Justia Education Law Opinion Summaries

A transgender student, Rebecca Roe, and the Sexuality and Gender Alliance (SAGA) at Boise High School challenged Idaho Senate Bill 1100 (S.B. 1100), which mandates that public school students use restrooms and changing facilities corresponding to their "biological sex." They argued that the law violates the Equal Protection Clause, Title IX, and the right to informational privacy. Roe and SAGA sought a preliminary injunction to prevent the law from being enforced.The United States District Court for the District of Idaho denied the preliminary injunction, concluding that SAGA was unlikely to succeed on the merits of its claims. The court found that the State's interest in protecting student privacy was an important governmental objective and that S.B. 1100 was substantially related to achieving that objective. The court also determined that SAGA did not show that the State had clear notice that Title IX prohibited segregated access to facilities based on transgender status. Additionally, the court found that SAGA did not demonstrate that S.B. 1100 violated the right to informational privacy.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court's decision. The Ninth Circuit agreed that SAGA did not establish a likelihood of success on the merits of its equal protection claim, as the State's interest in protecting bodily privacy was deemed important and the means chosen were substantially related to that objective. The court also held that SAGA failed to show that the State had clear notice that Title IX prohibited the exclusion of transgender students from facilities corresponding to their gender identity. Lastly, the court concluded that SAGA did not demonstrate that S.B. 1100 violated the right to informational privacy, as the statute did not necessarily disclose a student's transgender status. View "ROE V. CRITCHFIELD" on Justia Law

Jason Earlywine was employed as a teacher by the Board of Education of Paris Independent School District (BEP) from August 2007 to June 2019. In 2011, a student accused him of inappropriate conduct, leading to his placement on paid administrative leave, which was later changed to unpaid leave. He faced a criminal charge of Sexual Abuse in the First Degree, but the trial court granted him a directed verdict in January 2015, and the charge was expunged. Earlywine was reinstated in February 2015 but was terminated in 2019 for unspecified reasons. In 2020, he sued BEP to recover lost wages during his unpaid leave.The Bourbon Circuit Court initially handled the case, determining that BEP was within the waiver of immunity under KRS 45A.245(1) but transferred the case to Franklin Circuit Court due to venue appropriateness. BEP appealed, arguing governmental immunity and failure to exhaust administrative remedies. The Court of Appeals ruled that BEP's immunity was waived under KRS 45A.245(1) but concluded that Earlywine's failure to exhaust administrative remedies deprived the court of subject matter jurisdiction.The Supreme Court of Kentucky reviewed the case, affirming that BEP is subject to the waiver of immunity under KRS 45A.245(1). However, it reversed the Court of Appeals' conclusion regarding the exhaustion of administrative remedies, stating that this issue is subject to exceptions and should not have been addressed on interlocutory appeal. The Supreme Court remanded the case to Franklin Circuit Court for further proceedings, allowing Earlywine to argue any applicable exceptions to the exhaustion requirement. View "BOARD OF EDUCATION OF PARIS, KENTUCKY V. EARLYWINE" on Justia Law

Petitioner, a student at Stony Brook University, challenged the University's determination that he violated the University's Code of Student Responsibility by committing sexual misconduct against another student, S.G. The University conducted an investigation after receiving a report of the incident, during which S.G. provided a written statement detailing the encounter. P.C. declined to meet with the investigator. He was charged with sexual harassment, nonconsensual sexual contact, and nonconsensual sexual intercourse. A hearing was held, and the Review Panel found P.C. responsible for the charges, leading to his suspension.P.C. appealed the decision, arguing that the evidence did not support the findings and that the Review Panel improperly considered his decision to remain silent. The Appeals Committee upheld the Review Panel's determination and the disciplinary penalty. P.C. then commenced a CPLR article 78 proceeding, asserting that the determination lacked substantial evidence and was arbitrary and capricious.The Supreme Court transferred the case to the Appellate Division, which granted the petition, annulled the Appeals Committee's determination, dismissed the charges, and directed the University to expunge the matter from P.C.'s academic record. The Appellate Division majority found that substantial evidence did not support the conclusion that S.G. did not consent to the sexual activity and that the Review Panel improperly relied on P.C.'s decision not to answer questions.The Court of Appeals of New York reversed the Appellate Division's order, holding that substantial evidence supported the University's determination that P.C. violated the Code of Student Responsibility. The Court found that S.G.'s testimony and P.C.'s text messages provided sufficient evidence of nonconsensual sexual activity. The Court also rejected P.C.'s argument that the University's determination was arbitrary and capricious, concluding that the University followed its rules and procedures. The petition was dismissed. View "Matter of P.C. v Stony Brook Univ." on Justia Law

