Justia Education Law Opinion Summaries

A 13-year-old student, K.M., was found in possession of a folding knife on school grounds. The incident occurred when a campus supervisor took K.M. to the principal's office after a report of him vaping in the school bathroom. K.M. consented to a search of his backpack, which revealed two vape pens and a folding knife with two rusted blades. Later, the principal received a report that K.M. had threatened another student with the knife earlier in the day. Consequently, a police officer issued K.M. a citation for brandishing a knife and for possession of a knife on school grounds.The prosecution filed a wardship petition alleging that K.M. brought a weapon onto school property and brandished the knife. The juvenile court held a contested jurisdictional hearing, where the principal and the police officer testified. The court found K.M. guilty of the first count, designating the offense a felony, and dismissed the second count due to insufficient evidence. The court did not check the box indicating that it had found clear proof that K.M. knew his action was wrong. At a subsequent dispositional hearing, K.M.'s counsel argued that K.M. did not know he was breaking any rules when he had the knife at school because his father told him the knife was legal. The court declared K.M. a ward of the court and placed him on probation for six months.In the Court of Appeal of the State of California First Appellate District Division Three, K.M. argued that the prosecution did not prove, and the evidence does not support an implied finding, that he appreciated the wrongfulness of his conduct at the time of the incident. The court agreed with K.M., stating that there was no clear and convincing evidence that K.M. understood the wrongfulness of possessing a knife on school grounds. The court found insufficient evidence to support the juvenile court's implied finding that K.M. understood the wrongfulness of bringing a knife onto school property at the time of the incident. Therefore, the judgment was reversed and the matter was remanded for further proceedings. View "In re K.M." on Justia Law

The case involves a group of petitioners, including parents with children in nonpublic schools, who sought to compel a local school district to transport children to their private schools on days when the public schools were closed. The petitioners requested that the Washingtonville Central School District provide transportation for children attending nonpublic schools on 20 days when public schools were closed. The District denied these requests, citing its policy that it is not required to provide transportation to nonpublic schools on days when the District's schools are not in session. This policy aligns with guidance published by the State Education Department. The petitioners then initiated a hybrid CPLR article 78 proceeding and declaratory judgment action, seeking a declaration that the District must transport students to nonpublic schools on all days those schools are open and that the State Education Department's contrary guidance is invalid.The Supreme Court ruled in favor of the petitioners, concluding that the language of Education Law § 3635 (1) (a) required the District to transport nonpublic school students on all days their schools were open. The court granted the petitioners' motion for summary judgment on their request for declaratory relief, issued a permanent injunction, and denied the State Education Department's cross motion for summary judgment. However, the Appellate Division reversed this decision, finding that the language in Education Law § 3635 (1) (a) was ambiguous. After reviewing the provision's legislative history, the Appellate Division held that the law "permits, but does not require, school districts outside New York City to transport nonpublic school students to and from school on days when the public schools are closed."The Court of Appeals of New York affirmed the decision of the Appellate Division. The court held that Education Law § 3635 (1) (a) does not require school districts to provide transportation to nonpublic schools on days when public schools are closed. The court found that the phrase "sufficient transportation facilities" in the statute is ambiguous and could be interpreted in various ways. After examining the legislative history of the statute, the court concluded that the Legislature did not intend to require school districts to provide transportation to nonpublic schools on days when public schools are closed. The court also rejected the petitioners' arguments that the District's policy and the State Education Department's interpretation of Education Law § 3635 (1) (a) denied nonpublic school students equal protection of the law and that the State Education Department exceeded its statutory authority under Education Law § 3635 (1) (a). View "Matter of United Jewish Community of Blooming Grove, Inc. v Washingtonville Cent. Sch. Dist." on Justia Law

A group of twenty states sued the U.S. Department of Education and other federal entities, challenging the Department's interpretation of Title IX to prohibit discrimination based on sexual orientation and gender identity in education programs receiving federal financial assistance. The states argued that the Department's interpretation, issued without undergoing the notice-and-comment process required for legislative rules under the Administrative Procedure Act (APA), was procedurally and substantively unlawful.The U.S. District Court for the Eastern District of Tennessee granted the states a preliminary injunction, halting the enforcement of the Department's interpretation. The Department appealed, arguing that the states lacked standing, the interpretation was unreviewable, and the district court abused its discretion in issuing the injunction.The U.S. Court of Appeals for the Sixth Circuit affirmed the district court's decision. The court found that the states had standing to sue, the Department's interpretation was reviewable, and the states were likely to succeed on their claim that the interpretation was a legislative rule that should have undergone the notice-and-comment process. The court also found that the states would likely suffer irreparable harm without the injunction, the balance of equities tipped in their favor, and the public interest favored the injunction. View "Tennessee v. Department of Education" on Justia Law

