Justia Education Law Opinion Summaries

Jane Doe, a student in a dual enrollment program with the University of Kentucky, reported being raped by John Doe (JD) in her dorm room. The University held four student conduct hearings. The first three hearings resulted in JD's expulsion or suspension, but each decision was overturned by the University’s appeals board due to procedural errors. After the third reversal, Doe filed a Title IX lawsuit against the University. In the fourth hearing, the panel ruled against her, and Doe claimed the University mishandled this hearing in retaliation for her lawsuit.The United States District Court for the Eastern District of Kentucky granted summary judgment in favor of the University, concluding that Doe could not establish a prima facie case of retaliation under Title IX. The court found that Doe was no longer a student at the time of the fourth hearing and thus could not claim adverse school-related actions. It also limited its analysis to the allegations in Doe’s complaint, excluding additional evidence presented in opposition to summary judgment.The United States Court of Appeals for the Sixth Circuit reversed and remanded the case. The court held that Doe could suffer adverse school-related actions even if she was not a current student and that the University’s disciplinary proceedings are educational programs under Title IX. The court found that the University’s delays, procedural errors, and failure to adequately prosecute JD could dissuade a reasonable person from pursuing a Title IX claim. The court also held that Doe presented sufficient evidence to establish a causal connection between her lawsuit and the adverse actions. The case was remanded for further proceedings consistent with this opinion. View "Doe v. University of Kentucky" on Justia Law

A.D., a student with disabilities, attended Sparta High School and was designated as having a disability under the IDEA. In early 2019, Sparta informed A.D. that he was in danger of failing several classes, leading to a period of home instruction. A.D.'s parents withdrew him from school, and he subsequently passed the GED, receiving a State-issued high school diploma in April 2019. Despite re-enrolling at Sparta High School and receiving home instruction again, A.D. faced academic challenges and was withdrawn from school multiple times. In May 2021, Sparta denied A.D.'s re-enrollment request, citing his receipt of the State-issued diploma.M.N., A.D.'s mother, requested a due process hearing with the New Jersey Department of Education (DOE). The Administrative Law Judge (ALJ) ruled that A.D.'s State-issued diploma was a "regular high school diploma" under federal regulations, thus ending his entitlement to a FAPE. The Commissioner of the DOE upheld the ALJ's decision, and the Appellate Division affirmed, agreeing that the State-issued diploma met state standards and ended A.D.'s entitlement to a FAPE.The Supreme Court of New Jersey reviewed the case and held that a New Jersey State-issued diploma based on passing the GED is not a "regular high school diploma" under 34 C.F.R. § 300.102(a)(3)(iv). Therefore, a student who receives such a diploma remains entitled to a free appropriate public education under the IDEA. The Court reversed the Appellate Division's decision, concluding that A.D. remains entitled to receive a FAPE, and Sparta must provide it. View "Board of Education of the Township of Sparta v. M.N." on Justia Law

The case involves several special education students who alleged that their teacher physically and emotionally abused them. The students, who have various disabilities affecting their communication abilities, were assigned to the same classroom at Elm Street Elementary School in Coweta County, Georgia. The teacher, Catherine Sprague, was hired by the principal, Dr. Christi Hildebrand, despite lacking special education certification. Throughout the fall of 2019, the students exhibited signs of distress, and their parents noticed behavioral changes and physical signs of mistreatment. A paraprofessional, Nicole Marshall, reported multiple instances of abuse by Sprague to Hildebrand, who delayed reporting these allegations to law enforcement and the students' parents.The United States District Court for the Northern District of Georgia dismissed the students' complaint. The court ruled that emotional distress damages are not recoverable under Title II of the Americans with Disabilities Act (ADA) following the Supreme Court's decision in Cummings v. Premier Rehab Keller, P.L.L.C. The court also found that the students failed to state a constitutional violation against Hildebrand and the school district, and that Hildebrand was entitled to qualified immunity. The court declined to exercise supplemental jurisdiction over the state law negligence claim.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court affirmed that emotional distress damages are not recoverable under Title II of the ADA, as Title II incorporates the remedies of the Rehabilitation Act, which the Supreme Court in Cummings ruled does not allow for emotional distress damages. However, the appellate court found that the district court erred by not considering whether the students might be entitled to other forms of relief under Title II, such as damages for physical harm or nominal damages. The appellate court also affirmed the dismissal of the section 1983 claims, ruling that the alleged abuse did not meet the "shock-the-conscience" standard required for a substantive due process violation. The case was remanded for further proceedings to consider other potential relief under Title II. View "A.W. v. Coweta County School District" on Justia Law

