Justia Education Law Opinion Summaries

This case involves a child with significant developmental disabilities, B.D., who attended Georgetown Public Schools. B.D.'s parents, Rachel and Michael Doucette, sued the school district and various personnel, alleging that the school's failure to properly implement B.D.'s individualized education program (IEP) and health and safety plan led to a series of five severe seizures that B.D. experienced at school in 2012. The Doucettes claimed that the school district violated B.D.'s constitutional rights under 42 U.S.C. § 1983 and Massachusetts tort law.The district court granted the school district's motion for summary judgment, finding that a reasonable jury could not conclude that the school district engaged in the conscience-shocking conduct necessary to sustain the constitutional claim, nor that the school district was liable under the state-law claims.The United States Court of Appeals for the First Circuit affirmed the district court's decision. The court found that the school district's conduct, while flawed, did not rise to the level of "conscience-shocking" behavior necessary to establish a violation of B.D.'s substantive due process rights. The court also found that the Doucettes failed to establish that the school district's conduct was the but-for cause of B.D.'s seizures, a necessary element of their state-law claims. View "Doucette v. Jacobs" on Justia Law

The Regents of the University of California (Regents) approved the construction of a new hospital at the University of California San Francisco (UCSF) Parnassus Heights campus. The Parnassus Neighborhood Coalition (the Coalition), a group of local property owners, sued to halt the construction, arguing it would violate local building height and bulk restrictions. The Regents countered that as a state entity, they were immune from local building and zoning regulations when engaging in governmental activities, such as constructing university buildings. The trial court disagreed, ruling that the question of whether the construction constituted a governmental or proprietary activity could not be resolved at this stage.The trial court concluded that the Regents' immunity depended on whether the proposed construction was a governmental or proprietary activity, a question of fact that could not be resolved on a demurrer. The court further concluded that the exemption only applies when a project is solely for educational purposes. The Regents petitioned for a writ of mandate to vacate the trial court’s order.The Court of Appeal of the State of California First Appellate District Division Three reviewed the case. The court held that the proposed hospital would facilitate the provision of clinical services, thereby advancing UCSF’s academic mission and the Regents’ educational purpose, which is a governmental activity. Therefore, the project falls within the Regents’ broad public purpose, and the Regents are exempt from the local regulations at issue. The court concluded that the demurrer should have been sustained and issued the writ of mandate. The court also ordered modifications to the published opinion filed on June 13, 2024, but there was no change in the judgment. View "Regents of the University of Calif. v. Super. Ct." on Justia Law

The case involves Susan George, a teacher who had worked for the Susanville Elementary School District for several years before resigning to teach at another school district. She later returned to the District. Upon her return, the District did not credit her for the years of experience she gained at the other school district following her resignation. George filed a petition for writ of mandate arguing the District violated the uniformity requirement of Education Code section 45028 and the restoration requirement of section 44931 when placing her on the salary schedule without accounting for the years of experience she gained while outside the District after her resignation.The trial court found that the District complied with the Education Code. It ruled that the collective bargaining agreement prevented George from acquiring credit for the two years she worked for another school district. The trial court further found the uniformity requirement did not afford George relief and the District complied with the restoration requirement by restoring George to her prior position. Consequently, the trial court denied George’s petition for writ of mandate.The Court of Appeal of the State of California Third Appellate District reversed the trial court's decision. The appellate court held that the District violated the uniformity requirement by failing to place George at step 15 of the District’s salary schedule. The court disagreed with the District's argument that the uniformity requirement is inapplicable to George’s placement on the salary schedule because the restoration requirement controls the placement of teachers rehired within 39 months. The court found that the District must credit George with up to 12 years of out-of-district experience. The court remanded the case with directions to issue a writ compelling the District to place George on its salary schedule in compliance with Education Code section 45028 as construed herein, with appropriate back pay and benefits. The District was ordered to pay costs on appeal. View "George v. Susanville Elementary School District" on Justia Law

