Justia Education Law Opinion Summaries

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In a case before the United States Court of Appeals for the Fourth Circuit, a private school, Concordia Preparatory School, was sued by a student and her mother for alleged violations of Title IX of the Education Amendments of 1972, which prohibits sex-based discrimination in federally-funded educational programs. The plaintiffs claimed that the school's tax-exempt status under 26 U.S.C. § 501(c)(3) constituted federal financial assistance, thus making it subject to Title IX.The school moved to dismiss the claim, arguing that it did not receive federal financial assistance and was therefore not subject to Title IX. The district court denied the school's motion, agreeing with the plaintiffs that the school's tax-exempt status constituted federal financial assistance for Title IX purposes. However, the court certified an interlocutory appeal on this issue.Upon review, the Fourth Circuit Court of Appeals disagreed with the district court's interpretation. The appellate court reasoned that while tax exemption is a benefit, it is not equivalent to "receiving Federal financial assistance" as required by Title IX. The court explained that the term "assistance" implies aid, help, or support, which suggests a grant of funds. Tax exemption, however, is merely the withholding of a tax burden rather than an affirmative grant of funds. Furthermore, the court distinguished tax exemption from the indirect receipt of federal funds as was the case in Grove City College v. Bell.As such, the Fourth Circuit reversed the district court's decision and held that tax-exempt status does not equate to "receiving Federal financial assistance" for purposes of Title IX. The case was remanded for further proceedings. View "Buettner-Hartsoe v. Baltimore Lutheran High School Association" on Justia Law

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A high school student, identified as J.G., was required to undergo daily searches for weapons as part of a safety plan after committing firearm-related offenses. However, when J.G. returned to school for his tenth-grade year, he was not searched on the first two days. On his third day, school administrators discovered a loaded handgun in his backpack and he was arrested and charged with weapons-related offenses. J.G. moved to suppress evidence of the handgun, arguing that the search violated his Fourth Amendment rights as the safety plan was no longer in effect at the time of the search. His motion was denied by the juvenile court which found that the safety plan, with its requirement for daily searches, was still in place when the handgun was found.The Supreme Court of the State of Colorado affirmed the lower court's decision. The court held that a search of a student conducted on school grounds in accordance with an individualized, weapons-related safety plan is reasonable under the Fourth Amendment. The court reasoned that J.G.'s behavior did not create individualized reasonable suspicion on the day he was searched. However, the presence or absence of individualized suspicion is not the full extent of the inception prong of the reasonableness test. The court held that the search of J.G.’s backpack was reasonable at its inception because it was carried out in conformity with a formal safety plan and it was appropriately limited in its scope. The court also found that J.G. had sufficient notice of the search requirement to diminish his expectation of privacy in his backpack. View "People In re J.G." on Justia Law

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A medical resident, Dr. Jacquelyn Mares, was dismissed from Wright State University’s (WSU) obstetrics and gynecology residency program due to ongoing complaints and escalating disciplinary actions related to her unprofessional behavior. Following her dismissal, Mares was also terminated from her position at Miami Valley Hospital, where she was employed during her residency. As a result, Mares sued WSU, the hospital, its owner-operator Premier Health Partners, and several WSU employees, alleging violations of her procedural and substantive due process rights, as well as various contract-based state law claims. The district court granted summary judgment to the defendants.In its ruling, the United States Court of Appeals for the Sixth Circuit held that WSU did not violate Mares' procedural due process rights when it dismissed her from the residency program. The court found that WSU had followed its internal procedures closely and that Mares was afforded more than enough process. Also, the court held that WSU did not violate Mares' substantive due process rights. It determined that WSU's decision to dismiss her was not arbitrary or capricious, nor was it conscience-shocking. Finally, the court held that Miami Valley Hospital did not breach its contractual duties when it terminated Mares after her dismissal from WSU’s residency program. The court concluded that the hospital acted within the scope of the employment contract. Therefore, the court affirmed the district court’s decision to grant the defendants' summary judgment. View "Mares v. Miami Valley Hospital" on Justia Law

