Justia Education Law Opinion Summaries

After injuring her back in a car accident, plaintiff filed for and received long-term disability benefits from the insurance plan sponsored by her employer. Plaintiff brought suit pursuant to the Employee Retirement Income Security Act of 1974 (ERISA), 42 U.S. C. 29 U.S.C. 1001 et seq., against her employer and the administrators and underwriters of her employer-sponsored long-term benefit disability insurance policy after the claims administrator of that plan determined that she no longer qualified for benefits. At issue was whether the district court properly granted defendants' motion for summary judgment, finding no violation of law. The court held that because defendants acted reasonably, the court concluded that defendants' termination of plaintiff's benefits complied with federal law. The court found none of plaintiff's procedural claims persuasive and held that the district court did not err when it held that defendants did not violate plaintiff's right to a full and fair review of her adverse eligibility determination. The court also rejected plaintiff's argument that the district court violated local rule 7(h) where plaintiff failed to make this argument before the district court. Accordingly, the court affirmed the judgment of the district court. View "Pettaway v. Teachers Ins. and Annuity, et al." on Justia Law

The parents of E.M., a bilingual student, brought an action to challenge the Pajaro Valley Unified School District's (District) determination that E.M. did not qualify for special education under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq. The Special Education Division of the California Office of Administrative Hearings (OAH) upheld the District's assessment and the district court affirmed the OAH's decision. The court disagreed with the district court's assessment only to the extent that it found one claim not addressed and one report not measured for its relevance. Accordingly, the court affirmed the judgment of the district court in part and reversed in part. The court remanded for the district court to consider whether the report was relevant to the determination of whether the district met its obligations to E.M. under the IDEA and whether an auditory processing disorder could qualify as an other health impairment, and if so, whether the district met its obligations to assess E.M. and identify him as a child with an other health impairment. View "E. M. v. Pajaro Valley Unified Sch. Dist." on Justia Law

Plaintiff appealed summary judgment on her claims of sex discrimination and retaliation under 20 U.S.C. 1681(a) (Title IX) and 42 U.S.C. 1983. The court found that the case was nothing more than a dispute fueled by a disgruntled cheerleader mom, over whether her daughter should have made the cheerleading squad. The court affirmed summary judgment on the Title IX claim and held that the supposed harassment was not based on sex, it was not severe, pervasive or objectively unreasonable, and the district court was not deliberately indifferent to it. The court affirmed summary judgment on the Title IX retaliation claim and held that there was no support in the record for plaintiff's arguments. The court affirmed summary judgment on the section 1983 claim and held that any harassment was not based on sex, so there was no constitutional violation and there was no evidence that the district court was ever deliberately indifferent. The court affirmed summary judgment on the section 1983 retaliation claim and held that plaintiff failed to point to any evidence that the district court retaliated against her. View "Sanches v. Carrollton-Farmers Branch Indep. Sch. Dist." on Justia Law

Plaintiff, the mother of a developmentally disabled high school student, alleged that the several sexual encounters her daughter had with another developmentally disabled student in a school bathroom were the result of the school's failure to properly supervise her daughter. At issue was whether plaintiff, individually and on behalf of her daughter, had a cognizable Fourteenth Amendment due process claim against the daughter's special education teacher. The court held that the district court properly dismissed plaintiff's 42 U.S.C. 1983 civil rights claim at summary judgment where the special-relationship exception and the state-created danger exception did not apply in this case. The court held that whatever liability the special education teacher faced, that liability must come from state tort law, not the Fourteenth Amendment. Accordingly, the judgment of the district court was affirmed. View "Patel v. Kent Sch. Dist., et al." on Justia Law

The ACLU sued public charter school Tarek ibn Ziyad Academy (TIZA) and other defendants for violations of the Establishment Clause. At issue was whether the parents of students who attended TIZA had standing to intervene on behalf of the children and, in the alternative, whether the motion to intervene was timely. The court held that the parents had Article III standing where the parents have alleged an injury in fact, facts showing that the injury was imminent, the injury was fairly traceable to defendant's conduct, and redressability. The court held, however, that the district court did not make a clear error in finding the motion untimely where it was evident that for fourteen months, the parents were content to remain aloof from the litigation and dependent on TIZA to adequately represent their interests despite their knowledge of the case and its progress. The court further denied the ACLU's motion to supplement the record on appeal because the material proffered would not affect the outcome of the trial and denied the ACLU's motion to seal because it was moot. Accordingly, the court affirmed the district court's denial of the parents' motion to intervene. View "American Civil Liberties Union v. Mohammad, et al." on Justia Law