The case involves two groups of plaintiffs, referred to as the Schneider plaintiffs and the Page plaintiffs, who challenged the title and one-sentence "yes/no" statements prepared by the Attorney General and the Secretary of the Commonwealth (Secretary) for Initiative Petition 23-36. This petition proposed to replace the Massachusetts Comprehensive Assessment System (MCAS) tests, currently used as a measure of student competency for high school graduation, with a system where students must satisfactorily complete coursework certified by their district as showing mastery of state academic standards.The plaintiffs filed their complaints in the Supreme Judicial Court for Suffolk County, arguing that the title and one-sentence statements were misleading and inconsistent with the requirements of G. L. c. 54, § 53. The Page plaintiffs contended that the statements only mentioned the elimination of MCAS without stating that it would be replaced with something else. The Schneider plaintiffs argued that the statements did not disclose that the petition would prohibit the use of any uniform statewide assessment as a graduation requirement.The Supreme Judicial Court of Massachusetts found that the title and one-sentence statements accurately characterized the petition's proposal to eliminate MCAS tests as a graduation requirement. The court noted that while the petition also proposed a new assessment scheme and prohibited any future statewide assessment from being used as a graduation requirement, these were not distinct regulatory features of the petition. The court concluded that the title and one-sentence statements did not need to describe every feature of the petition. The court also rejected the additional arguments forwarded by the Page plaintiffs. The court remanded the matter to the county court for entry of a judgment declaring that the Attorney General and Secretary's title and one-sentence statements were in compliance with the requirements of G. L. c. 54, § 53. View "Schneider v. Attorney General" on Justia Law

The case involves Shannon Blick, a former principal of an elementary school in the Ann Arbor Public School District. In 2019, Blick was placed on paid leave while the school district investigated her role in a custodian's over-billing scheme. The leave lasted two years, and the school district eventually terminated Blick's contract. Blick filed a lawsuit while still on leave, alleging that various officials violated her freedoms of speech and association under the First Amendment. She also brought race-discrimination, due-process, and conspiracy claims against these officials. The district court rejected Blick's First Amendment claims at the summary-judgment stage and dismissed the other claims on the pleadings.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court's decision. The court found that Blick failed to show a reversible error. She argued that the school district violated the First Amendment by imposing a prior restraint that barred her from speaking during her leave and by taking harmful actions against her in retaliation for her speech. However, the court found that Blick's lawyers did not provide sufficient information about what she wanted to say or what she did say. The court also found that Blick's opening brief did not preserve her challenges to much of the district court's motion-to-dismiss decision. As a result, the court affirmed the district court's decision. View "Blick v. Ann Arbor Public School District" on Justia Law

The case revolves around a disabled child, Abigail P., who filed a due process complaint against the Old Forge School District under the Individuals with Disabilities Education Act (IDEA), Section 504 of the Rehabilitation Act, and Pennsylvania state law. Abigail, who suffers from severe disabilities, claimed that the school district denied her a free appropriate public education (FAPE) when it moved to remote instruction during the COVID-19 pandemic.The case was first heard by a hearing officer appointed by the Pennsylvania Department of Education, who disagreed with Abigail's claim. The United States District Court for the Middle District of Pennsylvania also disagreed and affirmed the hearing officer's decision.The case was then brought before the United States Court of Appeals for the Third Circuit. The court was tasked with deciding whether Abigail received a FAPE during the COVID-19 pandemic. The court affirmed the lower courts' decisions, stating that the school district did not deny Abigail a FAPE. The court concluded that the school district provided an educational program reasonably calculated to confer meaningful educational benefits in light of Abigail's individual circumstances, even during the period of remote instruction. The court also clarified that its opinion does not give school districts carte blanche to reduce a disabled student’s school day for any reason or no reason at all. View "Abigail P. v. Old Forge School District" on Justia Law

The case involves a group of plaintiffs who filed a civil rights action under 42 U.S.C. § 1983 against Independent School District 194 and its superintendent. The plaintiffs alleged that the defendants violated their First Amendment rights by discriminating against their political viewpoints. The controversy arose when the school district allowed the display of Black Lives Matter (BLM) posters in classrooms but rejected requests to display "All Lives Matter" and "Blue Lives Matter" posters and shirts. The district court dismissed the plaintiffs' First Amendment claims and denied the unnamed plaintiffs' motion to proceed under pseudonyms.The district court ruled that the unnamed plaintiffs had not sufficiently established a threat of a hostile public reaction to their lawsuit that would warrant anonymity. It also concluded that the BLM posters constituted government speech that is not subject to scrutiny under the First Amendment’s Free Speech Clause. The plaintiffs appealed both orders.The United States Court of Appeals for the Eighth Circuit affirmed in part, reversed in part, and remanded the case for further proceedings. The court affirmed the district court's denial of the motion to proceed under pseudonyms, finding that the unnamed plaintiffs did not provide sufficient evidence of a compelling fear of retaliation. However, the court reversed the district court's dismissal of the complaint, concluding that the plaintiffs had pleaded sufficient facts to allow a court to draw the plausible inference that the BLM posters are expressions of private persons, not government speech. The court also found that the district had engaged in viewpoint discrimination by allowing the display of BLM posters but rejecting "All Lives Matter" and "Blue Lives Matter" posters and shirts. View "Cajune v. Independent School District 194" on Justia Law

