Justia Education Law Opinion Summaries

Ayla Royan, a student in Chicago State University's (CSU) Doctor of Pharmacy program, was dismissed after failing two clinical rotations. Royan, who has clinical depression and an eating disorder, claimed her dismissal was due to her disabilities. CSU had accommodated her conditions by granting exam and assignment extensions and a yearlong medical leave. Despite these accommodations, Royan failed her first clinical rotation under Dr. Patel and her second under Dr. Kerner, leading to her dismissal.The United States District Court for the Northern District of Illinois granted summary judgment in favor of CSU, finding that Royan failed to present sufficient evidence that her dismissal was solely based on her disability. The court held that CSU had accommodated her disabilities and applied its academic standards without discrimination.The United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The appellate court held that Royan was not "otherwise qualified" for the program as she failed to meet the academic requirements, specifically passing the clinical rotations. The court also found no evidence of pretext in CSU's stated reasons for her dismissal. Additionally, the court concluded that no reasonable jury could find that CSU dismissed Royan solely because of her disabilities, as required under Section 504 of the Rehabilitation Act. The court emphasized that academic institutions have broad discretion in setting and enforcing academic standards, and CSU's actions were consistent with its policies and procedures. View "Royan v. Chicago State University" on Justia Law

Jane Doe attended high school in City View Independent School District from 2016 to 2020, where she was allegedly sexually abused by her teacher, Robert Morris. The abuse reportedly began when Doe was a fifteen-year-old freshman and continued until she graduated. Doe claims that she reported the abuse to school officials in 2018, but they threatened her with retaliation and did not report the abuse to law enforcement. In 2022, after public outcry over Morris being named coach of the year, Doe publicly stated her experiences, leading to further threats from school officials.Doe filed a lawsuit against City View ISD and several school officials in the United States District Court for the Northern District of Texas on April 4, 2023. The district court dismissed her second amended complaint with prejudice, concluding that her claims were barred by the statute of limitations. Doe appealed the dismissal of her Title IX claims, arguing that her claims were timely due to the continuing violation doctrine or equitable tolling.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court's dismissal. The court held that Doe's Title IX claims were barred by the statute of limitations, as they accrued no later than May 2020 when she graduated. The court also found that Doe's arguments for equitable tolling and the continuing violation doctrine were unavailing. Additionally, the court determined that Doe could not convert her First Amendment retaliation claim, based on a 2022 letter from a school official, into a Title IX retaliation claim. The court concluded that the district court did not abuse its discretion in denying Doe leave to amend her complaint. View "Doe v. City View Independent School District" on Justia Law

M.K., a minor, enrolled in the Pearl River County School District after being homeschooled. During his sixth-grade year, he was bullied by boys in four of his classes, who called him names like "gay." In October, M.K. exposed his genitals to one of the boys in a restroom, claiming it was either accidental or an attempt to prove he was not "gay." The District suspended M.K. and required him to attend an alternative school for six weeks, which he refused, considering it akin to a prison. M.K., through his father, sued the District and others, alleging deliberate-indifference sex-discrimination under Title IX.The United States District Court for the Southern District of Mississippi granted summary judgment in favor of the District, concluding that Title IX does not cover sexual-orientation discrimination and that the alleged behavior was not severe enough to be actionable. M.K. appealed this decision.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo. The court affirmed the district court's decision, holding that the student behavior M.K. experienced, while mean-spirited, did not meet the Supreme Court's stringent standard for "severe, pervasive, and objectively offensive" conduct required for a Title IX claim. The court emphasized that the behavior M.K. described, such as name-calling and teasing, is common in schools and does not rise to the level of actionable harassment under Title IX. The court concluded that M.K.'s experiences, though unfortunate, were not sufficient to sustain his Title IX claim against the District. View "M.K. v. Pearl River County School District" on Justia Law

Two students alleged that an Arkansas law violates their First Amendment rights by prohibiting their teachers from providing classroom materials and instruction about Critical Race Theory (CRT). The district court concluded that the law likely violated the students' right to receive information and entered a preliminary injunction. Arkansas officials appealed, arguing that the Free Speech Clause does not allow students to compel the government to provide certain classroom materials or instruction in public schools.The United States District Court for the Eastern District of Arkansas granted a preliminary injunction to the students but denied one to the teachers. The court determined that the teachers' speech was government speech, not their own, and thus any chill on their speech did not harm their rights. The court concluded that the students demonstrated that the law blocked their receipt of information previously provided before its enactment and that the Arkansas officials did not show a legitimate pedagogical reason for withholding teaching about CRT.The United States Court of Appeals for the Eighth Circuit reviewed the case and agreed with the Arkansas officials. The court held that the students conceded the classroom materials and instruction they sought to receive constituted government speech. Since the government's own speech is not restricted by the Free Speech Clause, the government is free to choose what to say and what not to say. The court concluded that the students could not show a likelihood of success on their claim and vacated the preliminary injunction. The court also declined to uphold the preliminary injunction based on the teachers' vagueness claim, as the teachers did not file a cross-appeal. The case was remanded for further proceedings. View "Walls v. Oliva" on Justia Law