Four parents of students in the Independence School District challenged the District’s policy of removing library materials upon receiving a complaint, pending a formal review. They argued that this policy violated their children's First Amendment rights and Fourteenth Amendment due process rights. The District moved to dismiss the case.The United States District Court for the Western District of Missouri granted the District’s motion to dismiss. The court concluded that the parents failed to demonstrate an injury-in-fact necessary for standing, as their claims were based on hypothetical future challenges rather than any current or imminent harm. The court noted that the plaintiffs did not allege any ongoing or threatened challenges to library materials, nor did they challenge the removal of any specific book.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s decision. The appellate court agreed that the plaintiffs lacked standing because they did not show a concrete and particularized injury that was actual or imminent. The court emphasized that the plaintiffs’ claims were speculative, as they were based on the possibility of future book challenges and removals. The court also noted that the plaintiffs did not allege any self-censorship or chilling effect on their children’s speech due to the policy. Therefore, the court held that the plaintiffs failed to meet the requirements for pre-enforcement review and affirmed the dismissal of the case. View "L.H. v. Independence School District" on Justia Law

The City of Helena appealed a decision by the Shelby Circuit Court that allowed the Pelham Board of Education (PBE) to acquire, develop, and use a piece of real property within Helena's corporate limits for an athletic field and parking lot to serve Pelham High School students. The property, purchased by the PBE in 2021, is adjacent to Pelham High School but located within Helena. Helena argued that the PBE lacked the authority to construct and operate school facilities outside Pelham's corporate limits and that the project violated Helena's zoning ordinance.The Shelby Circuit Court ruled in favor of the PBE, stating that city zoning ordinances do not apply to governmental functions performed by a government body. The court found that the PBE's construction of the athletic field was a governmental function related to public education, which is exempt from local zoning regulations. Helena appealed, arguing that the PBE's actions were not authorized under Alabama Code § 16-11-9 and that the project did not comply with Helena's zoning ordinance.The Supreme Court of Alabama affirmed the circuit court's decision. The court held that § 16-11-9 does not restrict a city board of education's powers to the geographic boundaries of the city it serves. The court also concluded that the PBE's construction and operation of the athletic field constituted a governmental function related to public education, which is exempt from municipal zoning ordinances. Therefore, Helena's zoning ordinance could not be enforced against the PBE's project. The court affirmed the circuit court's order, allowing the PBE to proceed with the development and use of the property. View "City of Helena v. Pelham Board of Education" on Justia Law

Shawn Jones, a teacher employed under a limited contract by the Kent City School District Board of Education, faced nonrenewal of his contract. The board was required by Ohio law (R.C. 3319.111(E)) to conduct three formal observations of Jones teaching before deciding on nonrenewal. The first observation occurred in January 2020, and the second in May 2020, both involving Jones actively teaching. However, the third observation, conducted in May 2020, only involved the evaluator attending a remote session with Jones’s students, which Jones could not attend due to a medical condition.The Portage County Court of Common Pleas initially affirmed the board’s decision not to renew Jones’s contract. Jones appealed, arguing that the board did not comply with the statutory requirement of observing him teaching three times. The Eleventh District Court of Appeals reversed the lower court’s decision, finding that the board failed to meet the statutory requirements because the third observation did not involve observing Jones teaching.The Supreme Court of Ohio reviewed the case and affirmed the Eleventh District Court of Appeals’ judgment. The court held that the board did not comply with R.C. 3319.111(E) because the third observation did not involve observing Jones teaching. The court ordered the board to reinstate Jones and remanded the case to the Portage County Court of Common Pleas for the calculation of Jones’s back pay. The court emphasized that the statutory requirement of observing the teacher teaching is mandatory and cannot be substituted by observing students without the teacher’s presence. View "Jones v. Kent City School Dist. Bd. of Edn." on Justia Law

The plaintiffs, current or retired public school superintendents and administrators, filed a lawsuit against the Office of Retirement Services (ORS) alleging that ORS violated the Public School Employees Retirement Act by using salary schedules it created to determine their retirement allowances. The plaintiffs, who worked under personal employment contracts rather than collective bargaining agreements (CBAs), argued that the Retirement Act did not authorize ORS to create these normal salary increase (NSI) schedules and apply them to their pension calculations.The Court of Claims granted summary disposition in favor of the defendants on all claims except for a violation of the Administrative Procedures Act (APA). After cross-motions for summary disposition, the Court of Claims also ruled in favor of the defendants on the APA claim. The plaintiffs appealed, and the Court of Appeals reversed, holding that ORS lacked statutory authority to create NSI schedules and that MCL 38.1303a(3)(f) did not apply to employees under personal employment contracts. The Michigan Supreme Court affirmed the lack of authority for ORS to create NSI schedules but reversed the Court of Appeals' interpretation of MCL 38.1303a(3)(f), remanding the case for further proceedings.The Michigan Supreme Court held that the term "normal salary schedule" is a written document established by statute or approved by a reporting unit’s governing body, indicating the time and sequence of compensation, and applying to a generally applicable job classification rather than a specific employee. The Court clarified that this term is not limited to CBAs and applies to public school employees regardless of their employment contract type. The case was remanded to the Court of Claims to determine whether the plaintiffs were subject to a normal salary schedule as defined. View "Batista v. Office Of Retirement Services" on Justia Law

