Justia Education Law Opinion Summaries

The Supreme Court denied the writ of mandamus sought by Andrew Frank to compel Ohio State University (OSU) to provide documents that Frank's attorney had requested in a public-records request, holding that OSU responded promptly and fully to the attorney's request and that Frank was not entitled to a writ of mandamus.The records in question were student records containing "personally identifiable information." The parties disputed whether the Family Education Rights and Privacy Act, 20 U.S.C. 1232g, applied to the requested records. The Supreme Court denied the writ of mandamus without reaching the issue, holding that OSU responded promptly and fully to the attorney's request and, therefore, Frank was not entitled to a writ of mandamus. View "State ex rel. Frank v. Ohio State University" on Justia Law

Plaintiff School districts located in Midwest City/Del City, Enid, Ponca City, and Oklahoma City filed an action alleging they received insufficient State Aid payments for the years 1992-2014. The named defendants were: the Superintendent of Oklahoma State Department of Education (OSDE); the Oklahoma Tax Commission; and (3) the Oklahoma State Treasurer. Plaintiffs sought writs of mandamus to compel defendants to demand and recoup excessive State Aid payments made to other school districts, and then pay the correct apportionments to plaintiffs. Plaintiffs sought summary judgment, and intervenors, school districts in Tulsa County, sought summary judgment against plaintiffs. The district court granted intervenors' motion for summary judgment and concluded the defendants did not have a duty to seek repayment of excessive State Aid payments made to other schools until an audit was performed by auditors approved by the State Auditor and Inspector. Plaintiffs appealed and after review, the Oklahoma Supreme Court held the audit used by the State Board of Education when demanding repayment must be performed by auditors approved by the State Auditor and Inspector. A school district possesses a legal right to a proper apportionment of State Aid regardless of excessive payments made to other districts. A school district lacked a cognizable legal interest and standing in a claim to compel the State Board of Education to fund a lapsed appropriation. Plaintiffs' filings raised the issue of their standing to judicially compel legislative appropriations; standing would have to be adjudicated on remand. View "Independent School District # 52 v. Hofmeister" on Justia Law

Petitioner Sherri Ybarra, the Idaho Superintendent of Public Instruction, petitioned the Idaho Supreme Court for a declaratory judgment, writ of mandamus, or writ of prohibition to remedy various alleged constitutional violations by the Idaho Legislature and the Idaho State Board of Education related to the funding and supervision of eighteen employees currently working in the Idaho Department of Education. During the 2020 legislative session, the Idaho Legislature passed two appropriation bills - Senate Bills 1409 and 1410 - which transferred supervision of eighteen full-time job positions within the Department’s Technology Group to the Board along with approximately $2.7 million in funding for those positions. The Superintendent argues that “by splitting eighteen employees away from three other workers and eliminating all funding for the office space, rent, and the maintenance and upgrading of the Department’s computers, this line item appropriation decentralizes and damages operations.” She also claimed these bills were the Legislature’s attempt to “strip the Superintendent of her authority through the budget process,” in retaliation for her failure to support a 2019 revised school funding formula. To effectuate such relief, the Superintendent invoked the Supreme Court's original jurisdiction, seeking a declaratory judgment that the Appropriation Bills were unconstitutional. The Superintendent sought a writ of mandamus and/or prohibition that would allow SB 1409's funding appropriation to the Board remain intact, but would restore the Superintendent's full management authority over the Technology Group. The Supreme Court found the Appropriations Bills constitutional, thereby declining to address requests for writs of mandamus and/or prohibition. View "Ybarra v. Legislature of the State of Idaho" on Justia Law

At issue in this case was the correct interpretation of Ariz. Rev. Stat. 23-750(E)(5), which provides that income earned by any individual who performed certain services while employed by an entity that provides such services to or on behalf of an "educational institution" cannot be used to qualify for unemployment during breaks between academic terms if that person is guaranteed reemployment.Plaintiffs were employees of Chicanos For La Cause (CPLC), a nonprofit corporation that administered federally funded Early Head Start and Migrant Seasonal Head Start programs and provided services to help school districts comply with their obligations under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq. When the summer break began, Plaintiffs applied for unemployment insurance benefits from Arizona Department of Economic Security (ADES), which granted benefits. The ADES Appeals Board reversed. The Supreme Court remanded the case to ADES to award unemployment benefits to two plaintiffs and for further proceedings to resolve the claims of the remaining plaintiffs, holding that section 23-750(E)(5) applies to plaintiffs only if they performed services for CPLC that CPLC supplied to the school districts. View "Rosas v. Arizona Department of Economic Security" on Justia Law

The Pennsylvania Supreme Court granted discretionary review to consider whether the Commonwealth Court erred in determining a school bus surveillance video sought in a request for public records pursuant to the Right-to-Know Law (RTKL) was not exempt from disclosure under the Family Educational Rights and Privacy Act (FERPA), 20 U.S.C. 1232g. Rudy Miller, on behalf of The Express Times (collectively, Requester), submitted a RTKL request to the District. Therein, Requester sought information in connection with an incident involving an elementary school teacher who, according to Requester, had roughly physically disciplined a child on a school bus outside of the school. Although its rationale departed from the analysis of the Commonwealth Court, the Supreme Court affirmed the lower court’s order, with instructions to redact students’ images from the video prior to disclosure. View "Easton Area Sch. Dist. v. Miller" on Justia Law

