Justia Education Law Opinion Summaries

The First Circuit affirmed the district court's dismissal of Plaintiff's complaint in part and otherwise vacated the judgment, holding that the University of Massachusetts at Amherst violated Plaintiff's federal constitutional right to due process in suspending him for five months without prior notice or a fair hearing but did not violate his rights in expelling him after providing a fair expulsion hearing.After the university suspended and then expelled Plaintiff, Plaintiff brought this action seeking compensatory damages, declaratory relief, and an injunction preventing the university from enforcing the expulsion. The district court entered summary judgment in favor of Defendants. The First Circuit (1) affirmed the district court's dismissal of Plaintiff's 42 U.S.C. 1983 claims challenging the adequacy of his expulsion hearing, Plaintiff's section 1983 claims for money damages against the university officials acting in their official capacities, and Plaintiff's Title IX claim; but (2) vacated for the entry of nominal monetary damages the dismissal of Plaintiff's section 1983 claims challenging the constitutionality of the manner in which the university suspended Plaintiff without prior notice or an adequate hearing. The Court then remanded the case for further proceedings. View "Haidak v. University of Massachusetts-Amherst" on Justia Law

The Fifth Circuit affirmed the bankruptcy court's denial of discharge on plaintiff's student loan debt under 11 U.S.C. 523(a)(8). The court held that there was no evidence that plaintiff's present circumstances -- her deteriorating diabetic conditions and the costs associated with it, and her inability to maintain employment -- are likely to persist throughout a significant portion of the loans' repayment period. Therefore, under the Brunner standard adopted by this court in In re Gerhardt, 348 F.3d at 91, and the vast majority of other circuit courts, plaintiff was not eligible for discharge for her student loans. View "Thomas v. Department of Education" on Justia Law

The Supreme Court affirmed in part and reversed in part the orders of the district court certifying three classes to proceed in a lawsuit against the University of Montana, holding that the district court abused its discretion in certifying Class 3 to pursue the claims.Current and former students of the University brought this lawsuit as a class action complaint alleging that the University breached its fiduciary duty to students by entering into a contract with Higher One, Inc. to process student loan refunds through non-competitive financial accounts and by providing students' personal information to Higher One. In two orders, the district court certified three classes to proceed in the lawsuit. The Supreme Court reversed in part, holding (1) the district court's certification of Class 3 under Mont. R. Civ. P. 23(b)(2) was an abuse of discretion; and (2) the district court abused its discretion in certifying Class 1 and Class 2 under Rule 23(b)(1) and (b)(2) but properly certified Class 1 and Class 2 under Rule 23(b)(3). View "Knudsen v. University of Montana" on Justia Law

The Court of Appeal affirmed the trial court's denial of a petition for writ of mandate seeking to set aside plaintiff's expulsion from Occidental College after an outside adjudicator found he had sexually assaulted and engaged in non-consensual sexual contact with another student. The court held that there was no violation of the school policy's notice requirements; there was no procedural unfairness where plaintiff was not prejudice when the policy's 60 day guideline for hearings was exceeded, he had access to all of the evidence against him, and he forfeited his contention that the adjudicator was biased; and there was no abuse of discretion in finding that plaintiff violated the policy by having nonconsensual sexual contact with the student View "Doe v. Occidental College" on Justia Law

The Koala brought this action for declaratory and injunctive relief, alleging that the University student government's passage of the Media Act, which eliminated registered student organization (RSO) funding for all print media, violated its First Amendment rights.The Ninth Circuit held that the Eleventh Amendment did not bar The Koala's claims and the relief The Koala sought was consistent with the Ex parte Young doctrine. The panel saw no reason why the rule articulated in the Free Speech cases cited -- that the government may not withhold benefits for a censorious purpose -- should not apply when the state singles out and burdens the press by revoking a subsidy, particularly where, as here, the record includes unusually compelling allegations that the government acted with discriminatory intent. Therefore, the second amended complaint's (SAC) Free Press Clause claim was sufficient to survive defendants' motion to dismiss because it alleged that the Media Act was passed for the express purpose of silencing a newspaper, and that defendants singled out The Koala for a disparate financial burden.The panel also held that the allegations in the SAC, and in the documents incorporated by reference into the SAC, supported the conclusion that defendants created a limited public forum encompassing all student activity funding, not one constrained to only media funds. Furthermore, the complaint sufficiently alleged a claim for First Amendment retaliation where The Koala's article was clearly protected speech, the Media Act chilled The Koala's speech, and The Koala adequately alleged a nexus between its speech and the Associated Students' alleged retaliatory conduct. Accordingly, the panel reversed in part and vacated in part. View "The Koala v. Khosla" on Justia Law