Fourteen-year-old Christopher "CJ" Lucero was hit by a car and severely injured while jaywalking across a city-owned street to enter his high school campus. The accident occurred near Betty H. Fairfax High School (BFHS) in Phoenix, which is part of the Phoenix Union High School District No. 210. On the day of the accident, there were no crosswalks, school zone speed limit or warning signs, or traffic lights near the school. CJ attempted to cross the street from a vacant dirt lot opposite the school, which was commonly used by parents to drop off students, although the school did not endorse this practice.CJ, through his father, sued the District for negligence, gross negligence, and premises liability. The Superior Court of Maricopa County denied the District's motion for summary judgment, reasoning that the District was aware of the jaywalking and the associated risks but did nothing to mitigate them. The court of appeals also denied the District's petition for special action relief.The Supreme Court of Arizona reviewed the case and held that the school did not owe CJ a duty of care as he crossed the street. The court reasoned that the risk of harm did not arise within the school-student relationship because CJ was not under the school's custody and control at the time of the accident. The court emphasized that the school did not own or control the street or the dirt lot and had no authority to install safety features. The court concluded that the general rule is that a school has no duty to protect students from hazards encountered while traveling to or from school. Consequently, the court vacated the court of appeals' decision and reversed the trial court's order, instructing the trial court to enter summary judgment in favor of the District. View "Phoenix Union High School District No. 210. v. Sinclair" on Justia Law

Kenya Taylor hired Los Angeles Unified School District (LAUSD) employee Tyler Martin-Brand to babysit her six-year-old son, Dayvon, during the winter break in 2019. Tragically, Martin-Brand killed Dayvon. Taylor sued LAUSD, alleging negligent hiring and supervision of Martin-Brand. A jury found in favor of Taylor, awarding her $30 million in damages. LAUSD appealed the trial court's denial of its motion for judgment notwithstanding the verdict (JNOV) and the judgment itself.The Superior Court of Los Angeles County denied LAUSD's motions for JNOV and a new trial, asserting that LAUSD was immune from liability under Education Code section 44808. The jury had found LAUSD negligent in hiring and supervising Martin-Brand, attributing 90% of the fault to LAUSD and 10% to Taylor.The Court of Appeal of the State of California, Second Appellate District, Division Three, reviewed the case. The court concluded that LAUSD was immune from liability for Dayvon’s off-campus death under Education Code section 44808, which limits school district liability for student injuries occurring off school property unless the district has specifically undertaken responsibility for the student. The court found that Dayvon’s death did not occur during any school-sponsored activity or under LAUSD’s supervision. Consequently, the court reversed the trial court's order and judgment, directing the trial court to enter judgment in favor of LAUSD. View "Taylor v. Los Angeles Unified School Dist." on Justia Law

The Oakland Education Association (OEA) represents certain employees of the Oakland Unified School District (District). Following a dispute over school closures approved by the District, OEA members conducted a one-day strike. OEA filed an unfair practice charge with the Public Employment Relations Board (PERB), claiming the District committed unfair practices under the Educational Employment Relations Act (EERA). The District filed a competing charge, claiming OEA’s strike was an unfair practice under EERA.PERB issued separate complaints for the competing charges and bifurcated the hearings. In its first decision, PERB found the District violated EERA. In its second decision, PERB held that OEA’s strike was legal because it was provoked by the District’s unfair practices and OEA had negotiated in good faith. The District did not challenge the first decision but contested the second, arguing that OEA’s strike was illegal and violated constitutional rights.The California Court of Appeal, First Appellate District, reviewed the case. The court held that public school employees may engage in unfair practice strikes under EERA. It concluded that PERB did not clearly err in finding that such strikes are allowed and that OEA’s one-day strike did not violate the rights to education, due process, or equal protection. The court also found that neither EERA nor the due process clause prohibits pre-impasse unfair practice strikes conducted before PERB determines an unfair practice has occurred. However, the court noted that PERB erred by excluding evidence of educational harm but deemed this error harmless. The court affirmed PERB’s decision. View "Oakland Unified School Dist. v. Public Employment Relations Board" on Justia Law

