Justia Education Law Opinion Summaries

The Fifth Circuit reversed the district court's dismissal of plaintiff's Title IX complaint for failure to exhaust administrative remedies under the Individuals with Disabilities Education Act (IDEA). Plaintiff's claims stemmed from an incident at school where another student raped her special needs child.Based on the Supreme Court's recent decision in Fry v. Napoleon Community Schools, 137 S. Ct. 743 (2017), the court held that if a disabled person seeks Title IX relief that a non-disabled person could also seek and requests relief that is different from or in addition to a free appropriate public education (FAPE), the IDEA's exhaustion requirement does not apply.In this case, plaintiff's claim involved simple discrimination, irrespective of the IDEA's FAPE obligation. Were all traces of the child's disabilities removed, the court explained that plaintiff's claim would look nearly identical to allegations that the school was deliberately indifferent to the child's sexual abuse. Therefore, the court held that the gravamen of the complaint was not about the denial of a FAPE, and the IDEA's exhaustion requirement does not apply. Accordingly, the court remanded for further proceedings. View "Doe v. Dallas Independent School District" on Justia Law

The Fifth Circuit affirmed the district court's grant of summary judgment to the university in an action brought by a student, alleging substantive due process and equal protection claims in connection with the university's evaluation of allegations that the student cheated on an exam.The court held that the district court abused its discretion by refusing to consider the student's expert reports solely because they were unsworn, without considering whether the opinions were capable of being presented in a form that would be admissible in evidence. In regard to the substantive due process claim, the court held that the student failed to identify any summary judgment evidence raising a genuine fact issue that defendants did not actually exercise professional judgment in resolving the cheating allegations, or that the result of the process was beyond the pale of reasoned academic decision-making. Likewise, the court held that the student failed to demonstrate a genuine issue of material fact as to his equal protection claim. In this case, there was nothing in the record to suggest that the student was intentionally treated in a manner irrationally different from other similarly situated students. View "Patel v. Texas Tech University" on Justia Law

The named plaintiff, Mike Zeyen sought declaratory relief and recovery of damages from Pocatello/Chubbuck School District No. 25 on behalf of all students currently enrolled in the district and their guardians. Zeyen alleged that School District 25’s practice of charging fees violated Article IX, section 1, of the Idaho Constitution. Zeyen first sought to certify the class to include all students within School District 25. Zeyen’s later motion to amend sought to add a takings claim under both the Idaho and U.S. Constitutions. The district court denied Zeyen’s motion for class certification based on lack of standing and denied his motion to amend both as untimely and prejudicial to School District 25. The Idaho Supreme Court determined Zeyen failed to show that the district court abused its discretion by denying his second motion for leave to amend the complaint. Furthermore, the Court determined Zeyen lacked standing to bring his class action suit. The Court therefore affirmed the district court's denial of Zeyen's motion to certify the class and denial of his motion for leave to amend the first amended complaint. View "Zeyen v. Pocatello/Chubbuck School Dist 25" on Justia Law

In 2015, plaintiffs sued 88 school districts and the California Department of Education, seeking relief for alleged violations of Education Code section 51210(g). That law requires no less than 200 minutes of physical education instruction every 10 school days for pupils in first through sixth grades. In 2017, five of the districts sought to have the court issue a writ of mandamus against them, granting the relief sought in the petition. The superior court granted the motion. The court of appeal affirmed, rejecting arguments that it was error for the trial court to enter the judgments without an evidentiary proceeding; that the allegations did not preclude writ relief beyond the limited relief contained in the judgments (injunctive relief); and the trial court should have allowed amendment of the petition to state a cause of action for declaratory relief. The plaintiffs unsuccessfully argued that a writ of mandate was an inadequate remedy because it cannot compel the school districts’ employees to comply with the PE mandate and that no writ could issue unless the Districts admit noncompliance with the PE mandate. View "Cal200, Inc., v. Apple Valley Unified School District" on Justia Law

The Supreme Court affirmed in part and reversed in part the order of the district court entering an injunction directing Defendants to place on the ballot a measure asking voters whether they approved the demolition of Hoover Elementary School and the use of the proceeds for school district purposes, holding that the district court erred in granting Plaintiffs injunctive relief.The Iowa City Community School District refused to authorize the placement of the ballot issue at an election after a petition bearing more than 2000 signatures had been timely filed with the Board. When the Board refused to direct the county auditor to place the matter on the ballot for the upcoming election, Plaintiffs sought injunctive relief and damages against the school district court individual board members. The district court entered an injunction and directed the district court to place the matter on the next general election ballot. The district court then granted Defendants summary judgment on Plaintiffs' claims for damages. The Supreme Court reversed in part, holding that Defendants were entitled to summary judgment on all claims because the school district was under no legal obligation to require the county auditor to place the matter on the ballot. View "Young v. Iowa City Community School District" on Justia Law

Plaintiff and his parents filed suit against the school district, seeking damages under the Rehabilitation Act and 42 U.S.C. 1983 after plaintiff was expelled from high school. The Fifth Circuit explained that, because plaintiff did not exhaust the Individuals with Disabilities Education Act's (IDEA) procedures, his suit asserting other federal claims must be dismissed if it seeks relief that is also available under the IDEA. In this case, both the substance and language of plaintiff's complaint reveal that he was challenging the denial of a free appropriate public education (FAPE) that the IDEA promised him.The court held that plaintiff did not seek awards tied to the cost of providing him with an adequate education. Rather, he sought damages for injuries like emotional distress, and such traditional compensatory damages were not available under the IDEA. Therefore, the IDEA's exhaustion requirement applied to plaintiffs who seek damages for the denial of a FAPE. In this case, because plaintiff did not first seek relief through the IDEA administrative process, his lawsuit was properly dismissed. View "McMillen v. New Caney Independent School District" on Justia Law

