Justia Education Law Opinion Summaries

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In 2023, the Texas Legislature passed the Restricting Explicit and Adult-Designated Educational Resources Act (READER), which requires vendors selling books to Texas public schools to issue sexual-content ratings for all library materials they have ever sold or will sell. Certain Texas bookstores, trade associations, and a legal defense organization sued for injunctive relief, alleging that READER violates their First and Fourteenth Amendment rights. The district court granted a preliminary injunction, which Texas appealed. The United States Court of Appeals for the Fifth Circuit affirmed the grant of the preliminary injunction against the Commissioner of the Texas Education Agency, vacated the preliminary injunction against the Chairs of the Texas State Library and Archives Commission and the Texas State Board of Education, and remanded the case to the district court with instructions to dismiss the suit against them. The court held that the plaintiffs were likely to succeed on their claim that READER unconstitutionally compels speech. The court also found that the plaintiffs would suffer irreparable harm if the injunction was not granted, the balance of equities tipped in their favor, and an injunction was in the public interest. View "Book People, Inc. v. Wong" on Justia Law

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In this case, Jeffrey L. Cruce, the former head football coach and athletic director for Berkeley High School, filed a lawsuit against the Berkeley County School District (the District) for wrongful termination and defamation. The defamation claim was based on an email circulated by an athletic trainer questioning the integrity of student athlete files maintained by Cruce. The court of appeals had ruled that Cruce was a public official for the purposes of defamation law, and thus required to prove actual malice to win his defamation claim, which the South Carolina Tort Claims Act (SCTCA) grants the District immunity from.The Supreme Court of South Carolina disagreed, stating that being a public employee and enjoying media attention does not make Cruce a public official, as he did not have any official influence or decision-making authority about serious issues of public policy or core government functions. The court also rejected the District's claim that Cruce was a public figure, stating that the controversy over Cruce's coaching tactics did not affect large segments of society and was unrelated to the defamation claim. The court ruled that Cruce was not a public official, not a public figure, and that his defamation claim was supported by evidence, reversing the decision of the court of appeals and reinstating the jury's damages award. View "Cruce v. Berkeley County School Dist" on Justia Law

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In this case, Alyssa Reid, a former faculty member at James Madison University (JMU) in Virginia, was accused of violating JMU’s Title IX policy against non-consensual relationships based on her past relationship with a graduate student. JMU and its officials investigated the accusation and held a hearing, leading to a decision that Reid violated the policy. Reid appealed the decision to JMU’s provost, who denied her appeal. Subsequently, Reid sued JMU and several officials, raising three due process claims under both 42 U.S.C. § 1983 and the Virginia Constitution, as well as a sex discrimination claim under Title IX.The United States District Court for the Western District of Virginia held that Reid’s claims accrued when the dean made his decision, and thus they were barred by the applicable two-year statute of limitations. Reid appealed this decision, arguing that her claims accrued not when the dean issued his decision, but when the provost denied her appeal.The United States Court of Appeals for the Fourth Circuit agreed with Reid. The court found that Reid did not have a complete and present cause of action until JMU reached a final decision in her Title IX proceedings. The court determined that JMU did not make clear that the dean’s decision was its official position. Rather, JMU’s official position was made clear to Reid when the provost denied her appeal with a “final,” non-appealable decision. Therefore, Reid’s due process and Title IX claims were not barred by the applicable two-year statute of limitations, and the court reversed the district court's dismissal of Reid’s claims and remanded for further proceedings. View "Reid v. James Madison University" on Justia Law

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In a dispute between Timothy Towne and the Unified School District No. 259, the Supreme Court of the State of Kansas reversed the lower courts' rulings, finding that self-insured school districts are not exempt from regulation under the Kansas Insurance Code. Towne, an employee of the school district, was injured in a car accident and received benefits from the school district's self-funded medical benefit plan. After Towne recovered funds from a third party, the school district required him to reimburse the plan. Towne claimed that the plan's subrogation clause, which allowed for this reimbursement, was unenforceable under Kansas regulations. The district court and Court of Appeals held that the school district's plan was exempt from the Kansas Insurance Code, thereby making the subrogation clause enforceable. However, the Supreme Court reversed, holding that the medical benefit plan offered by the school district is a "health benefit plan" and the school district is a "health insurer" under Kansas law, making the school district subject to the anti-subrogation regulation. The case was remanded for further proceedings. View "Towne v. U.S.D. 259" on Justia Law

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In a case involving an attorney father, Scott D. Pitta, and the Bridgewater-Raynham Regional School District, the United States Court of Appeals for the First Circuit affirmed the district court's dismissal of Pitta's claim that he had a First Amendment right to video record a private meeting discussing his child's Individualized Educational Program (IEP). The court found that an IEP Team Meeting does not occur in a public space, is closed to the public, and involves discussion of highly sensitive information about a student. Furthermore, the court stated that public school teachers and administrators carrying out their IEP obligations are not akin to the "public officials" in previous cases that established a First Amendment right to record. The court also noted that Pitta's claimed right to record was not linked to the public's right to receive information. Finally, the court reasoned that even if there were a First Amendment right to record such meetings, the school district's prohibition of video recording served a significant governmental interest and was narrowly tailored to promoting candid conversations and protecting sensitive information during IEP discussions. View "Pitta v. Medeiros" on Justia Law

