Justia Education Law Opinion Summaries

This case started more than fifty years ago when Minnie Liddell sued to desegregate the St. Louis public school system. The NAACP joined the lawsuit, and the State of Missouri (among others) became a defendant. The parties struck a deal that lasted until 1999 when they agreed to end Missouri’s remedial obligations. The Missouri Legislature ratified the parties’ settlement agreement and created a charter-school option. A group of charter schools complained to the Missouri Legislature, which altered the funding formula in 2006. The revised formula, part of Senate Bill 287, is what has led to the current dispute. The St. Louis Public School District and one of the plaintiffs asked the district court to enforce the settlement agreement by having Missouri reimburse it for the special-sales-tax revenue it had lost under the new funding formula. The district court sided with Missouri, and both sides appealed. Plaintiffs continued to believe that the St. Louis Public School District should receive all the special-sales-tax revenue. And Missouri argued that the desegregation-spending condition finds no support in the settlement agreement.   The Eighth Circuit affirmed the district court’s judgment but vacated the part requiring charter schools to spend those funds on “desegregation measures.” The court explained that there has been no “disproportionate adverse financial impact” on the St. Louis Public School District because it never had a right to keep all the special-sales-tax revenue for itself. Moreover, the court rejected the argument that allowing charter schools to spend their money as they see fit is inconsistent with the “purpose” of the settlement agreement. View "Deric Liddell v. State of Missouri" on Justia Law

This case involves an appeal by the Charlotte-Mecklenburg County Board of Education (“CMS”) and cross-appeal by Plaintiff, individually and on behalf of his child, A.B. Plaintiff filed an administrative action in North Carolina, alleging that CMS violated the Individuals with Disabilities Act (“IDEA”), by failing to provide A.B. with a free appropriate public education (“FAPE”) through an individualized education plan (“IEP”). The administrative law judge (“ALJ”) dismissed Plaintiff’s action as time-barred by a one-year statute of limitations. CMS filed an original civil action in district court, seeking a judicial determination that the statute of limitations barred Plaintiff’s administrative action. Plaintiff and A.B. filed a counterclaim, asking the district court to decide the merits of the underlying IDEA claim. The district court agreed with the SHRO and held that the statute of limitations did not bar Plaintiff’s IDEA claim, but it held that Plaintiff needed to exhaust his administrative remedies before bringing the merits to federal court. Both parties appealed.   The Fourth Circuit affirmed the district court’s holding as to CMS’s appeal and held that the statute of limitations does not bar Plaintiff’s IDEA claim. But, because Plaintiff’s counterclaim is compulsory, the court concluded that he need not exhaust. Therefore, the court reversed on that issue and remanded to the district court for further proceedings. The court explained that the Plaintiff was prevented from filing a timely administrative petition because CMS withheld information it was required to provide him. Therefore, his IDEA petition was not barred by the statute of limitations. View "Charlotte-Mecklenburg County Board of Education v. Aleah Brady" on Justia Law

The Loudoun County Public Schools (the “LCPS”) developed and implemented a “Student Equity Ambassador Program” “to amplify the voices of Students of Color and those who have experienced or witnessed injustices, marginalization, or discrimination.” In response, the parents of several children who attend the LCPS sued the Loudoun County School Board (the “School Board”) on behalf of their minor children, asserting Equal Protection and First Amendment claims, claiming their children are not eligible for the Program due to their race or viewpoint.The district court granted the School Board's motion to dismiss and the parents appealed.On appeal, the Fourth Circuit held that the parents did not have standing to challenge the Student Equity Ambassador Program because their children did not apply for the program or even express an interest in applying. However, the court also held that the parents plausibly alleged that implementing the Program chilled their children’s speech to support their First Amendment claims. Thus, the court vacated the district court's ruling on the parents' First Amendment claims. View "Patti Menders v. Loudoun County School Board" on Justia Law