In 2006, SFSU hired Gupta, an American woman of Indian ancestry, as a tenure-track assistant professor. In 2009, Gupta and other women of color in the School of Social Work raised issues concerning “hostile work environment” and discrimination. Two months later, Gupta received a critical fourth-year review. Shortly thereafter, Gupta sent emails to a colleague complaining that her workplace was hostile towards women of color. Her supervisor told Gupta “I know about [the emails] ... I’m going to get even.” Another professor witnessed the exchange. After being denied early tenure Gupta filed an EEOC complaint and a federal lawsuit. An arbitrator ordered SFSU to review Gupta for tenure the following year. Despite excellent evaluations and recommendations, Gupta was denied tenure; her supervisor made threatening remarks to a colleague who questioned the decision. SFSU granted tenure to Dr. J.H., another School of Social Work professor, who had not filed a complaint. Gupta’s scores were better than J.H.’s scores and Gupta had more than double the minimum publication requirement, while J.H. had not met that requirement. SFSU terminated Gupta’s employment in 2014.A jury awarded Gupta $378,461 for retaliation; the court awarded $587,160.75 in attorney fees and costs. SFSU has reinstated Gupta as a tenured professor. The court of appeal affirmed, rejecting arguments that the trial court erred in: allowing Gupta to present evidence of a “comparator professor” without requiring her to show her qualifications were clearly superior; refusing to give a special jury instruction regarding comparator evidence; and intervening in the questioning of witnesses in a manner that favored Gupta. View "Gupta v. Trustees of the California State University" on Justia Law

Walter Jones appeals the order of the Circuit Court of Madison County affirming his removal as trustee of the Canton Public School District (CPSD) by the Board of Aldermen (the Board) of the City of Canton (the City). Jones argued the Board lacked the authority to remove him as a public official. Finding that the Board’s actions were prohibited by the Mississippi Constitution, the Mississippi Supreme Court agreed: because the Board’s authority was based on a city ordinance inconsistent with the Mississippi Constitution and because the Board’s action violated Jones’s right to due process, the Supreme Court reversed the circuit court’s decision to affirm the Board’s removal of Jones as school-board trustee. View "Jones v. City of Canton, Mississippi" on Justia Law

During his high school senior year, Frank had an encounter with the school’s new resource officer, Redwood City Officer Stahler. Frank’s father filed a complaint alleging Stahler had physically handled Frank in an unlawful manner. An investigation followed but Stahler continued at the school. Months later, Frank and three others left a class without permission. Frank was found in the library. An aide directed him to the administrative vice principal’ office, where Stahler was located. Frank called his father on his cell phone and told the aide he wanted to go to the principal’s office instead but generally cooperated with the aide. Stahler arrived and reprimanded Frank about using the phone in violation of school rules. There was physical contact; the two dispute the nature of the confrontation. Eventually, Stahler grabbed his wrist, forced Frank to the ground, handcuffed him and arrested him. The juvenile court sustained charges of misdemeanor battery and resisting a peace officer. The court of appeal reversed. Stahler did not indicate that Frank acted willfully or unlawfully to touch him. There is no substantial evidence that Frank’s touching Stahler, even if willful, was “harmful or offensive,” another required element of battery. There is no indication Stahler was enforcing any disciplinary rules during the encounter. Given Stahler’s failure to give Frank any clear or direct orders, there was insufficient evidence that Frank willfully resisted Stahler. View "People v. Francis A." on Justia Law

Plaintiff, a child, by and through his parents, brought a Governmental Tort Claims Act action alleging he was injured through the negligence of a school bus driver. The child was taken to a hospital emergency room, given several diagnostic tests, and treated with 4 staples for one laceration and Dermabond for another. When he filed his District Court action more than one year later he alleged he had medical-related expenses in the amount of $6,209.30, and potential unknown medical expenses as a result of being hit by the bus. Further, he alleged pain and suffering and sought a sum in excess of $10,000. The three basic questions raised on application for certiorari review by the Oklahoma Supreme Court were: (1) whether an Oklahoma Governmental Tort Claims notice sent by certified mail to a superintendent of a public school statutorily sufficient; (2) whether an insurance adjuster's request for more information tolled the GTCA time limits if the request also stated an intent for tolling to not occur; and (3) whether a unilateral request by plaintiff for settlement negotiations tolled the GTCA time limits. The Supreme Court held plaintiff's Governmental Tort Claims Act (GTCA) notice of claim sent to the correct school superintendent by certified mail satisfied the requirement in 51 O.S. 156(D) for filing the GTCA notice with the office of the clerk of the school's board of education, although the superintendent did not transmit the notice to the proper clerk for filing. Further, the Court held the insurance adjuster's request for additional information did not toll the 90-day time limit for approval, denial, or deemed denial of the GTCA claim when the request expressly stated it would not extend or waive the GTCA time limits. Finally, the Court held a plaintiff's letter unilaterally seeking settlement negotiations was not an agreement pursuant to 51 O.S. 157 to toll the GTCA time limits. View "I. T. K. v. Mounds Public Schools" on Justia Law