A school principal used the school's printer after hours to create a coaster as a retirement gift for a friend. The coaster design contained the School District's official logo but altered the District's motto in a disrespectful manner. A custodian took pictures of the coaster, which were shared on social media, leading to public outrage. The principal left the community the next day. The District proposed to terminate him for incompetence and violating anti-harassment policies. After a brief pretermination hearing, the District terminated the principal. The principal appealed, and the Board upheld the termination following an additional hearing.The principal then appealed to the superior court, which also affirmed his termination. The court found that the District had grounds to terminate the principal due to substantial noncompliance with District rules and regulations and that the community's reaction to the coaster was reasonable. The court also rejected the principal's free speech arguments, stating that his speech was not protected under the First Amendment. The court acknowledged that the pretermination hearing process was flawed but deemed the error harmless due to the subsequent post-termination hearing.The Supreme Court of the State of Alaska reviewed the case. The court held that the Board had a reasonable basis to terminate the principal for incompetency under AS 14.20.170(a)(1) due to his inability to perform his duties effectively after the incident. The court also concluded that the principal's termination did not violate his free speech rights under AS 14.20.095 or the First Amendment. However, the court found that the pretermination hearing process did not provide sufficient due process, as the principal was not informed of his right to call witnesses. The court affirmed the termination but reversed the superior court's decision denying back pay, awarding back pay through the date of the Board's post-termination hearing decision. View "Stirling v. North Slope Borough School District" on Justia Law

A tenured professor at the University of Illinois Chicago School of Law, Jason Kilborn, included an expurgated racial slur in a law school exam question. This led to an investigation by university officials, who found that Kilborn had created a racially hostile environment and violated the university's nondiscrimination policy. Consequently, Kilborn was suspended from teaching until he completed a diversity training program and was denied a two percent raise. Kilborn sued several university officials, alleging violations of his constitutional rights to free speech and due process.The United States District Court for the Northern District of Illinois dismissed Kilborn's federal claims with prejudice, finding that his speech was not constitutionally protected. The court also declined to exercise supplemental jurisdiction over his state law claims, dismissing them without prejudice. Kilborn appealed the decision.The United States Court of Appeals for the Seventh Circuit reviewed the case and reversed the dismissal of Kilborn's First Amendment retaliation claim, concluding that his speech was constitutionally protected under the Supreme Court's decisions in Connick v. Myers and Pickering v. Board of Education. The court found that Kilborn's speech addressed matters of public concern and that the university's actions could be seen as pretextual. However, the court affirmed the dismissal of Kilborn's remaining federal claims, including his compelled speech and procedural due process claims. The court also vacated the dismissal of Kilborn's state law claims for further consideration by the district court. View "Kilborn v. Amiridis" on Justia Law

The plaintiffs, January and Jeffrey Littlejohn, allege that the Leon County School Board and its officials violated their parental due-process rights. The dispute arose when school officials met with the Littlejohns' thirteen-year-old child to discuss the child's gender identity and developed a "Student Support Plan" without involving the parents, contrary to their wishes. The school officials acted in compliance with the Board's guidelines, which did not require parental notification if the child did not request it.The United States District Court for the Northern District of Florida dismissed the Littlejohns' claims. The court found that the release of a new guide in 2022 mooted the claims for injunctive relief based on the superseded 2018 guide. It also determined that the individual defendants were entitled to qualified immunity on the damages claims. The court concluded that the school officials' actions did not "shock the conscience" and thus did not violate the Littlejohns' substantive due-process rights. Consequently, the court dismissed the federal claims and declined to exercise supplemental jurisdiction over the state constitutional claims.The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the actions of the school officials were executive, not legislative, in nature. Therefore, the appropriate standard was whether the officials' conduct "shocked the conscience." The court concluded that the school officials' actions did not meet this standard as a matter of law. The court emphasized that the officials did not act with intent to injure and sought to help the child, even if their actions were contrary to the parents' wishes. Thus, the dismissal of the Littlejohns' claims was affirmed. View "Littlejohn v. School Board of Leon County" on Justia Law

Angalia B., the legal guardian and Educational Decision Maker (EDM) for J.B., a student at a Clark County School District (CCSD) elementary school, requested J.B.'s education records under FERPA and NRS 392.029(1). After receiving the records, Angalia suspected that certain emails were missing and requested all communications, including emails stored in CCSD's Google Vault. When CCSD did not respond, Angalia filed a motion to join CCSD to J.B.'s ongoing dependency case and to compel the production of the emails. CCSD opposed, arguing that the emails were not education records under FERPA and NRS 392.029(1) as they were not in J.B.'s permanent file. The district court ruled that the emails were education records and ordered CCSD to produce them.The Supreme Court of Nevada reviewed the case. The court determined that the emails stored in CCSD's Google Vault were maintained by CCSD, satisfying the second prong of the FERPA definition of education records. However, the court found that the district court erred in determining that the emails were directly related to J.B. without first reviewing their content. The Supreme Court of Nevada granted the petition for a writ of mandamus, directing the district court to vacate its order compelling CCSD to produce the emails.The Supreme Court of Nevada held that the district court must perform an in camera review of the emails to determine if they are directly related to J.B. If the emails are found to be directly related, they will qualify as education records under FERPA. The court emphasized that records are maintained when stored in a secure database, such as Google Vault, and that the definition of "maintained" should be interpreted broadly to accommodate future technological advancements. View "Clark County School District v. District Court" on Justia Law