Plaintiff was dismissed from the Univeristy of Virginia's doctoral program after receiving poor grades. Plaintiff sued, alleging national origin discrimination and retaliation based on interactions with his immediate supervisor. The district court granted the school's motion to dismiss and Plaintiff appealed.The Fourth Circuit affirmed, finding that although his supervisor made derogatory comments about Plaintiff's national origin, they were not made in close proximity to the school's decision to dismiss Plaintiff. The supervisor made a "handful" of comments over the course of four years, none of which were close in time to the Plaintiff receiving poor grades or being dismissed from the program. View "Andreas Alberti v. Rector and Visitors of the University of Virginia" on Justia Law

The University's adjunct faculty taught individual classes on a semester-by-semester basis. Their appointment letters referred to the Collective Bargaining Agreement, specified a per-course salary, and estimated the number of work hours. Although the letters specified a work appointment from the first day of classes to the end of the semester, adjuncts were required to work outside of these time periods to prepare a syllabus and submit final grades. Adjuncts’ wage statements did not show the number of hours worked or an hourly pay rate.Gola brought claims for unpaid wages and failure to pay compensation at the time of discharge, citing work done outside of the assignment period and after the adjuncts’ “termination,” and alleged that the University failed to issue wage statements in compliance with Labor Code 226(a). Gola asserted a derivative claim under the Private Attorneys General Act (PAGA) seeking civil penalties.The trial court held that two causes of action were preempted by the Labor Management Relations Act (29 U.S.C. 141) because they could not be resolved without interpreting the CBA. On the wage statement claim, the court concluded that adjuncts were not exempt employees and that the University was liable for penalties because it knew that facts existed bringing its actions within the provisions of section 226. The court calculated statutory damages and PAGA penalties and awarded Gola attorneys’ fees and costs. The court of appeal affirmed, rejecting arguments that newly-enacted Labor Code 515.7—permitting employers to classify certain adjunct faculty as exempt from specified wage statement requirements—should be applied retroactively. View "Gola v. University of San Francisco" on Justia Law

In March 2020, Bradley University closed its campus and canceled in-person activities because of the COVID-19 pandemic. It canceled one week of classes as it migrated to remote learning. Bradley resumed classes virtually and offered remote activities and resources. The campus remained closed for the rest of the semester. Bradley never rescheduled the week of canceled classes; the Spring 2020 Semester was 14 weeks instead of the planned 15 weeks of classes listed in Bradley’s Catalog, which stated: “This catalog serves as a contract between a student and Bradley.” Full-time, on-campus students had paid $17,100 in tuition and an $85 activity fee. The University provided pro-rata refunds for room and board to students who were forced to leave on-campus housing but did not refund tuition or activity fees.Eddlemon filed a purported class action, alleging that Bradley breached an implied contract to provide 15 weeks of classes and on-campus activities, and, alternatively that the University’s retention of tuition and activity fees constituted unjust enrichment. The district court certified a “Tuition Class” and an “Activity Fee Class.” The Seventh Circuit vacated. The district court did not conduct the rigorous analysis required by Rule 23 for class certification but repeatedly referred to Eddlemon’s allegations without addressing his proffered evidence or examining how he would prove his allegations with common evidence. View "Eddlemon v. Bradley Universityx" on Justia Law

Parents and guardians of students with disabilities brought an enforcement action under the Individuals with Disabilities Education Act, alleging that the New York City Department of Education must immediately fund their children’s educational placements during the pendency of ongoing state administrative proceedings. Plaintiffs moved for a preliminary injunction, which the district court denied. Plaintiffs appealed from that denial.   The Second Circuit affirmed. As a threshold jurisdictional matter, the court held that although the Plaintiffs are not yet entitled to tuition payments for the portion of the school year that has yet to occur, their claims are nevertheless ripe because they also seek payments for past transportation costs. On the merits, the court held that the IDEA’s stay-put provision does not entitle parties to automatic injunctive relief when the injunctive relief concerns only educational funding, not placement. Applying the traditional preliminary injunction standard, the court concluded that Plaintiffs are not entitled to the relief they seek because they have not shown a likelihood of irreparable injury. View "Mendez v. Banks" on Justia Law