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In this case, a minor student known as A.J.T., who suffers from epilepsy, sued her school district, Osseo Area Schools, alleging disability discrimination for not providing her evening instruction sessions. A.J.T.'s epilepsy is severe in the mornings, preventing her from attending school until noon. The child's parents requested evening instruction so that she could have a school day closer in length to her peers. However, the school district denied these requests.A.J.T., through her parents, filed a lawsuit alleging violations of Section 504 of the Rehabilitation Act and the Americans with Disabilities Act (ADA). The district court granted Osseo Area Schools' motion for summary judgment, finding that the school district could not be held liable as it did not act with bad faith or gross misjudgment.The United States Court of Appeals for the Eighth Circuit affirmed the district court's decision. The court stated that while A.J.T. might have established a genuine dispute about whether the district was negligent or even deliberately indifferent, she failed to prove that school officials acted with "either bad faith or gross misjudgment." The court found that the school district did not ignore A.J.T.'s needs or delay its efforts to address them. It further held that in cases involving educational services for disabled children, mere noncompliance with applicable federal statutes or failure to provide a reasonable accommodation is not enough to trigger liability. The plaintiff must prove that the school officials acted with bad faith or gross misjudgment. In this case, A.J.T. failed to identify conduct that cleared that high bar, and as such, the court held that summary judgment was proper. View "A.J.T. v. Osseo Area Schools, Independent School District No. 279" on Justia Law

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In this case, the United States Court of Appeals for the Eighth Circuit considered the appeal of Osseo Area Schools (the District) against the ruling of the district court, which held that the District had denied A.J.T., a student with a disability, a Free Appropriate Public Education (FAPE) as mandated by the Individuals with Disabilities Education Act (IDEA). A.J.T. suffers from a rare form of epilepsy, causing seizures that prevent her from attending school before noon. Consequently, her parents had requested the District to provide evening instruction, which was refused.The district court found that the District's refusal to provide A.J.T. with evening instruction resulted in her making de minimis progress overall and even regressing in some areas, such as toileting. The court also determined that A.J.T. would have made more progress had she received evening instruction. On these grounds, the court concluded that the District had failed to provide A.J.T. with a FAPE.On appeal, the Eighth Circuit affirmed the district court's judgment. The court rejected the District's argument that the IDEA's scope was limited to regular school hours, noting nothing in the IDEA suggested such a limitation. Furthermore, the court agreed with the district court's assessment of A.J.T.'s limited progress and regression in toileting. After considering the evidence, the court concluded that the District's refusal to provide evening instruction, based solely on administrative concerns, resulted in A.J.T.'s minimal progress and denied her a FAPE. View "Osseo Area Schools, Independent School District No. 279 v. A.J.T." on Justia Law

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In this appeal, the Pennsylvania State Education Association (PSEA) challenged a resolution issued by the Public School Employees’ Retirement Board (PSERB), which addressed how it intended to apply a statute related to the withdrawal of public school employees from a multi-employer pension system. The Commonwealth Court dismissed PSEA’s action for lack of standing. The court held that PSEA had not shown a substantial, direct, and immediate interest in PSERB’s action or inaction, as PSEA's true dispute was with school district employers over subcontracting, not with PSERB.However, the Supreme Court of Pennsylvania reversed this decision, finding that PSEA did have standing to challenge the resolution. The Supreme Court held that PSEA’s interest in the issue was substantial as it far exceeded the interest of the public at large in the correct application of the statute. The court also found that PSEA’s interest was direct because the resolution was causally connected to the harm PSEA alleged in its ability to effectively negotiate over subcontracting decisions. Additionally, the court found that PSEA’s interest was immediate because the causal connection was real and concrete, not remote or speculative. The court noted that PSEA's averments established a substantial, direct, and immediate interest sufficient to warrant a request for the sort of remedy that a declaratory judgment action seeks—a clarification of the law to resolve a dispute between interested parties over its meaning. Consequently, the Supreme Court of Pennsylvania reversed the Commonwealth Court’s order and remanded the matter to allow PSEA’s action to proceed. View "PSEA v. PSERB" on Justia Law