The DC Circuit held that the district court wrongly denied a stay-put injunction because it placed the burden of proof on the student rather than the local educational agency. Furthermore, the error had continuing adverse consequences for the student's claim for compensatory education. Accordingly, the court reversed and remanded for further proceedings.In this case, by holding that M.K. was not entitled to a stay-put injunction, the court held that the district court's order had the dual effect of both (i) empowering the school to continue excluding M.K. from its educational services, and (ii) limiting M.K.'s claim to compensatory educational relief for the time of that extended exclusion. The court reasoned that M.K.'s compensatory education request was not merely a "collateral consequence" of the underlying stay-put dispute, but it was part and parcel of it. View "Olu-Cole v. E.L. Haynes Public Charter School" on Justia Law

After the Association filed suit alleging that the District's school funding practices inadequately fund charter schools, the district court rejected the Association's claims. The DC Circuit did not reach the merits of the Association's claims, holding that the district court lacked jurisdiction over the claims. In this case, none of the Association's claims under the School Reform Act, Home Rule Act, and Constitution arose under federal law within the meaning of the federal question statute. Accordingly, the court vacated the district court's judgment and remanded for dismissal of the complaint for want of jurisdiction. View "D.C. Association of Chartered Public Schools v. District of Columbia" on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court on a complaint filed by Thornton Academy and residents of Arundel (collectively, Plaintiffs) in connection with the decision of Regional School Unit 21 and its Board (collectively, RSU 21) not to allow Arundel middle school students to attend Thornton Academy at public expense, holding that the court did not misinterpret Me. Rev. Stat. 20-A, 1479.In their complaint, Plaintiffs sought a declaratory judgment that RSU 21 incorrectly interpreted and applied Me. Rev. Stat. 21-A, 1479 in deciding that all Arundel public middle school students must attend the Middle School of the Kennebunks and that public funds cannot be used for those students to attend Thornton Academy. The superior court concluded that, pursuant to Me. Rev. Stat. 21-A, 1479(3)(A), RSU 21 must continue to allow Arundel middle school students to attend Thornton Academy at public expense. The Supreme Judicial Court affirmed, holding that section 1479(3)(A) requires RSU 21 to provide the option for Arundel middle school students to attend Thornton Academy at public expense. View "Thornton Academy v. Regional School Unit 21" on Justia Law

Plaintiff filed suit against NYIT, alleging violations of the Americans with Disabilities Act (ADA), Title IX of the Education Amendments of 1972, and New York State Human Rights Law (NYSHRL). Plaintiff alleged that NYIT discriminated against him based on his homosexuality and mental health disability.The Second Circuit affirmed in part, holding that plaintiff's 2010-11 claims were untimely, and the continuing violation doctrine did not apply to these claims. However, the court held that the district court erred in dismissing plaintiff's 2013-14 claims under the ADA and Title IX, because the four month statute of limitations for a New York State Article 78 Proceeding did not apply to these claims. Rather, a three year statute of limitations applied to both claims, and thus his claims were timely. Accordingly, the court vacated in part and remanded. View "Purcell v. N.Y. Institute of Technology - College of Osteopathic Medicine" on Justia Law

The First Circuit affirmed the judgment of the district court in favor of the Fay School, Inc. and Fay's Head of School as to Appellants' complaint alleging unlawful retaliation for demands for an accommodation for a certain condition of G., a twelve-year-old minor, holding that the district court correctly denied Appellants' claims.G., a former student of the Fay School, and her parents (collectively, Appellants) brought this suit against Fay after the school refused to remove wireless internet from its classrooms to accommodate G.'s alleged electromagnetic hypersensitivity (EHS), a sensitivity to electromagnetic fields. Appellants alleged, among other claims, unlawful retaliation for an accommodation for G.'s condition, in violation of Title V of the Americans with Disabilities Act, 49 U.S.C. 12203(a), breach of contract, and misrepresentation. The First Circuit affirmed, holding (1) damages are not an available remedy for a Title V retaliation claim premised upon an exercise of rights under Title III of the ADA; and (2) Appellants failed to raise triable issues of fact as to their contract and misrepresentation claims. View "G. v. Fay School" on Justia Law