Felissa Jones, the mother of an elementary school student, reported to the Mississippi Department of Child Protection Services (MDCPS) that her son had suffered abuse and neglect by staff at his school. MDCPS responded that it does not investigate reports of abuse at school. Jones then sued MDCPS, seeking declaratory and injunctive relief related to MDCPS’s policy that the agency does not investigate allegations of abuse in out-of-home settings such as schools.The Hinds County Chancery Court denied Jones's motion for a judgment in her favor on the pleadings and granted MDCPS's motion for a judgment on the pleadings, dismissing Jones's complaint. The court ruled that Jones's request for declaratory relief related to MDCPS’s former intake policy was moot because the policy was no longer in effect. It also ruled that the current intake policy does not violate the relevant statutes, but instead conforms to the statutory mandate to refer allegations of child abuse in out-of-home settings to local law enforcement.In the Supreme Court of Mississippi, Jones appealed the lower court's decisions. The court affirmed the lower court's rulings, stating that MDCPS does not have a duty to investigate reports of abuse in out-of-home settings, such as schools, because children who are mistreated by school staff do not fall under the youth court’s limited jurisdiction. The court also found that Jones's claim for declaratory relief from the amended policy had no merit because the policy tracks the relevant statutes. View "Jones v. Department of Child Protection Services" 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 proposed hospital was alleged to exceed local building height and bulk restrictions. The Parnassus Neighborhood Coalition (the Coalition), a group of property owners residing near the proposed hospital, sued to halt the construction, claiming it was a “threatened nuisance per se.” The Regents argued that as a state entity, they were immune from complying with local building and zoning regulations when engaging in a governmental activity such as constructing university buildings.The trial court disagreed with the Regents, concluding that their immunity depended on whether the proposed construction constituted a governmental or proprietary activity, a question of fact that could not be resolved on a demurrer. 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 concluded 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. The court held that the Regents are exempt from the local regulations at issue, and the demurrer should have been sustained. The court issued the writ of mandate, directing the trial court to vacate its order denying the Regents’ demurrer and to enter a new order sustaining the demurrer. View "The Regents of the University of California v. Superior Court" on Justia Law

The case revolves around Timothy Poole, a law graduate who failed the Kentucky Bar Examination five times. Poole claimed that the Kentucky Office of Bar Admissions (KYOBA) and its Executive Director, Valetta Browne, denied him necessary accommodations, leading to his repeated failures. He sought either retroactive admission to the Kentucky Bar Association or permission to retake the exam with all his accommodations.Previously, Poole had initiated a lawsuit in Fayette Circuit Court, alleging negligence on Browne's part regarding the October 2020 exam, which caused him emotional distress, loss of employment opportunities, and other damages. However, the complaint was dismissed, with the court ruling that individuals serving in a judicial capacity are immune from civil liability for their conduct and communications during their duties.The Supreme Court of Kentucky, after reviewing Poole's petition, his interactions with the KYOBA, and the accommodations offered, found that Poole was given appropriate accommodation and ample opportunities to pass the bar exam. The court noted that Poole voluntarily chose to sit for the exam twice without any accommodations, despite having inquired about them and allegedly possessing the required materials for his application. The court also pointed out that Poole never voiced any objection to the additional testing time allowance afforded to him and did not appeal that determination.The court also clarified that the rule limiting attempts to pass the bar exam to five, including attempts on the Uniform Bar Examination (UBE) taken in Kentucky or any other jurisdiction from February 2021 onwards, applies to all attempts, not just those after February 2021.The court concluded that Poole's application process and the exams were conducted in a fair and equitable manner, and any failure to approve and implement additional accommodations was due to Poole's failure to apply for them or seek appellate review of the accommodation granted. The court affirmed the KYOBA's determination that Poole had exhausted his attempts to pass the Kentucky Bar Exam and denied his requests for relief. View "Poole v. Browne" on Justia Law

The case involves the Edmond Public Schools (the Petitioner) and the State of Oklahoma, the State Board of Education, and the State Superintendent of Public Instruction (the Respondents). The Petitioner filed an application for the Supreme Court to prevent the enforcement of rules by the Respondents. These rules were to be used in enforcement proceedings against the school district before the State Board. The Petitioner argued that the State Board lacked the authority to supervise, examine, and control a local school board's discretion in supplying books for a school library that meet local community standards.The State Board of Education had publicized proposed rules for school library media programs, which included prohibitions on pornographic and sexualized content for books and other media. The Board adopted these rules, citing the Oklahoma Constitution and state statutes as their authority. However, the Oklahoma Attorney General issued an opinion stating that the proposed rules were not based on a specific grant of legislative authority, which was necessary for the Board to create these rules. The Legislature passed a resolution that did not expressly approve or disapprove the State Board's new rules. The Governor later issued a Declaration stating that the proposed rules for the State Department of Education were not subject to the joint resolution and approved these proposed rules as permanent rules for the State Department of Education.The Supreme Court of the State of Oklahoma assumed original jurisdiction, in part, over the controversy. The court held that state statutes give a local school board power and a type of statutory discretion to supply books for a school library that meet local community standards. The court also held that no statute gives the State Board of Education, State Department of Education, and Superintendent of Public Instruction the authority to supervise, examine, and control a local school board's exercise of this discretion when the local school board applies local community standards for books it supplies for a local school library. The court issued a writ of prohibition to prevent additional enforcement proceedings against the school district based on the respondents' objection to the presence of certain books in the local school library. The court denied the petitioner's request for declaratory and injunctive relief. View "INDEPENDENT SCHOOL DISTRICT NO. 12 v. STATE" on Justia Law