A group of parents, represented by Parents Defending Education (PDE), challenged the Olentangy Local School District's policies that prohibit harassment based on gender identity, including the intentional use of non-preferred pronouns. PDE argued that these policies violated the First Amendment's Free Speech Clause. The policies in question include the Anti-Harassment Policy, the Personal Communication Devices (PCD) Policy, and the Code of Conduct, all of which aim to prevent harassment and bullying within the school district.The United States District Court for the Southern District of Ohio denied PDE's motion for a preliminary injunction to prevent the enforcement of these policies. The court found that PDE had not demonstrated a likelihood of success on the merits of their First Amendment claims. Specifically, the court held that the policies did not unconstitutionally compel speech, did not constitute viewpoint discrimination, and were not overbroad. The court also determined that PDE had not shown that the policies would likely cause irreparable harm.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision. The appellate court agreed that PDE had not met the burden of showing a clear likelihood of success on the merits. The court found that the school district's policies were consistent with the standard for regulating student speech established in Tinker v. Des Moines Independent Community School District, which allows schools to regulate speech that could substantially disrupt school activities or invade the rights of others. The court also held that the policies did not unconstitutionally compel speech, as students could use first names instead of pronouns, and that the policies were not overbroad. The court concluded that PDE had not demonstrated that the balance of equities or the public interest favored granting a preliminary injunction. View "Parents Defending Education v. Olentangy Local School District" on Justia Law

J.M., an 11-year-old student, filed a class action lawsuit through his guardian ad litem against Illuminate Education, Inc., an education consulting business. J.M. alleged that Illuminate obtained his personal and medical information from his school to assist in evaluating his educational progress. Illuminate promised to keep this information confidential but negligently maintained its database, leading to a data breach where a hacker accessed the information. Illuminate delayed notifying J.M. and other victims about the breach for five months, during which J.M. began receiving unsolicited mail and phone calls.The trial court sustained Illuminate's demurrer, concluding that Illuminate did not fall within the scope of the Confidentiality of Medical Information Act (CMIA) or the Customer Records Act (CRA) and that J.M. failed to state a cause of action. J.M. filed a proposed second amended complaint with additional facts and a motion for reconsideration. The trial court reviewed the amended pleadings but maintained that J.M. had not stated a cause of action and could not amend to do so, thus sustaining the demurrer without leave to amend and entering judgment for Illuminate.The California Court of Appeal, Second Appellate District, reviewed the case and concluded that Illuminate falls within the scope of the CMIA and CRA. The court found that J.M. stated sufficient facts to support causes of action under both statutes. The court held that the trial court abused its discretion by sustaining the demurrer without leave to amend. The judgment of dismissal was reversed, and the case was remanded to the trial court, allowing J.M. to file an amended complaint with additional facts. View "J.M. v. Illuminate Education, Inc." on Justia Law

The case involves a dispute between Pima County and the State of Arizona regarding the reimbursement of desegregation expenses. Following amendments to Arizona Revised Statutes (A.R.S.) § 15-910 in 2018, the State ceased reimbursing Pima County for desegregation expenses that exceeded the Arizona Constitution’s 1% limit on residential property taxes. The key issue was whether these expenses, previously classified as "primary property taxes," should still be reimbursed by the State under the new statutory framework.The Arizona Tax Court initially ruled in favor of Pima County, holding that the State must reimburse the desegregation expenses as additional state aid for education. The court found the State's interpretation of the amended statute unworkable and inconsistent with the constitutional mandate. The State appealed this decision.The Arizona Court of Appeals reversed the Tax Court's decision, concluding that the legislature had the authority to amend the statutory scheme and reclassify the desegregation expenses as secondary property taxes. The court reasoned that the new classification did not violate the Arizona Constitution, as the legislature's amendments were within its purview to alter statutory tax classifications.The Arizona Supreme Court reviewed the case and affirmed the Court of Appeals' decision. The Court held that the 2018 amendments to A.R.S. § 15-910 effectively reclassified desegregation expenses as secondary property taxes, which are not subject to reimbursement under A.R.S. § 15-972(E). The Court concluded that the State is not required to reimburse Pima County for these expenses, as the new classification aligns with the legislative intent and does not violate the constitutional 1% limit on residential property taxes. The case was remanded to the Tax Court for the entry of judgment in favor of the State. View "PIMA COUNTY v. STATE OF ARIZONA" on Justia Law