Nathan Zent, who has spastic quadriplegic cerebral palsy, has been a student at Dickinson State University (DSU) since 2015, pursuing a Bachelor of Arts in English with a Political Science Minor. Zent, who uses a motorized wheelchair and an iPad with text-to-speech assistive technology, received vocational rehabilitation (VR) services from the North Dakota Department of Health and Human Services (DHHS) from 2015 until May 2023. His individualized plan for employment (IPE) identified an employment outcome of journalist or writer, which DHHS supported until 2022. However, DHHS discontinued Zent’s services, citing concerns about his ability to achieve competitive integrated employment due to his need for significant support.The Division of Vocational Rehabilitation of DHHS decided to discontinue Zent’s VR services, and an administrative law judge (ALJ) affirmed this decision. Zent appealed to the district court of Stark County, which also affirmed the ALJ’s decision. Zent then appealed to the North Dakota Supreme Court, arguing that DHHS’s decision was based on an erroneous interpretation of the statutes and regulations governing VR services and that the ALJ applied the incorrect standard of proof.The North Dakota Supreme Court reviewed the case and affirmed the district court’s judgment. The court held that DHHS did not misapply the statutes and regulations governing VR services in determining that Zent’s chosen employment outcome of journalist or writer was inconsistent with the goal of competitive integrated employment. The court also concluded that the ALJ correctly applied the preponderance of the evidence standard, as the clear and convincing standard only applies to eligibility determinations for VR services, not to determinations regarding specific employment outcomes. View "Zent v. NDDHHS" on Justia Law

Fiorisce, LLC, a limited liability company, filed a qui tam lawsuit against Colorado Technical University (CTU) under the False Claims Act (FCA), alleging that CTU misrepresented compliance with federal credit hour requirements to fraudulently obtain federal student aid funds. Fiorisce claimed that CTU's online learning platform, Intellipath, provided insufficient educational content and falsified learning hour calculations to meet federal standards. Fiorisce's principal, a former CTU faculty member, created the company to protect their identity while exposing the alleged fraud.The United States District Court for the District of Colorado reviewed the case. CTU moved to dismiss the complaint, arguing that the FCA’s public disclosure bar precluded the suit because the allegations were substantially similar to previously disclosed information. The district court denied CTU’s motion, finding that Fiorisce’s specific claims about misrepresentation of credit hours and the use of Intellipath were not substantially the same as prior disclosures. The court also suggested that Fiorisce might qualify as an original source of the information.CTU appealed the district court’s denial of its motion to dismiss to the United States Court of Appeals for the Tenth Circuit, seeking interlocutory review under the collateral order doctrine. The Tenth Circuit concluded that the collateral order doctrine did not apply, as the public disclosure bar did not confer a right to avoid trial and could be effectively reviewed after final judgment. The court emphasized that expanding the collateral order doctrine to include such denials would undermine the final judgment rule and dismissed CTU’s appeal for lack of jurisdiction. View "Fiorisce, LLC v. Colorado Technical University" on Justia Law

The defendant, Nicholas H. Brooks, was convicted of two counts of simple assault following a jury trial. The incident occurred on February 17, 2022, when Brooks, working as a substitute educator, attempted to take a toy from a student who was causing a disturbance in the classroom. The student refused to comply, swore at Brooks, and allegedly lunged at him. Brooks then grabbed the student's sweatshirt and pushed him against a wall. The jury saw video evidence of the incident and heard testimony from multiple witnesses.The Superior Court (Bornstein, J.) denied Brooks' request to instruct the jury on the "special responsibilities" defense for the charges on which he was convicted. The court allowed the instruction only for the charge related to grabbing the student's hand. Brooks was acquitted of the second-degree assault charge and the first simple assault charge but was convicted of the second and third simple assault charges. Brooks appealed, arguing that the trial court erred in its jury instructions, admission and exclusion of certain testimonies, and handling of the complainant's school records.The Supreme Court of New Hampshire reviewed the case and found that the trial court erred in not providing the special responsibilities defense instruction for all charges. The court clarified that the correct standard of review for such a denial is de novo, not an unsustainable exercise of discretion. The court determined that there was "some evidence" to support a rational finding that Brooks was acting as a person with special responsibilities throughout the incident. Consequently, the court reversed Brooks' simple assault convictions and remanded the case for a new trial. The court also addressed other evidentiary issues, finding errors in the trial court's admission of certain testimonies and exclusion of a student's statement. View "State v. Brooks" on Justia Law