Education Law - Justia Case Law Summaries

South Carolina State Conference of the NAACP v. Weaver

2026-07-08T10:30:40-08:00

A South Carolina budget provision, known as the “Proviso,” prohibits public schools from using state funds to teach certain concepts related to race and sex. Several Black students, the South Carolina State Conference of the NAACP (SC NAACP), and author Ibram Kendi challenged the Proviso, alleging it led to the removal of an Advanced Placement African American Studies (AP AAS) course and one of Kendi’s books from school libraries. The students and SC NAACP asserted that eliminating the AP AAS course infringed upon students’ First Amendment right to receive information, while Kendi claimed the book’s removal constituted viewpoint discrimination. Plaintiffs further alleged that the Proviso was void for vagueness and violated the Equal Protection Clause. The United States District Court for the District of South Carolina dismissed the complaint for lack of Article III standing. The court concluded that the individual students did not allege a concrete injury as they had not actually enrolled in AP AAS, and found that even a student who had enrolled failed to establish that her injury was traceable to the Proviso rather than an unrelated curriculum review. The district court also held that Kendi’s injury was not redressable because the school district cited an alternative, unchallenged rationale for removing his book. The United States Court of Appeals for the Fourth Circuit affirmed in part, reversed in part, vacated in part, and remanded. It affirmed dismissal with respect to a student who had graduated and another who had not taken concrete steps to enroll in AP AAS. However, it held that SC NAACP adequately alleged standing for at least one member with an ongoing injury, and Kendi sufficiently alleged standing for his viewpoint discrimination claim. The court vacated dismissal of other claims and remanded for the district court to address unresolved standing and merits questions. View "South Carolina State Conference of the NAACP v. Weaver" on Justia Law

Pernell v. Commissioner of the FL State Board of Education

2026-07-07T06:31:44-08:00

Florida enacted a law prohibiting public university professors from endorsing or promoting certain ideas related to race, color, sex, and national origin in classroom instruction. The law, known as the Individual Freedom Act, identifies eight specific concepts that professors are barred from espousing, such as claims of moral superiority based on race or sex, inherent racism or oppression, and the idea that virtues like merit or colorblindness are themselves racist or sexist. The law allows professors to discuss these concepts in a neutral way, but not to advocate for them, and imposes severe penalties on both individual professors and universities for violations, including the loss of significant funding and potential termination of employment. Groups of professors and students from several Florida public universities filed lawsuits in the United States District Court for the Northern District of Florida, arguing that the Act violated their First Amendment rights by restricting viewpoint-based expression and was unconstitutionally vague. The district court granted preliminary injunctions in both cases, enjoining enforcement of the Act’s classroom restrictions against the plaintiffs, finding that at least one plaintiff had standing to challenge each prohibited concept. The court concluded the Act was likely unconstitutional as applied to public university professors. On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the district court’s grant of a preliminary injunction. The Eleventh Circuit affirmed, holding that the Act’s restrictions amount to unconstitutional viewpoint discrimination in violation of the First Amendment. The court distinguished between permissible curricular control by universities and the broad, legislative ban imposed by the state’s political branches. It concluded that neither public-employee speech doctrine nor government speech doctrine justified the law’s suppression of disfavored ideas in the university classroom, and that the Act impermissibly infringed on academic freedom and open inquiry. The preliminary injunction was affirmed. View "Pernell v. Commissioner of the FL State Board of Education" on Justia Law

Adelanto Elementary Sch. Dist. v. Krause

2026-07-06T11:03:28-08:00

A former superintendent of a California school district, who later became an elected member of the district’s Board of Trustees, was subject to a workplace violence restraining order (WVRO) requested by the district on behalf of three employees. These employees, who worked closely with the superintendent, reported that he engaged in a persistent course of conduct that included angry outbursts, threats of termination, intrusive and inappropriate text messages, stalking behaviors, and unsolicited photographs. The conduct caused substantial emotional distress and fear among the employees, leading them to seek mental health treatment and report his actions to the police. After his termination, the superintendent continued to interact with the employees in ways they perceived as intimidating, including the placement of campaign signs near their homes and the publication of internal documents on social media. The Superior Court of San Bernardino County granted a temporary restraining order and, after a multi-day hearing, issued a WVRO prohibiting the superintendent from harassing, disturbing the peace of, or contacting the three employees. The WVRO imposed restrictions on his proximity to the employees and their workplace, allowed his attendance at board meetings only under specific conditions, and included a provision barring him from commenting on the WVRO at board meetings. The order was set to last four years, subject to early termination if he was no longer associated with the district. The California Court of Appeal, Fourth Appellate District, Division One, reviewed the case. The court held that an employer’s right to seek a WVRO on behalf of employees is unwaivable under Civil Code section 3513, rejected arguments concerning insufficient evidence and violation of parental rights, and found sufficient evidence of a future threat of harassment. However, it determined that the WVRO’s prohibition on comments at board meetings was overbroad and violated First Amendment rights, and that the order’s four-year duration exceeded the statutory maximum. The court modified the order to remove the speech restriction and limit its duration to three years, then affirmed the WVRO as modified. View "Adelanto Elementary Sch. Dist. v. Krause" on Justia Law