The case involves a challenge to the constitutionality of the State of New Hampshire's funding for public education. The plaintiffs, which include several school districts and individuals, argue that the amount of base adequacy aid provided under RSA 198:40-a, II(a) is insufficient to cover the cost of providing a constitutionally adequate education as defined by RSA 193-E:2-a. They seek a declaratory judgment and injunctive relief to increase the funding.The Superior Court (Ruoff, J.) ruled in favor of the plaintiffs, declaring RSA 198:40-a, II(a) unconstitutional on its face. The court found that the current funding level of $4,100 per pupil was significantly below the amount necessary to provide an adequate education. The court determined a conservative minimum threshold of $7,356.01 per pupil, which it found to be the minimum amount that base adequacy aid must exceed. The court also directed the State to immediately increase base adequacy aid payments to this threshold amount pending further legislative action.The State appealed to the Supreme Court of New Hampshire, arguing that the trial court erred in its findings and that the immediate payment directive violated the separation of powers doctrine. The State contended that the trial court should have considered the total funding provided under RSA 198:40-a, including differentiated aid, rather than focusing solely on base adequacy aid.The Supreme Court of New Hampshire affirmed the trial court's rulings on the admissibility of expert testimony, the declaration that RSA 198:40-a, II(a) is facially unconstitutional, and the determination of a conservative minimum threshold for base adequacy aid. However, the court reversed the trial court's immediate payment directive, finding that it failed to properly weigh separation of powers concerns and the history of school funding litigation. The court emphasized the need for the legislative and executive branches to act expeditiously to remedy the constitutional deficiency in funding public education. View "Contoocook Valley Sch. Dist. v. State" on Justia Law

During the 2022-2023 school year, the Montgomery County Board of Education introduced LGBTQ+-inclusive storybooks into the public school curriculum for kindergarten through fifth grade. Initially, the Board allowed parents to opt their children out of this instruction, consistent with its guidelines for respecting religious diversity. However, the Board later rescinded this opt-out policy, citing disruptions and potential social stigma for students who opted out. A group of parents from diverse religious backgrounds, who believe the curriculum undermines their religious teachings on sexuality and gender, filed a lawsuit seeking to reinstate the opt-out option.The United States District Court for the District of Maryland denied the parents' request for a preliminary injunction, dismissing their reliance on Wisconsin v. Yoder and characterizing their claim as an objection to school indoctrination. The court held that the curriculum did not violate the Free Exercise Clause. A divided panel of the Fourth Circuit affirmed, finding insufficient evidence that the storybooks coerced students to change their views or act contrary to their faith.The Supreme Court of the United States reversed the Fourth Circuit's decision, holding that the parents are entitled to a preliminary injunction. The Court found that the Board's policies substantially interfere with the religious development of the children and impose a burden on religious exercise similar to that in Yoder. The Court concluded that the parents are likely to succeed on the merits of their claim, suffer irreparable harm without relief, and that an injunction is in the public interest. The Board must notify parents in advance when the books will be used and allow their children to be excused from that instruction. View "Mahmoud v. Taylor" on Justia Law

Parents and students in Louisiana challenged a state statute requiring public schools to permanently display the Ten Commandments in every classroom. The statute, House Bill 71 (H.B. 71), mandated that the Ten Commandments be displayed prominently and legibly, with an optional inclusion of other historical documents. Plaintiffs argued that this statute violated the Establishment Clause and Free Exercise Clause of the First Amendment.The United States District Court for the Middle District of Louisiana found the statute facially unconstitutional and issued a preliminary injunction to prevent its enforcement. The court ruled that the statute's primary purpose was religious, not secular, and that it coerced students into religious observance, thus violating the Establishment Clause. Louisiana officials appealed the decision, arguing that the statute had a valid secular purpose and that the plaintiffs lacked standing.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court's decision. The Fifth Circuit held that the statute was unconstitutional under the Establishment Clause, relying on the precedent set by Stone v. Graham, which struck down a similar statute in Kentucky. The court found that the statute's requirement to display the Ten Commandments in every classroom, without integrating them into an educational curriculum, served no secular educational purpose and was inherently religious.The court also determined that the plaintiffs had standing to challenge the statute, as they would be directly affected by the displays. The court rejected Louisiana's arguments regarding ripeness, standing, and sovereign immunity. The preliminary injunction was upheld, preventing the enforcement of H.B. 71 and requiring Louisiana officials to notify all public schools of the court's ruling. View "Roake v. Brumley" on Justia Law