Board to discuss the situation. The Board apparently took no action, and Plaintiff "individually and as mother and guardian of J.H." sued the Board and the individually named defendants asserting state-law and federal-law claims She also filed a motion for a temporary restraining order, a preliminary injunction, and a permanent injunction. Upon review, the Supreme Court found that the Board members in their official capacities were immune from the state-law claims filed against them insofar as those claims sought monetary damages. As such, the trial court lacked subject-matter jurisdiction over those state-law claims against the officials in their official capacities. However, the Board members were not immune from Plaintiff's state-law claims insofar as she sought injunctive relief based upon the Board members' alleged fraud, bad faith, or actions that were beyond the Board members' authority or that were taken under a mistaken interpretation of law. The Court noted that the Board and its members were not immune from the federal-law claims filed against them. Based on the foregoing, insofar as the Board appealed the preliminary injunction against it based upon the state-law claims filed by Plaintiff, the Supreme Court dismissed their appeal for lack of subject-matter jurisdiction. Because the Court reversed the preliminary injunction, the Court declined to order the trial court to vacate the preliminary injunction entered against the Board insofar as it was based on those claims. View "Colbert Cty. Bd. of Edu. v. James" on Justia Law

The Boaz City Board of Education ("the Board") and its members Alan Perry, Fran Milwee, Roger Adams, Alan Davis, and Tony G. King (collectively "the Board members") petitioned the Supreme Court for a writ of mandamus to direct the circuit court to vacate its order that denied their motion to dismiss claims filed against them by Lisa and Donnie Tarvin and to enter an order dismissing the claims with prejudice. According to the complaint, Leland Dishman, the superintendent for the Board, struck kindergarden teacher Lisa Tarvin with a paddle. Dishman read a statement at a press conference, denying that the incident occurred. The Tarvins sued the Board, the Board members in their official capacities, and Dishman in his individual capacity, alleging claims of assault and/or battery, defamation, libel, and slander and sought monetary damages. The Board and the Board members moved to dismiss the claims against them, arguing that they were immune from suit under the State immunity doctrine. Upon review, the Supreme Court found that the Board and its members demonstrated that under the Alabama Constitution, they had immunity from the claims asserted against them, and "a clear legal right to have the claims… dismissed with prejudice." The Court granted the petition and issued the writ. View "Tarvin v. Dishman" on Justia Law