Justia Education Law Opinion Summaries

Z.M., a non-verbal autistic child, attends the Center for Autism at Kiln Creek Elementary School. Through his father, he filed a lawsuit alleging that while being transported on a school bus, Newport News Public Schools employees struck him with a wet sock, verbally abused him, and allowed him to leave the bus partially unclothed. The complaint also mentioned previous verbal insults by school employees. Z.M. sought $15 million in compensatory and punitive damages, alleging negligence and gross negligence by the School Board and its employees.The Newport News School Board filed a plea in bar, claiming sovereign immunity. The Circuit Court of Newport News denied the plea regarding claims of simple and gross negligence but granted it concerning punitive damages, citing sovereign immunity. The School Board then filed an interlocutory appeal under Code §§ 8.01-626 and 8.01-670.2, which allow appeals from decisions on sovereign immunity pleas.The Supreme Court of Virginia reviewed the case de novo. The court concluded that Code § 22.1-194, which waives sovereign immunity when a vehicle is "involved in an accident," did not apply because the bus was not involved in an accident. The court held that the alleged acts did not relate to the operation of the bus as a vehicle. Consequently, the court reversed the circuit court's judgment and remanded the case for further proceedings. The court also noted that while the School Board is protected by sovereign immunity, the employees accused of gross negligence are not, allowing the lawsuit to proceed against them. View "Newport News School Board v. Z.M." on Justia Law

Libby Hilsenrath sued the Board of Education of the School District of the Chathams, claiming that the inclusion of instructional videos about Islam in her son's seventh-grade World Cultures and Geography class violated the Establishment Clause of the First Amendment. The class covered various world regions and their predominant religions, including Christianity, Buddhism, Hinduism, and Islam. The specific lessons on Islam included PowerPoint presentations and two YouTube videos, "Intro to Islam" and "The 5 Pillars of Islam," which Hilsenrath argued were proselytizing.The United States District Court for the District of New Jersey granted summary judgment to the Board, finding no Establishment Clause violation. The court applied the Lemon test and later, following a remand due to the Supreme Court's decision in Kennedy v. Bremerton School District, applied a historical analysis. The District Court concluded that the curriculum did not resemble any traditional hallmarks of religious establishment, such as coercion or preferential treatment of one religion over others.The United States Court of Appeals for the Third Circuit reviewed the case and affirmed the District Court's judgment. The Third Circuit held that the curriculum did not constitute proselytization or coercion, as the videos were part of a secular educational program covering multiple religions. The court also found no evidence of favoritism towards Islam, noting that the curriculum included teachings on various world religions. The court emphasized that the curriculum did not bear any hallmarks of religious establishment and upheld the District Court's decision. View "Hilsenrath v. School District of the Chathams" on Justia Law

The Los Angeles College Faculty Guild, AFT Local 1521, sought to reverse the trial court’s denial of its motion to compel arbitration of three grievances against the Los Angeles Community College District. The grievances involved safety-related construction projects at Los Angeles City College, the termination of a faculty member at Pierce College, and the miscalculation of retirement benefits for a faculty member at Los Angeles Trade-Technical College.The Superior Court of Los Angeles County partially granted the motion to compel arbitration for the grievance related to backpay for the retirement benefits issue but denied the motion for the other grievances. The court found that the grievances were beyond the scope of the collective bargaining agreement and were preempted by the Education Code and other statutory requirements.The Court of Appeal of the State of California, Second Appellate District, Division Eight, affirmed the trial court’s decision. The appellate court held that the grievances related to construction projects and employment termination were not arbitrable because they were preempted by the Education Code and the Construction Bonds Act. The court also found that the grievance related to retirement benefits was partially arbitrable only concerning the backpay issue, as the Public Employees’ Retirement Law governed the reporting of service credits to CalPERS, and the arbitrator could not order injunctive relief beyond the scope of the collective bargaining agreement.The appellate court concluded that the Guild failed to demonstrate that the grievances were within the scope of representation as enumerated by the Educational Employment Relations Act and affirmed the trial court’s mixed ruling. View "L.A. College Faculty Guild v. L.A. Community College District" on Justia Law