A minor, L.M., represented by his father and stepmother, sued the Town of Middleborough, Massachusetts, the Middleborough School Committee, and various school officials, alleging that his First Amendment rights were violated when he was prohibited from wearing a t-shirt that read "There Are Only Two Genders" at his public middle school. The United States District Court for the District of Massachusetts denied L.M.'s motion for a preliminary injunction and granted final judgment in favor of the defendants.On appeal, the United States Court of Appeals for the First Circuit affirmed the District Court's rulings. The Court of Appeals held that the school officials reasonably interpreted the message on L.M.'s t-shirt as demeaning to the gender identities of other students. The court also found that the school officials reasonably forecasted that the t-shirt's message would negatively affect the psychology of students with the demeaned gender identities and disrupt the learning environment. The court concluded that the school's actions were permissible under the "material disruption" limitation of the Supreme Court's decision in Tinker v. Des Moines Independent Community School District, which allows schools to regulate student speech that materially disrupts classwork or involves substantial disorder.The Court of Appeals also rejected L.M.'s facial challenges to the school's dress code, finding that he lacked standing to challenge one provision and that the other provision was not unconstitutionally vague or overbroad. View "L. M. v. Town of Middleborough, Massachusetts" on Justia Law

The case involves two former faculty members at the University of California, Los Angeles (UCLA), who were accused of serious misconduct. An independent law firm was hired to investigate the allegations, and the resulting report concluded that the professors had engaged in improper activities. The professors resigned their positions as part of a settlement agreement, with no findings of misconduct or admissions of liability. A former UCLA employee requested the report under the California Public Records Act (CPRA), and the professors objected, leading to a series of legal actions known as "reverse-CPRA" actions.The Superior Court of Los Angeles County denied the professors' petitions to withhold the report, concluding that the public interest in disclosure outweighed the professors' privacy interests. The court found that the allegations of misconduct were serious and substantial, and that the public had a strong interest in knowing how the university handled such complaints. The professors appealed this decision.While the appeal was pending, the Los Angeles Times made its own CPRA request for related documents, including the investigation report and the settlement agreements. The professors sought a preliminary injunction to prevent the release of these documents, but the trial court denied their request. The court found that the professors were unlikely to succeed on the merits of their claim, as the analysis for the disclosure of these documents was the same as for the investigation report. The professors appealed this decision as well.The Court of Appeal of the State of California, Second Appellate District, affirmed the trial court's decision. The appellate court agreed with the trial court's analysis and found no reason to delay a decision on a matter concerning public transparency. The court concluded that the professors had not established a likelihood of success on the merits of their claim and were therefore not entitled to injunctive relief. View "Doe v. The Regents of the University of California" on Justia Law

The case involves a group of plaintiffs, including the Health Freedom Defense Fund, Inc. and California Educators for Medical Freedom, who challenged the COVID-19 vaccination policy of the Los Angeles Unified School District (LAUSD). The policy, which was in effect for over two years, required employees to get the COVID-19 vaccination or lose their jobs. The plaintiffs argued that the policy interfered with their fundamental right to refuse medical treatment.The case was initially dismissed by the United States District Court for the Central District of California, which applied a rational basis review under Jacobson v. Massachusetts, concluding that the policy served a legitimate government purpose. The court held that even if the vaccine did not prevent transmission or contraction of COVID-19, it furthered the purpose of protecting LAUSD students and employees from COVID-19.The plaintiffs appealed to the United States Court of Appeals for the Ninth Circuit. During the appeal, LAUSD rescinded its vaccination policy. LAUSD then asked the court to dismiss the appeal, arguing that the case was now moot. The plaintiffs objected, arguing that LAUSD withdrew the policy because they feared an adverse ruling.The Ninth Circuit held that the case was not moot, applying the voluntary cessation exception to mootness. The court found that LAUSD's pattern of withdrawing and then reinstating its vaccination policies, particularly in response to litigation risk, was enough to keep the case alive.On the merits, the Ninth Circuit held that the district court misapplied the Supreme Court’s decision in Jacobson v. Massachusetts. The court found that Jacobson did not apply because the plaintiffs had plausibly alleged that the COVID-19 vaccine does not effectively prevent the spread of COVID-19. The court vacated the district court’s order and remanded the case for further proceedings under the correct legal standard. View "HEALTH FREEDOM DEFENSE FUND, INC. V. ALBERTO CARVALHO" on Justia Law