State of Florida v. Secretary, US Department of Education

2026-07-06T09:32:09-08:00

The dispute centers on whether the U.S. Department of Education may constitutionally rely on private educational accreditors in disbursing federal education funds. Under the Higher Education Act, colleges and universities must be accredited by a recognized accreditor for their students to be eligible for federal financial aid. Accreditors are private, voluntary organizations funded by the schools they accredit. Florida challenged this arrangement, alleging that it unconstitutionally delegates government power to private accreditors and violates both the Appointments Clause and the Spending Clause, claiming the accreditation requirement is an unascertainable condition for federal funds. The United States District Court for the Southern District of Florida reviewed the suit after Florida brought four claims: a private nondelegation doctrine challenge, an Appointments Clause challenge, a Spending Clause challenge, and a now-abandoned Administrative Procedure Act challenge. The federal government moved to dismiss, and the district court granted the motion. The district court found no unlawful delegation of government power, noted that Title IV funds are directed to students and not institutions, determined the accreditation requirement is unambiguous, and dismissed the Appointments Clause claim because accreditors do not determine eligibility for federal funds. On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the district court’s dismissal de novo. The Court held that private accreditors do not exercise government authority that could violate the Vesting Clauses or the Appointments Clause. The Court also determined that the accreditation requirement is an ascertainable condition for federal funds, as it is a well-understood, longstanding practice and does not amount to an ambiguous or novel restriction. The Eleventh Circuit affirmed the district court’s dismissal of Florida’s suit. View "State of Florida v. Secretary, US Department of Education" on Justia Law

West Virginia v. B. P. J.

2026-06-30T07:15:06-08:00

A state law in West Virginia prohibited male students, as determined by biological sex, from participating on female sports teams. A student who is a biological male but identifies as female and has taken puberty blockers and hormones sought to participate on the girls’ cross-country and track-and-field teams and brought suit against West Virginia officials, alleging violations of Title IX and the Equal Protection Clause. Similarly, Idaho passed a law barring male students from female sports teams; a transgender woman who is a biological male but identifies as female and had taken hormones challenged Idaho’s law after trying out for collegiate women’s sports. Both states justified their laws by referencing inherent physical differences between the sexes and concerns for safety and competitive fairness in women’s sports. The United States District Court for the Southern District of West Virginia granted summary judgment for the state, finding no violation of Title IX or the Equal Protection Clause. The United States Court of Appeals for the Fourth Circuit reversed the ruling on the Title IX claim and remanded for further factual findings on the Equal Protection claim. Meanwhile, in Idaho, the United States District Court for the District of Idaho issued a preliminary injunction against enforcement of the statute; the United States Court of Appeals for the Ninth Circuit affirmed that decision, finding a likely violation of the Equal Protection Clause. The Supreme Court of the United States reversed both appellate court decisions. It held that Title IX permits schools to maintain separate men’s and women’s sports teams determined by biological sex and does not require exceptions for transgender athletes, regardless of puberty blockers or hormone use. The Court further held that the Equal Protection Clause does not bar states from limiting female sports teams to biological females, finding the sex-based classification substantially related to important government interests in safety and competitive fairness. The cases were remanded for further proceedings consistent with this opinion. View "West Virginia v. B. P. J." on Justia Law