The Attorney General for the State of Oklahoma, on behalf of the state, sought a writ of mandamus and declaratory relief against the Oklahoma Statewide Virtual Charter School Board and its members. The state argued that the board's contract with St. Isidore of Seville Catholic Virtual School, a religious charter school, violated state and federal law and was unconstitutional. The state contended that the contract violated the Oklahoma Constitution, which mandates that all charter schools be nonsectarian in their programs, admission policies, and other operations. The state also argued that the contract violated the federal Establishment Clause, which prohibits the state from using public money for the establishment of a religious institution.The Charter School Board had approved St. Isidore's application to become an Oklahoma virtual charter school and later approved its contract for sponsorship. The contract recognized certain rights, exemptions, or entitlements applicable to St. Isidore as a religious organization under state and federal law. The contract also stated that St. Isidore had the right to freely exercise its religious beliefs and practices consistent with its religious protections.The Supreme Court of the State of Oklahoma assumed original jurisdiction over the case. The court found that the contract violated the Oklahoma Constitution, the Oklahoma Charter Schools Act, and the federal Establishment Clause. The court held that St. Isidore, as a public charter school, was a governmental entity and a state actor. The court also held that the contract violated the Establishment Clause because it allowed for the use of state funds for the benefit and support of the Catholic church and required students to participate in religious curriculum and activities. The court granted the extraordinary and declaratory relief sought by the state and directed the Charter School Board to rescind its contract with St. Isidore. View "DRUMMOND v. OKLAHOMA STATEWIDE VIRTUAL CHARTER SCHOOL BOARD" on Justia Law

The case involves Benjamin Stanley, who was employed by Western Michigan University (WMU) for about a month before his employment was terminated. Stanley, who has severe ADHD, claimed that WMU and certain supervisors discriminated and retaliated against him in violation of the Americans with Disabilities Act (ADA). He also brought a claim under Michigan’s Persons with Disabilities Civil Rights Act (PWDCRA), as well as a claim for intentional infliction of emotional distress. The district court dismissed Stanley’s federal claims for lack of subject-matter jurisdiction based on Eleventh Amendment immunity and dismissed his state-law claims for failure to comply with the Michigan Court of Claims Act’s notification statute.The district court's dismissal of Stanley's claims was appealed to the United States Court of Appeals for the Sixth Circuit. The appellate court affirmed the district court’s dismissal of Stanley’s federal claims and the denial of Stanley’s motion for leave to amend his complaint. However, the court vacated the judgment in part and remanded to the district court to dismiss Stanley’s federal and state-law claims without prejudice. The court found that the district court lacked subject-matter jurisdiction to adjudicate Stanley’s ADA claims because the defendants were entitled to Eleventh Amendment immunity, and Stanley lacked standing to request injunctive relief from the individual defendants. The court also found that the district court lacked jurisdiction to decide Stanley’s state-law claims because it lacked subject matter jurisdiction over any federal issues. View "Stanley v. Western Michigan University" on Justia Law

The case involves Jennifer Sugg, a student who was dismissed from her Certified Registered Nurse Anesthesiology (CRNA) program at Midwestern University after failing several required courses. Sugg sued Midwestern University and EmergencHealth (EH), alleging breach of contract and fraud. The United States District Court for the Southern District of Texas granted summary judgment in favor of the defendants on all causes of action, and Sugg appealed.Sugg enrolled in Midwestern's CRNA program in 2016. She failed a course in her first semester and was placed on academic leave. After retaking the course and receiving a passing grade, she was placed on academic probation due to her low GPA. Sugg later failed her first clinical rotation course and was dismissed from the program. She appealed the decision, and the dismissal was overturned so she could retake the course. However, after failing another course, she was dismissed again. Sugg appealed this decision as well, but it was upheld by the university's Promotion and Graduation Committee and the Dean of the College of Health Sciences.The United States Court of Appeals for the Fifth Circuit affirmed the lower court's decision. The court found that Midwestern University did not breach the contract as it followed its guidelines and dismissed Sugg based on her academic performance. The court also found that Sugg failed to show that the university's decision was a substantial departure from accepted academic norms. Regarding the claims against EH, the court found that EH did not interfere with Sugg's contract with Midwestern University and did not make any false or misleading statements. Therefore, the court affirmed the summary judgment in favor of the defendants. View "Sugg v. Midwestern University" on Justia Law