The New York State Department of Education and related defendants appealed from an order of the district court denying their motion to vacate an award of attorney's fees to plaintiff where the district court had awarded plaintiff attorney's fees pursuant to 42 U.S.C. 1988(b) after he successfully challenged on equal protection grounds New York State Education Law 6704(6), which restricted professional veterinarian licenses to United States citizens and aliens who were lawful permanent residents of the United States. The Department appealed the district court's ruling and while the appeal was pending, the United States granted plaintiff permanent legal resident status, which meant that section 6704(6) no longer precluded him from obtaining the license. Accordingly, a panel of the court dismissed the appeal as moot and vacated the judgment. The Department then moved to vacate the fee award. The court agreed with the district court that because the judgment in plaintiff's favor, though later vacated, had brought a judicially-sanctioned, material alteration of the parties' legal relationship that had not been reversed on the merits, plaintiff was a prevailing party entitled to attorney's fees under 42 U.S.C. 1988(b). View "Kirk v. New York Dep't. of Educ." on Justia Law

The Michigan Campaign Finance Act (MCFA) prohibits a "public body" from using public resources to make a "contribution or expenditure" for political purposes. At issue in this case what whether a public school district's administration of a payroll deduction plan that collects and remits political contributions from its employees to the Michigan Education Association's political action committee violates the MCFA. Upon review, the Supreme Court found that through the administration of a payroll deduction plan that remits funds to a partisan political action committee, a school district makes both a "contribution" and “expenditure" under the terms of the MCFA. View "Michigan Edu. Ass'n v. Michigan Sec'y of State" on Justia Law

Proposal 2, a successful voter-initiated amendment to the Michigan Constitution, became effective in 2006 and prohibited public colleges from granting "preferential treatment to[] any individual or group on the basis of race, sex, color, ethnicity, or national origin." The district court entered summary judgment upholding Proposal 2. The Sixth Circuit reversed, based on two U.S. Supreme Court decisions, and applying strict scrutiny because the enactment changed the governmental decision-making process for determinations with a racial focus. Proposal 2 targets a program that "inures primarily to the benefit of the minority" and reorders the political process in Michigan in such a way as to place "special burdens" on racial minorities. Admissions committees are political decision-making bodies and the Proposal is more than a mere repeal of desegregation laws. The court noted the procedural obstacles that would be faced by minorities favoring race-based admissions.

In the fall of 2008 William Hartford, a high school science teacher, was fired after his Montana teaching certificate expired by his inadvertence in failing to renew it. Hartford sought to file a grievance, alleging that he had been terminated without just cause in violation of a collective bargaining agreement (CBA) entered into between Kalispell School District (District) and the Kalispell Education Association (KEA). The district superintendent, and later the board of trustees, denied Hartford's request, claiming the matter did not constitute a valid grievance under the CBA on grounds that Hartford was not a member of the bargaining unit at any point during his employment in the fall of 2008 and that he was not a "teacher" as defined under Montana law during his employment in the fall of 2008. Hartford and the KEA filed a petition in the district court to compel arbitration as provided in the CBA. The district court granted summary judgment in favor of Hartford and the KEA and ordered the matter submitted to arbitration. The Supreme Court affirmed, concluding that the questions raised by the matter were properly submitted to arbitration.

After a petition seeking to transfer territory from Dutton/Brady K-12 School District to Conrad High School and Elementary Districts was refused by the county superintendent of schools, the petition was referred to a three-member panel of county superintendents. The panel denied the petition, and the district court affirmed. Conrad Schools appealed, arguing that the district court erred in concluding the panel of superintendents abused its discretion in denying the petition. The Supreme Court affirmed, holding that the record demonstrated that the panel carefully evaluated the effects of the proposed transfer and made its decision based upon the best and collective interests of all students involved.