Fischer v. Southeast Community College

2026-06-26T05:08:04-08:00

Two individuals—a student enrolled in a nursing program and a prospective paramedic student—challenged a community college’s policy requiring proof of COVID-19 vaccination for participation in certain clinical programs. The student alleged she was removed from the nursing program after failing to provide proof of vaccination and not receiving a clear response to her request for a medical exemption. She also claimed that the college placed her in clinical rotations at facilities with strict vaccination requirements, while other students were placed at locations accommodating the unvaccinated. The prospective paramedic student did not complete the vaccination requirement, did not seek an exemption, and was told that proof of vaccination or a successful exemption was necessary for acceptance. The District Court for Lancaster County allowed amendment of the initial complaint, but ultimately dismissed the amended complaint for lack of subject matter jurisdiction and failure to state a claim. The court found that the contract and negligence claims were barred by sovereign immunity, that the due process and equal protection claims lacked sufficient factual allegations to proceed, and that the “ultra vires” claim was not cognizable. The court denied further leave to amend, finding amendment would be futile. A timely postjudgment motion to alter or amend was denied, and the plaintiffs appealed. The Nebraska Supreme Court, after reviewing for plain error due to briefing deficiencies, found no plain error in the lower court’s dismissal of the case. The Court concluded that the district court properly dismissed all claims and that the appeal was timely. The Supreme Court affirmed the judgment of the district court. View "Fischer v. Southeast Community College" on Justia Law

E.W. v. The Board of Education of East St. Louis School District No.189

2026-06-25T07:06:05-08:00

Two elementary school students attending a private school in East St. Louis, whose homes are more than 1½ miles from their school and located along a public school bus route, sought to compel the local public school district to provide them with bus transportation. Previously, the district had provided this service, but stopped due to a shortage of bus drivers. The students’ parents argued that the district’s refusal to transport their children violated a state law requiring districts to provide transportation to nonpublic school students under certain conditions. The Circuit Court of St. Clair County granted summary judgment in favor of the school district, concluding that the relevant section of the Illinois School Code only required the district to provide transportation for nonpublic schoolchildren along its existing regular bus routes, and did not require the district to modify or create new routes to accommodate these students. The court found that the plaintiffs had not identified an existing route they could use. On appeal, the Illinois Appellate Court reversed, holding that the statute required the district to treat qualifying nonpublic schoolchildren the same as public schoolchildren, including modifying routes if necessary to provide transportation to and from their school. The Supreme Court of the State of Illinois reviewed the case and reversed the appellate court’s decision. The court held that, under section 29-4 of the School Code, a local school district’s obligation to provide transportation to nonpublic schoolchildren living at least 1½ miles from their school is limited to points along the district’s existing regular bus routes. The statute does not require the district to modify its routes or establish separate routes to serve nonpublic school students. The Supreme Court affirmed the circuit court’s grant of summary judgment in favor of the district. View "E.W. v. The Board of Education of East St. Louis School District No.189" on Justia Law

C. W. v. Smith

2026-06-17T12:31:49-08:00

A male freshman football player at a public high school in Alabama was subjected to repeated acts of harassment by older teammates, including physical and verbal abuse with sexual overtones and an attempted sexual assault known as “keying,” where a car key is forced into a player’s anus. The harassment was meant to emasculate him and included slurs and other conduct suggesting hostility toward his perceived failure to conform to masculine stereotypes. The student reported these incidents to school officials, including the head coach, but the school’s response was minimal and did not stop the harassment. The student ultimately transferred to a different school as a result. Afterward, the student, through his representative, sued the school district and the head coach in the United States District Court for the Northern District of Alabama. He alleged violations of Title IX and the Equal Protection Clause, as well as state tort claims. The district court dismissed the federal claims, concluding that the harassment was motivated by anti-freshman bias rather than sex, that the conduct did not qualify as actionable same-sex sexual harassment under Title IX or the Equal Protection Clause, and that the coach was entitled to qualified immunity. The court declined to exercise supplemental jurisdiction over the state claims. The United States Court of Appeals for the Eleventh Circuit reviewed the dismissal de novo. It held that the student plausibly alleged sex-based harassment actionable under Title IX and the Equal Protection Clause because the alleged conduct targeted him for failing to conform to sex stereotypes and involved inherently sexual acts. The court concluded that the allegations supported a finding of deliberate indifference by the school district and the coach and that the coach was not entitled to qualified immunity. The Eleventh Circuit vacated the district court’s dismissal and remanded for further proceedings. View "C. W. v. Smith" on Justia Law