Petitioner, a sixteen-year-old, applied to the Mountaineer Challenge Academy (MCA) as an alternative to public high school. During the acclimation period, he injured his knee after exiting his bunk improperly. He was evaluated by medical personnel, placed on restricted duty, and later cleared for full duty. Subsequently, he was discharged from the program for noncompliance. Petitioner sued MCA and the West Virginia Army National Guard, alleging that their failure to enforce safety policies caused his injury and led to his unjust dismissal.The Circuit Court granted summary judgment in favor of the respondents, citing qualified immunity. The court found that the actions of the MCA staff involved discretionary functions and did not violate any clearly established statutory or constitutional rights. The Intermediate Court of Appeals affirmed this decision, agreeing that the cadre’s supervision fell within discretionary actions and that there was no violation of the petitioner’s right to an education or any statutory duty to supervise.The Supreme Court of Appeals of West Virginia reviewed the case de novo. The court held that the cadre’s actions were discretionary and protected by qualified immunity. It found no violation of clearly established rights or laws, as MCA is not part of the public school system and thus not subject to the same constitutional protections. The court also concluded that the petitioner failed to demonstrate that the respondents acted fraudulently, maliciously, or oppressively. Consequently, the court affirmed the lower courts' decisions, upholding the grant of summary judgment in favor of the respondents. View "Moorhead v. West Virginia Army National Guard" on Justia Law

The appellants, James Ruble, Linda O’Connor, Cynthia Brill, and Suzanne Holland, were administrators employed by the Switzerland of Ohio Local School District Board of Education. In 2021, the board, following the recommendation of a new superintendent, suspended their contracts to streamline the administration, which was deemed overstaffed. The administrators argued that the local policy under which their contracts were suspended was invalid as it did not meet the requirements of R.C. 3319.171.The Seventh District Court of Appeals denied the administrators' petition for a writ of mandamus, which sought reinstatement to their former positions with back pay and benefits. The court found that the board’s policy was valid and that the reasons for the contract suspensions were legitimate. The administrators then appealed to the Supreme Court of Ohio, focusing solely on the argument that the board’s policy was invalid under R.C. 3319.171.The Supreme Court of Ohio affirmed the lower court’s decision, holding that the administrators failed to demonstrate a clear legal right to reinstatement under R.C. 3319.171. The court noted that the statute does not provide a right to reinstatement if a local policy is found deficient. The court also denied the administrators' motion for oral argument, finding the briefs sufficient to resolve the issues. The judgment of the Seventh District Court of Appeals was thus affirmed, and the administrators' contracts remained suspended under the board’s policy. View "State ex rel. Ruble v. Switzerland of Ohio Local School Dist. Bd. of Edn." on Justia Law

A student, C.S., transferred from one high school to another within the Fort Smith School District and was rendered ineligible to participate in sports for one year due to the district's policy on intradistrict transfers. This policy contrasts with the immediate eligibility granted to students transferring from outside the district. Vincent Standridge, C.S.'s father, challenged this policy, arguing it violated state law, equal protection, parental rights, and constituted an abuse of power.The Sebastian County Circuit Court dismissed Standridge's complaint, holding that the policy did not violate Arkansas Code subsection 6-18-1904(f), which the court interpreted as applying only to interdistrict transfers. The court also found no constitutional violations or abuse of power.The Supreme Court of Arkansas reviewed the case and reversed the circuit court's decision in part. The Supreme Court held that Arkansas Code subsection 6-18-1904(f) applies to both intra- and interdistrict transfers, thus prohibiting the district's policy of excluding intradistrict transfer students from sports based solely on their transfer status. The court remanded the case for entry of judgment in Standridge's favor on this statutory claim.However, the Supreme Court affirmed the circuit court's dismissal of Standridge's equal protection, parental rights, and abuse of power claims. The court found that the district's policy had a rational basis and did not violate equal protection. It also held that there is no constitutional right to participate in sports and that the policy did not interfere with parental rights. The court concluded that there is no recognized claim for "abuse of power" in this context.The Supreme Court directed the clerk to issue the mandate immediately to allow C.S. to participate in extracurricular activities before the end of the spring semester. View "STANDRIDGE V. FORT SMITH PUBLIC SCHOOLS" on Justia Law

Neysha Cruz, on behalf of her son O.F., filed a lawsuit against the New York City Department of Education (DOE) under the Individuals with Disabilities Education Act (IDEA). Cruz rejected the DOE's education plan for O.F., who has multiple disabilities, and sought reimbursement for his private school tuition. Cruz argued that the DOE's placement of O.F. in a twelve-student classroom violated a New York regulation requiring students with highly intensive management needs to be placed in classes of six or fewer students. The DOE acknowledged the regulation but argued that another regulation allowing a maximum of twelve students for those with severe multiple disabilities also applied, giving them discretion in class size placement.An Impartial Hearing Officer (IHO) initially found that the DOE offered O.F. a Free Appropriate Public Education (FAPE) but that the recommended school could not implement the IEP due to scheduling issues. The IHO ordered partial reimbursement for private tuition. The State Review Officer (SRO) reversed the IHO's finding on the school's ability to implement the IEP and concluded that the DOE provided a FAPE, thus denying reimbursement.The United States District Court for the Southern District of New York upheld the SRO's decision, agreeing that the DOE could choose between the two class size regulations. Cruz appealed to the United States Court of Appeals for the Second Circuit.The Second Circuit found that the case hinged on interpreting New York's education regulations and certified the question to the New York Court of Appeals. The court sought clarification on whether the DOE must satisfy both class size regulations or if it can choose between them when both apply to a student. The Second Circuit retained jurisdiction pending the state court's response. View "Cruz v. Banks" on Justia Law

