Justia Education Law Opinion Summaries

Ten special education students and their parents and guardians (Appellants) sued Clover Park School District for intentional torts, outrage, negligence and unlawful discrimination under state law. Clover Park moved for summary judgment to dismiss, arguing that Appellants had not exhausted the administrative remedies available under the state Individuals with Disabilities Education Act (IDEA). The trial court granted Clover Park’s motion. Upon review, the Supreme Court reversed the trial court and remanded the case, holding that IDEA’s administrative exhaustion requirement does not apply to state-law claims nor does Washington State law require exhaustion before filing such claims. View "Dowler v. Clover Park Sch. Dist. No. 400" on Justia Law

A Caucasian high school football player (H) accidentally hit an African-American team member (D) with his car, causing D to suffer a sprained ankle. H got out and apologized. D threatened to kill him. The principal had instructed staff to be lenient with African-Americans because too many were serving suspensions. Although the Code of Conduct prohibits threats, the school did not discipline D. D's parents threatened suit. The principal admitted suspending H for 10 days to "cover" himself and the school. H's witness statements were not provided to panelists in advance. H's attorney was limited to passing notes and not allowed to present witnesses. Employees were informed that they would lose their jobs if they attended the hearing. The board sustained the charge of reckless endangerment and suspension, so that it went on H's record. An appeal was denied. Before his suspension, college recruiters had approached H and a congressman had offered an appointment, the first step to attend a military academy. H alleges he lost those opportunities. The district court dismissed 42 U.S.C. 1983 claims for substantive due process violations, failure to train, and negligence; claims by H's parents; claims against individuals in their official capacities; claims against the board of education and the public school system. The Sixth Circuit affirmed denial of the motion to dismiss procedural due process and equal protection claims based on the conduct of three defendants and that those defendants are not protected by qualified immunity.View "Heyne v. Metro. Nashville Pub. Schs." on Justia Law

A six-year-old boy, with profound hearing impairment, was furnished with transportation to and from school as part of his individualized education program. The school district contracts with a private company for bus service. The boy alleged sexual abuse by a bus driver. The family sued under 42 U.S.C. 1983 and Title IX of the Education Amendments of 1972, 20 U.S.C. 1681-1688. The district court ruled in favor of the defendants. The First Circuit affirmed. The Section 1983 claim was properly rejected because transportation to and from school is not an exclusive state function; defendants did not act under color of state law. The Title IX claim failed because it is not clear that the "appropriate person," with the authority to take disciplinary action against the bus driver, actually knew about the alleged harassment and exhibited deliberate indifference toward it.View "Santiago v. Commonwealth of PR" on Justia Law

A former public high school student alleged that his history teacher violated his rights under the Establishment Clause by making comments during class that were hostile to religion in general, and to Christianity in particular. At issue was whether the teacher was entitled to qualified immunity. The court affirmed the district court's conclusion that the teacher was entitled to qualified immunity. The court also held that because it was readily apparent that the law was not clearly established at the time of the events in question, and because the court could resolve the appeal on that basis alone, the court declined to pass upon the constitutionality of the teacher's challenged statements. View "C.F. v. Capistrano Unified Sch. Dist, et al." on Justia Law

The family owned property and lived in Newburyport, but enrolled their son in school in Stamford, Connecticut during the 2008-2009 school year. His mother rented an apartment in Connecticut and on weekends returned to a Newburyport. The family gave up the Newburyport residence and moved to Connecticut in fall, 2009. The First Circuit vacated rulings in favor of the school district under the Individuals with Disabilities Education Act, 20 U.S.C. 1400-1482, which requires an education authority to provide an Individualized Education Plan for the benefit of any child with a disability. The district court misread the claims as moot. The claims are fairly read as saying that a procedural inadequacy, untimeliness, compromised plaintiffs' son's right to a guaranteed education. Newburyport had no obligation to draft a 2009 IEP for a nonresident, but the parents sought tuition reimbursement for the 2008-09 school year. View "Doe v. Newburyport MA Public Sch." on Justia Law

Plaintiff sued his former music teacher, the Logan-Rogersville R-VII School District, and the school principal, asserting nine different claims stemming from the teacher's alleged sexual abuse of plaintiff. At issue was whether the district court erred in dismissing plaintiff's claims and denying his motion to amend his complaint. The court held that the district court correctly concluded that Counts 3, 4, 7, 8, and 9 were time-barred where plaintiff's complaint established that his cause of action accrued in 1992 when he was 15 years old, the statute of limitations was tolled until his 21st birthday, and he had five years, until November 22, 2003, to file his complaint. The court also held that plaintiff's claims under 42 U.S.C. 1983 and Title IX were also time-barred where both claims relied on the state's statute of limitations governing personal-injury claims and Missouri imposed a five-year statute of limitations for personal injury actions, Mo. Rev. Stat. 516.120.4. For the same reasons, plaintiff's state-law claims were time barred by section 516.120.4. The court further held that the district court's dismissal of plaintiff's childhood sexual abuse claim was affirmed where Mo. Rev. Stat. 537.046 required him to commence his action within five years of his 18th birthday. The court finally held that the district court properly dismissed plaintiff's sexual abuse claim against the school district and principal and the district court did not err in denying as futile plaintiff's motion to amend. Accordingly, the court affirmed the judgment of the district court. View "Walker v. Barrett, et al." on Justia Law