The United States District Court for the Western District of Washington certified two questions to the Washington Supreme Court in connection with the meaning of the Washington Law Against Discrimination (WLAD), chapter 49.60 RCW. The federal trial court asked: (1) whether a school district was subject to strict liability for discrimination by its employees in violation of the WLAD; and (2) if yes, then did "discrimination," for the purposes of this cause of action, encompass intentional sexual misconduct, including physical abuse and assault? Gary Shafer was hired by the Olympia School District in 2005 as a school bus driver. It was undisputed that Shafer, during his employment, abused passengers on school buses, including P.H. and S.A., the minor plaintiffs in this case. Plaintiffs sued the school district in federal court, naming multiple defendants, and claiming both state and federal causes of action. Defendants moved for summary judgment, which was granted in part and denied in part. In response to the Washington Supreme Court's decision in Floeting v. Group Health Cooperative, 434 P.3d 39 (2019), plaintiffs successfully moved to amend their complaint to include a claim under the WLAD. The amended complaint alleges that the minor plaintiffs’ treatment constituted sex discrimination in a place of public accommodation. The Supreme Court answered "yes" to both certified questions: a school district may be subject to strict liability for discrimination in places of public accommodation by its employees in violation of the WLAD; and under the WLAD, discrimination can encompass intentional sexual misconduct, including physical abuse and assault. View "W.H. v. Olympia School Dist." on Justia Law

Plaintiff filed suit on behalf of herself and her son under the Individuals with Disabilities Education Act (IDEA), alleging that the Board denied her son a free appropriate public education (FAPE) and violated the stay-put provision of the Act by refusing to pay for services mandated by the child's individualized education plan (IEP).After the district court's judgment on remand, the Second Circuit held that the district court did not abuse its discretion in denying reimbursement for several of the expenses plaintiff requested. However, the district court did err in determining that the funds administrator could unilaterally reduce these services covered by the fund and that plaintiff must pay for half of the compensatory fund's fees. Accordingly, the court affirmed in part, vacated in part, and remanded. View "Doe v. East Lyme Board of Education" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing the judgment of the trial court upholding the transfer of a tenured teacher (Plaintiff), working as a school administrator, to a teaching position because Plaintiff did not have an administrator license, holding that Plaintiff failed to prove that the transfer decision was not made in good faith and was arbitrary, capricious, or improperly motivated.In reversing the trial court, the court of appeals held that a regulation required the director of the school system to review the administrative duties Plaintiff had performed in the past in order to determine whether an administrator license was required, and the director's failure to do so rendered his transfer decision arbitrary and capricious. The Supreme Court reversed, holding (1) Plaintiff pointed to no provision in the Teacher Tenure Act that prevents a school system from establishing instructional leadership by school administrators as a priority; (2) consistent with the school system's priorities, Plaintiff was precluded from having administrative duties in the upcoming school year that involved more than fifty percent instructional leadership absent an administrator license; and (3) consequently, the director's failure to consider Plaintiff's past work did not render the transfer decision either arbitrary or capricious. View "Geller v. Henry County Board of Education" on Justia Law

Upon panel rehearing, the Fifth Circuit withdrew its prior opinion and substituted the following opinion.After an administrative hearing officer found that the School District violated the Individuals with Disabilities Education Act (IDEA) and awarded O.W. two years of private school tuition, the district court affirmed the award.The Fifth Circuit affirmed in part and reversed in part, holding that the IDEA's text and structure, including its implementing regulations, compel a conclusion that the child find and expedited evaluation requirements are separate and independent such that a violation of the latter does not mean a violation of the former. To the extent the district court held otherwise, the court held that this was error. The court also held that the continued use of behavioral interventions was not a proactive step toward compliance with the school district's child find duties and thus a child find violation occurred. The court further held that the district court erred in finding the May 6, 2015, modification represented an actionable failure to implement O.W.'s individualized education program (IEP), but correctly concluded the May 18, 2015, modification rose to the level of an actionable violation. The court remanded the remedy question to the district court for reconsideration. View "Spring Branch Independent School District v. O.W." on Justia Law

The Supreme Court reversed the judgment of the circuit court denying a request for declaratory and injunctive relief to bar enforcement of the Franklin County School Board's policy requiring parents to provide a birth certificate and proof of residence in the county for any child who is homeschooled, holding that the policy was contrary to the Homeschool Statute, Va. Code 22.1-254.1.In denying declaratory and injunctive relief the circuit court found that the board's policy was not contrary to the Code, was not ultra vires, and addressed the "valid public policy of ensuring the children monitored by [the Board] are between the ages of five (5) and eighteen (18) and are residents of Franklin County." The Supreme Court reversed, holding that the Board did not have authority to adopt the policy pursuant to section 22.1-78 because that statute only allows school boards to adopt regulations for the supervision of public schools, not home instruction. View "Sosebee v. Franklin County School Board" on Justia Law