In 2021, the Napa Foundation for Options in Education (Napa Foundation) filed a petition with the Napa Valley Unified School District (School District) to establish the Mayacamas Charter Middle School. The School District Board of Education denied the petition, and the Napa Foundation then submitted the petition to the Napa County Board of Education (County Board), which also denied it. The Napa Foundation appealed to the State Board of Education (State Board), which reversed the denials. The School District and the California School Boards Association’s Educational Legal Alliance (Educational Legal Alliance) filed petitions for writs of mandate to set aside the State Board’s decision.The trial court granted the writ petitions, finding that the State Board abused its discretion. The court concluded that the District Board did not provide a fair and impartial hearing process and that the County Board’s decision was supported by substantial evidence, including the fiscal impact of the proposed charter school on the School District.The California Court of Appeal, Third Appellate District, reviewed the case. The court found that the State Board’s determination that the District Board failed to provide a fair and impartial hearing was not supported by substantial evidence. The court also found that the County Board’s written factual findings, which detailed the negative fiscal impact of the proposed charter school, were supported by substantial evidence. The court concluded that the State Board’s decision to reverse the County Board’s denial was arbitrary, capricious, and entirely lacking in evidentiary support.The Court of Appeal affirmed the trial court’s judgments, upholding the denials of the charter school petition by the District Board and the County Board. The court emphasized that the State Board failed to properly apply the abuse of discretion standard in its review of the lower boards’ decisions. View "Napa Valley Unified School Dist. v. State Bd. of Education" on Justia Law

The United States District Court for the District of Massachusetts issued a temporary restraining order (TRO) on March 10, 2025, preventing the Government from terminating various education-related grants. The order also required the Government to pay past-due grant obligations and continue paying future obligations. The District Court concluded that the respondents were likely to succeed on the merits of their claims under the Administrative Procedure Act (APA).The Government filed an application to vacate the District Court's order on March 26, 2025, which was extended on March 24, 2025. The application was presented to Justice Jackson and referred to the Supreme Court. The Supreme Court noted that the District Court's order had characteristics of a preliminary injunction, making it appealable. The Government argued that the District Court lacked jurisdiction to order the payment of money under the APA, as the APA's waiver of sovereign immunity does not apply to claims seeking money damages or to orders enforcing contractual obligations to pay money.The Supreme Court of the United States granted the Government's application to stay the District Court's order pending the appeal in the United States Court of Appeals for the First Circuit and any subsequent petition for a writ of certiorari. The Court found that the respondents had not refuted the Government's claim that it would be unlikely to recover the grant funds once disbursed and that respondents would not suffer irreparable harm while the TRO is stayed. The stay will terminate automatically if certiorari is denied or upon the sending down of the judgment of the Supreme Court if certiorari is granted. The Chief Justice would have denied the application. View "Department of Education v. California" on Justia Law

Jacob Doe, a student at the University of North Carolina at Chapel Hill (UNC-CH), was found responsible for two allegations of sexual misconduct and subsequently expelled from the university system. Doe sued the university and several employees, claiming violations of his Fourteenth Amendment due process rights, Title IX, and various state laws. The district court largely denied the defendants' motions to dismiss, allowing Doe’s federal and most state law claims to proceed.The defendants appealed to the United States Court of Appeals for the Fourth Circuit. The appellate court found that the district court erred in rejecting the defendants' claims of sovereign and qualified immunity. The court held that the UNC institutions were entitled to sovereign immunity, reversing the district court’s decision to allow Doe’s claims against them. Additionally, the court determined that the individual university employees were entitled to qualified immunity regarding Doe’s due process claims for damages, as the right to cross-examination in university disciplinary proceedings was not clearly established at the time.However, the appellate court affirmed the district court’s decision to allow Doe to seek prospective injunctive relief for the alleged due process violations. The court recognized that Doe had adequately alleged a liberty interest due to the permanent expulsion and the ongoing harm from the erroneous disciplinary record. The court declined to exercise pendent appellate jurisdiction over the district court’s denial of the motion to dismiss Doe’s Title IX claim against UNC-CH, dismissing that portion of the appeal for lack of jurisdiction.In conclusion, the Fourth Circuit affirmed in part, reversed in part, and dismissed in part the district court’s rulings, allowing Doe’s claims for prospective injunctive relief to proceed while dismissing his claims for damages against the UNC institutions and individual employees. View "Doe v. The University of North Carolina System" on Justia Law