Norma Jean King worked for the Hays/Lodge Pole School District for more than thirty-five years, holding positions of elementary school teacher, elementary school principal, and high school principal. After serving as the high school principal for three years, the school district board of trustees reassigned her to an elementary school teaching position. On appeal, the county superintendent and, subsequently, the state superintendent affirmed the board's reassignment decision. The district court reversed the state superintendent's ruling, holding that the state superintendent erred in ruling that a principal position was comparable to a teaching position. The Supreme Court reversed the judgment of the district court, holding that the district court erred in concluding that the positions of teacher and principal were not comparable positions of employment under the applicable statutes. Remanded. View "King v. Hays Lodge Pole Sch. Board of Trs." on Justia Law

Plaintiffs appealed from a judgment of the district court granting summary judgment in favor of a school district and principal on 42 U.S.C. 1983 claims arising out of the treatment of their son, a middle school student with a history of misbehavior in school, who wrote an essay with descriptions of illegal activity, violence, and suicide (Racing Time essay). Plaintiffs appealed the dismissal of a First Amendment retaliation claim brought on behalf of their son and the dismissal of their own Fourth Amendment substantive due process claim. The court held that none of the principal's actions in response to the student's speech constituted retaliation; and because neither of the principal's actions in response to the essay were adverse, the court affirmed the district court's grant of summary judgment to the principal on the First Amendment retaliation claim. The court also held that the principal's call to Child and Family Services (CFS) did not violate the parents' substantive due process rights where there was no actual loss of the parents' custody and no reasonably jury could conclude that the principal's report to CFS, or the resulting requirement that the student by psychiatrically evaluated, was even remotely "outrageous" or "conscience-shocking." The court did not reach the question of qualified immunity. Accordingly, the court affirmed the judgment of the district court. View "Cox v. Warwick Valley Central Sch." on Justia Law

This case arose when a student told a police officer that her teacher, plaintiff, inappropriately touched her and police subsequently searched plaintiff's home for child pornography. Plaintiff and his son sued the police officer, the City of Covina, and the Chief of Police for violating his constitutional rights, claiming that the city and the officers violated his and his son's Fourth Amendment right to be free from unreasonable search and seizure; the city inadequately trained and inadequately investigated complaints about its officers (Monell claim); and all defendants inadequately supervised and trained their subordinates with respect to the incidents alleged. The court held that, under the totality of the circumstances, a search warrant issued to search a suspect's home computer and electronic equipment lacked probable cause when no evidence of possession or attempt to posses child pornography was submitted to the issuing magistrate; no evidence was submitted to the magistrate regarding computer or electronics used by the suspect; and the only evidence linking the suspect's attempted child molestation to possession of child pornography was the experience of the requesting police officer, with no further explanation. The court held, however, that it had not previously addressed such issues and therefore, the officers involved in the search were entitled to qualified immunity. The court also affirmed the dismissal of plaintiff's Monell and supervisory liability claims where amending the complaint would be futile. View "Dougherty, et al. v. City of Covina, et al." on Justia Law

Qui tam relators brought this action on behalf of the United States government, appealing the district court's judgment dismissing, without leave to amend, their original complaint against the Individual Defendants and Ernst & Young (EY) under Federal Rule of Civil Procedure 12(b)(6). Relators alleged that the Individual Defendants, with the help of EY, falsely certified to the Department of Education its compliance with the Higher Education Act's (HEA), 20 U.S.C. 1094, ban on recruiter-incentive compensation in order to receive federal education funds, thereby violating the False Claims Act (FCA), 31 U.S.C. 3729(a)(1), (2), (3), (7). The court held that under the liberal standards for amending complaints, relators should be permitted to plead additional facts that could cure the complaint's deficiencies as to the allegations that Corinthian made a false statement and acted with the requisite scienter. The court also held that relators should have been allowed to amend the complaint to sufficiently state an FCA claim against the Individual Defendants. The court further held that, assuming that their complaint sufficiently alleged a false statement, relators have sufficiently pled an FCA violation as to EY. Accordingly, the court reversed the district court's Rule 12(b)(6) dismissal as to Corinthian, the Individual Defendants, and EY, and remanded with instructions to permit leave to amend the complaint. View "United States, et al. v. Corinthain Colleges, et al." on Justia Law