Dr. Bounds was hired for one year beginning in July 2019 as an at-will employee. In February 2020, Dr. Scott stated that Scott would recommend that Bounds's contract be renewed. Scott notified Bounds and others on March 24 that she would email approved contracts and that they had until March 31 to sign and return the contracts. Upon receiving the contract, Bounds noted that her vacation days had been reduced. Scott told Bounds to contact the Board. Later that day, Bounds became ill and was advised to quarantine for 14 days. Bounds testified that she made inquiries to the Board but never received a reply. On April 1, Scott telephoned Bounds, who had not returned the signed contract. Bounds replied that she wanted her attorney to review the agreement. Scott warned that the Board previously had released another administrator who did not sign her contract by the deadline. The following day, Scott advised Bounds that the Board had requested that her position be posted as vacant. On April 14, Bounds was notified that her position had been posted.Bounds filed suit, 42 U.S.C. 1983, contending that the Board had deprived her of procedural due process by rescinding her contract and posting her position without notice or the opportunity to be heard. The Seventh Circuit affirmed summary judgment in favor of the defendants. Bounds did not have a property interest subject to due process protections. Bounds had no enforceable expectation as to her continued employment. View "Bounds v. Country Club Hills School District 160" on Justia Law

Brownsburg Community School Corporation requires its high school teachers to call all students by the names registered in the school’s official student database. Kluge, a teacher, objected on religious grounds to using the first names of transgender students to the extent that he deemed those names not consistent with their sex recorded at birth. After Brownsburg initially accommodated Kluge’s request to call all students by their last names only, the school withdrew the accommodation when it became apparent that the practice was harming students and negatively impacting the learning environment for transgender students, other students in Kluge’s classes and in the school generally, and the faculty.Kluge brought a Title VII religious discrimination and retaliation suit after he was terminated from his employment. The district court granted the school summary judgment, concluding that the school was unable to accommodate Kluge’s religious beliefs and practices without imposing an undue hardship on the school’s conduct of its business of educating all students and rejected Kluge’s retaliation claim.The Seventh Circuit affirmed. The undisputed evidence demonstrates that Kluge’s accommodation harmed students and disrupted the learning environment. No reasonable jury could conclude that harm to students and disruption to the learning environment are de minimis harms to a school’s conduct of its business. View "Kluge v. Brownsburg Community School Corp." on Justia Law

This case involves a student named J.M. A psychologist diagnosed J.M. with autism spectrum disorder. Based in part on that diagnosis, J.M.’s mother—Plaintiff—asked the local school district to evaluate J.M. for an IEP. Plaintiff disagreed with the IEP team’s conclusion and asked the school district to pay for additional evaluations in five areas it had considered before (adaptive behavior, educational, speech-language, occupational therapy, and autism). Without waiting for another decision from the IEP team, Plaintiff launched the administrative review process by petitioning for a contested case hearing. Plaintiff’s initial filing alleged seven violations of the IDEA. Plaintiff then filed a complaint in federal district court, seeking seven forms of relief.   The Fourth Circuit denied the school district’s motion to dismiss this appeal for lack of subject matter jurisdiction. However, the court saw no basis for disturbing the district court’s grant of summary judgment for the school district. The court explained that beyond making a bare allegation that the ALJ issued an incompetent decision, Plaintiff does not explain how any of the alleged procedural defects she identified corrupted any administrative findings. The court also rejected Plaintiff’s claim that the IEP team acted wrongfully in failing to follow the recommendations of private evaluators in determining J.M.’s eligibility for an IEP. The IDEA does not require school districts to defer to the opinions of private evaluations procured by a parent. To the contrary, the IDEA instructs school districts to rely on diverse tools and information sources in making an eligibility assessment. View "Cheri Miller v. Charlotte-Mecklenburg Schools" on Justia Law