Justia Education Law Opinion Summaries

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

The case involves the Newport School Committee and the Cumberland School Committee (collectively, plaintiffs) and the Rhode Island Department of Education and the Rhode Island Council on Elementary and Secondary Education (collectively, defendants). The dispute arose when the plaintiffs refused to reimburse the Department of Children, Youth, and Families (DCYF) at the "per-pupil special-education" rate for the cost of educating children who were placed in residential treatment programs by DCYF but were not receiving special-education services. The Family Court had placed two children in the temporary custody of DCYF and designated Newport and Cumberland as the residences of the children's custodial parents for the purpose of determining the municipalities' financial responsibility for the children's education.The Commissioner of Elementary and Secondary Education agreed with DCYF's argument that the municipalities were required to pay the per-pupil special-education rate according to the unambiguous language of the relevant statutes. The Commissioner issued two decisions ordering Newport and Cumberland to reimburse DCYF for the cost of educational services provided to the children at the special-education rate. After the Council on Elementary and Secondary Education denied the municipalities' independent appeals of the Commissioner's decisions, the municipalities appealed to the Superior Court. The trial justice consolidated the two cases and issued a written decision, determining that the clear and unambiguous language of the statute required the designated city or town to pay its share of the cost of educational services to DCYF rather than the higher, per-pupil special-education rate.The Supreme Court of Rhode Island reviewed the case and found that there is nothing in the relevant statutes that expressly obligates a municipality to pay the per-pupil special-education rate when the child in question is not actually receiving special-education services. The court concluded that municipalities are not required to reimburse DCYF at the per-pupil special-education rate when there were no special education services rendered and thus, no special education costs incurred. The court directed the parties to file supplemental briefs to resolve the remaining question of what reimbursement, if any, DCYF should receive for the educational cost of non-special-education students placed in residential treatment programs that include the delivery of educational services. View "Newport School Committee v. Rhode Island Department of Education" on Justia Law

This case involves a dispute between the University of Rhode Island Board of Trustees and the University of Rhode Island (plaintiffs) and the Hellenic Society Paideia – Rhode Island Chapter (defendant). The dispute arose from a breach-of-contract related to the construction of a Center for Hellenic Studies at the University of Rhode Island. The plaintiffs and defendant had entered into a Ground Lease Agreement that established the parameters for this construction project. The defendant failed to construct the Center for Hellenic Studies within the agreed timeframe, leading to litigation.The Superior Court stayed the litigation pending arbitration, as per the mandate. The arbitration proceedings were held, and the arbitrator issued a decision. The arbitrator found that the defendant had breached the lease agreement by failing to construct the Center for Hellenic Studies within the requisite timeframe, among other failures. The arbitrator also determined that a joint venture did not exist between the parties. The arbitrator directed the defendant to reimburse the plaintiffs for the cost and expenses that they will incur in their efforts to restore the construction site to its prior status.The plaintiffs filed a motion in Superior Court to confirm the arbitration award, which the defendant objected to and cross-moved to vacate. The trial justice granted the plaintiffs' motion to confirm the award and denied the defendant's cross-motion to vacate. The trial justice declined to review the arbitrator’s determination that the plaintiffs properly terminated the lease agreement and rejected the defendant’s objection to the arbitral remedy.The Supreme Court of Rhode Island affirmed the judgment of the Superior Court. The court concluded that the arbitrator's award drew its essence from the parties' lease agreement and lacked any indication that the arbitrator manifestly disregarded the law. The court rejected the defendant's arguments that the arbitrator had exceeded his authority. The court affirmed the trial justice's order confirming the arbitration award. View "The University of Rhode Island Board of Trustees v. Hellenic Society Paideia-Rhode Island Chapter" on Justia Law

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