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The Supreme Court of the State of Washington considered two questions certified by the United States Court of Appeals for the Ninth Circuit regarding a university's duty of care towards its students. The plaintiff, a student, alleged that the defendant university was negligent in failing to protect her from being raped by a fellow student, who had prior complaints of sexual misconduct, at an off-campus party. The first question asked whether under Washington law a university has a special relationship with its students that gives rise to a duty to use reasonable care to protect them from foreseeable harm caused by other students. The Court answered yes, indicating that such a relationship exists as defined by the common law principles laid out in the Restatement (Second) of Torts § 344. This duty applies when a student is on campus or participating in university-sponsored activities. The second question asked about the scope of this duty. The Court determined that the duty applies within the confines of the university campus or at university-controlled events, and is based on a student's enrollment and presence on campus. The Court did not extend this duty to off-campus situations or situations not under the university's control. Therefore, the Court concluded that the university was not liable for the plaintiff's off-campus assault. View "Barlow v. State" on Justia Law

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This is an appeal before the California Court of Appeal, Fourth Appellate District, Division One regarding an attorney fees dispute between multiple charter school entities and two school districts. The case arose from a dispute over whether certain charter schools were operating within the geographic boundaries of the Grossmont Union High School District and San Diego Unified School District in violation of the California Charter Schools Act. After a series of litigation and appeals, the charter school entities, which included Diego Plus Education Corporation, Western Educational Corporation, Lifelong Learning Administration Corporation, and Educational Advancement Corporation, were successful in defending their right to operate the schools. They subsequently sought attorney fees pursuant to California Code of Civil Procedure section 1021.5. The trial court granted the motion and ordered the school districts to pay attorney fees amounting to $582,927. The school districts appealed this decision. The appellate court conditionally reversed the order for attorney fees and remanded the case, finding that the trial court did not properly evaluate whether the financial burden of private enforcement warranted an award of attorney fees under section 1021.5. The appellate court instructed the trial court to apply the proper legal standard on remand. View "Grossmont Union High School Dist. v. Diego Plus Education Corp." on Justia Law

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The Supreme Court of Iowa ruled that the State University of Iowa, Iowa State University of Science and Technology, and the University of Northern Iowa were required to be members of the Iowa Individual Health Benefit Reinsurance Association (IIHBRA) and therefore had to pay assessments to the association. The universities had argued that they were not members of IIHBRA and that the statute requiring them to pay assessments violated the Iowa Constitution, which prohibits the state from acting as a surety for another. The court rejected these arguments, finding that the statutory scheme did not violate the constitution and that the universities, as providers of health benefit plans, were indeed members of IIHBRA. The court also ruled that IIHBRA was statutorily authorized to impose late payment fees against its members. However, the court denied IIHBRA's request for attorney fees and costs. The court affirmed in part, reversed in part, and remanded the case for further proceedings. View "Iowa Individual Health Benefit Reinsurance Ass’n v. State University of Iowa" on Justia Law

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The case involves a dispute between a family and a school district regarding the provision of special education services under the Individuals with Disabilities Education Act (IDEA). The student, Jeremy Holland, who suffers from various learning impediments, had an individualized education plan developed by the Kenton County School District. This plan included special education teachers accompanying Jeremy to some of his classes at his high school and providing him with behavioral instruction at the end of the school day. For his senior year, Jeremy's family decided to enroll him full-time at a local community college and argued that the IDEA required the school district to provide the same level of support and special education services at the college. The school district disagreed, contending that the IDEA did not impose such an obligation.The United States Court of Appeals for the Sixth Circuit held in favor of the school district. The court determined that the IDEA does not require a school district to provide special education services at the post-secondary level after a student graduates from high school, nor does it require the school district to provide the same services to high school students when they enroll in dual-credit courses offered at post-secondary institutions. The court found that Jeremy's education at the community college was post-secondary, not secondary, and therefore the IDEA did not apply. Additionally, the court found that the school district did not violate the terms of Jeremy's individualized education plan, as the plan did not indicate that Jeremy would receive services at any place other than his high school. The court affirmed the district court's granting of summary judgment in favor of the school district. View "Holland v. Kenton Cnty. Public Schs." on Justia Law

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In the case involving a high school student, Jacob Bradley, and his parents, the United States Court of Appeals for the Sixth Circuit concluded that the Individuals with Disabilities Education Act (IDEA) does not require states to provide special education services to students participating in dual-credit or dual-enrollment programs offered at postsecondary institutions.Jacob Bradley, a gifted student with several physical and cognitive conditions, was enrolled in the Craft Academy for Excellence in Science and Mathematics, a state-run dual-credit program located at Morehead State University. His parents sought reimbursement for special education support accommodations provided at Craft under IDEA. However, the district court ruled that IDEA, which offers federal funds to states to provide free appropriate public education to students with disabilities, does not apply to Craft because its dual-credit classes provide postsecondary rather than secondary school education.The Court of Appeals affirmed this decision, holding that the IDEA’s obligation to provide a "free appropriate public education" applies to "secondary," not postsecondary, education. The court also noted that, under Kentucky law, Craft is considered a postsecondary school because it delivers a college-level course of study on a college campus.The court also concluded that the state and federal agencies' interpretation of the IDEA and the state law, which excluded dual-credit courses at postsecondary institutions from IDEA’s mandate, was correct. The court emphasized that the IDEA is a spending clause legislation that operates as a contract between the federal government and states, and states need to comply only with clearly written terms in the Act, not uncertain or ambiguous ones.Additionally, the court affirmed the dismissal of the Bradleys' claims under the Americans with Disabilities Act and Section 504 of the Rehabilitation Act, as they failed to demonstrate how the Commonwealth separately violated the provisions of these distinct Acts.In conclusion, the court held that the IDEA does not obligate Kentucky school districts to provide special education services to a student participating in dual-credit classes offered at a postsecondary institution. The court also affirmed the dismissal of the Bradleys' claims under the Americans with Disabilities Act and Section 504 of the Rehabilitation Act. View "Bradley v. Jefferson Cnty. Public Schs." on Justia Law