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In the United States Court of Appeals for the Second Circuit, the appellant, Brittany Jones, claimed she was sexually abused by a teacher between 2009 and 2011, when she was a high school student. She brought her claims under the Child Victims Act (CVA) of New York, which revived time-barred claims of child sexual abuse victims, and provided a two-year window from August 14, 2019 to August 14, 2021 for the filing of such claims. However, Jones filed her suit four months before the commencement of this window. The United States District Court for the Western District of New York, in a summary judgment, ruled in favor of the school district, holding that Jones's premature filing created a valid statute-of-limitations defense for the school district.This decision was appealed and the key question before the appellate court was whether the six-month waiting period created by the CVA was a statute of limitations. The appellate court concluded that neither the text of the CVA nor any precedent from New York courts provided clear guidance on this issue. Given the significant state policy interests implicated by the CVA, the appellate court decided to certify the question to the New York Court of Appeals: whether the six-month waiting period for claims under the CVA establishes a statute of limitations, a condition precedent to bringing suit, or some other affirmative defense. The court reserved its decision on the appeal pending the response from the New York Court of Appeals. View "Jones v. Cattaraugus-Little Valley Central School District" on Justia Law

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A private Catholic high school in Madison, Wisconsin, sued the city and other defendants, claiming that the city's decision to deny the school permission to install lights for nighttime athletic events violated the Religious Land Use and Institutionalized Persons Act (RLUIPA) and the Free Exercise Clause of the U.S. Constitution. The school also claimed a vested property right under Wisconsin law.In the United States Court of Appeals for the Seventh Circuit, the school argued that the city's actions amounted to unequal treatment and a substantial burden on its religious exercise. However, the court found that the school, as a master plan institution under the city's Campus-Institutional District ordinance, was not comparably situated to other institutions that had been granted lighting permits. The court also ruled that the city's denial of the permit did not amount to a substantial burden on the school's religious exercise under RLUIPA.Furthermore, the court found that the school's Free Exercise claim provided no additional protections beyond those under RLUIPA and thus could be dismissed. Lastly, the court rejected the school's vested rights claim, as the lighting permit application did not conform to the municipal zoning requirements in effect at the time. Consequently, the court affirmed the lower court's summary judgment in favor of the city. View "Edgewood High School of the Sacred Heart, Incorpor v. City of Madison, Wisconsin" on Justia Law

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In a dispute between tenured faculty members and Tufts University, the faculty members alleged that the university's policies requiring them to cover half of their salary with external research funding and reducing their laboratory space violated their tenure rights to economic security and academic freedom. These policies, instituted between 2016 and 2019, led to a decrease in the plaintiffs' salaries and full-time status, and their laboratory space was reduced or closed entirely when they failed to meet the external funding requirements.The Supreme Judicial Court of Massachusetts noted that tenure contracts are defined by their specific terms and must be understood in the context of the academic community's norms and expectations. The court found that the term "economic security" in the tenure contracts was ambiguous and further evidence was needed to determine whether the reductions in salary and full-time status violated the economic security provided in the tenure contracts. However, the court concluded that neither economic security nor academic freedom guaranteed the plaintiffs specific lab space.The court reversed the lower court's judgment in favor of Tufts on the compensation policies, remanding the case for further proceedings. However, it affirmed the lower court's judgment that the laboratory space guidelines did not violate the plaintiffs' tenure rights. The court also left unresolved the plaintiffs' claims under the Wage Act, as it was dependent on the outcome of the compensation dispute. View "Wortis v. Trustees of Tufts College" on Justia Law

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This appeal, heard by the United States Court of Appeals for the First Circuit, centered on the constitutionality of Massachusetts' Law 80, which retroactively provided immunity to higher education institutions for monetary damages due to actions taken in response to the COVID-19 pandemic. The plaintiffs, students at Boston University (BU), had sued the university for breach of contract and unjust enrichment following BU's transition to remote learning during the Spring 2020 semester. They contended that they had paid for in-person instruction and services, which BU failed to provide.The lower court ruled in favor of BU, holding that the university was entitled to the defense of impossibility as it had to comply with COVID-19 emergency orders. On appeal, the court was required to consider whether the retroactive application of Law 80 to the case violated the Due Process Clause of the United States Constitution.The appellate court found that Law 80 served reasonable public interests related to public health, safety, future compliance, and economic consequences beyond the control of the universities. The court also determined that the plaintiffs' alleged implied contract rights did not constitute vested rights. Furthermore, the court noted that the scope of Law 80 was appropriately limited and did not excessively burden the plaintiffs.Consequently, the court held that Law 80 does not violate due process and affirmed the lower court's judgment, ruling in favor of BU. The court did not need to consider the merits of the lower court's decision to exclude the plaintiffs' expert witness's testimony. View "Dutra v. Trustees of Boston University" on Justia Law