Boddy v. Grech

2026-06-10T12:30:37-08:00

At a school board meeting in Xenia, Ohio, a member of the public sought to use her allotted time during the public comment period to criticize the school district’s handling of alleged critical race theory instruction, as well as the conduct of the superintendent and board. Although her remarks were calmly delivered, board president Mary Grech interrupted her, threatened to cut her microphone, and eventually did so, recessing the meeting amid disruptions from the audience. The speaker was not permitted to complete her five-minute comment, nor was she allowed additional time after the meeting resumed. The individual who was silenced brought a lawsuit against the school board and its president under 42 U.S.C. § 1983, arguing that her First Amendment rights were violated. She sought a preliminary injunction to prevent enforcement of the board’s public comment policy against her in the future. The United States District Court for the Southern District of Ohio conducted a hearing and denied the request for a preliminary injunction. The court concluded that the plaintiff had not demonstrated a strong likelihood of success on the merits or irreparable harm, and found the facts and motives for the board president’s actions to be equivocal. The United States Court of Appeals for the Sixth Circuit reviewed the matter and reversed the district court’s denial of the preliminary injunction. The appellate court held that the plaintiff’s speech—critical of school officials—was protected by the First Amendment and did not fall into any unprotected category. The court found that the board president engaged in impermissible viewpoint discrimination by curtailing speech because of its critical content, and also ratified a heckler’s veto by silencing the speaker rather than the disruptive audience. The Sixth Circuit concluded that the plaintiff demonstrated a strong likelihood of success on the merits and that irreparable harm to constitutional rights was presumed. The case was remanded with instructions to grant the preliminary injunction. View "Boddy v. Grech" on Justia Law

Herbert v. St. James Parish School Bd

2026-06-02T15:31:46-08:00

A mother sought to enroll her disabled child, D.H., in a public Montessori academy operated by a school board in St. James Parish, Louisiana. The school board’s policy required both the child and parent to reside in the parish for enrollment eligibility. Although the mother initially provided an affidavit stating both she and D.H. lived in St. James Parish, it was later discovered that she resided in neighboring St. John the Baptist Parish. After confirming this, the school board disenrolled D.H., citing violation of its residency requirement. The mother filed administrative requests with the Louisiana Department of Education, seeking a due process hearing, a “stay-put” order to keep D.H. enrolled during proceedings, and an independent educational evaluation. The administrative law judge granted a temporary stay-put order but, after an evidentiary hearing, determined D.H. was not a resident of St. James Parish and dismissed the case for lack of subject-matter jurisdiction. The mother then brought suit in the United States District Court for the Eastern District of Louisiana, alleging violations of the Individuals with Disabilities Education Act (IDEA), the Rehabilitation Act, and the Americans with Disabilities Act (ADA), and requested reversal of the residency finding, reinstatement of the stay-put order, and compensatory education. The district court denied her preliminary injunction, dismissed her claims with prejudice, and held that she failed to state a claim upon which relief could be granted. On appeal, the United States Court of Appeals for the Fifth Circuit affirmed the district court’s judgment. The Fifth Circuit held that the school board was not obligated to provide a free appropriate public education (FAPE) to D.H. because residency was an essential eligibility requirement under both Louisiana and federal law. The court also found that the mother’s claims of disability discrimination and requests for equitable remedies lacked sufficient factual support. View "Herbert v. St. James Parish School Bd" on Justia Law

Solas v. South Kingstown School Committee

2026-05-29T07:35:18-08:00

A school committee in a Rhode Island town responded to community members’ concerns about racial inequity in district policies and staff diversity by voting to create an advisory group, later called the BIPOC Advisory Board. This Board was facilitated by a third-party organization under contract with the committee, with meetings initially open only to those identifying as BIPOC. The Board’s role was to discuss and make suggestions about district policies, which it conveyed to a policy sub-committee that, in turn, could submit proposals to the school committee. The Board had no authority to make binding decisions or directly implement policy changes. The school committee funded the facilitation of the meetings but did not compensate Board members. After being denied access to Board meetings, a plaintiff filed a complaint with the Rhode Island Office of the Attorney General, arguing that the Board was a public body subject to the Open Meetings Act (OMA). The Attorney General found that the Board was not a public body under the OMA. The plaintiff then filed suit in the Providence County Superior Court, seeking declaratory relief. The Superior Court denied the plaintiff’s motion for summary judgment and granted summary judgment to the school committee, finding that the Board was not a public body under the OMA. The court reasoned that the Board had no voting or veto power and that the policy review process provided public opportunities for input. On appeal, the Supreme Court of Rhode Island affirmed the Superior Court’s judgment. The Court held that the Board was not a public body subject to the OMA because it was an amorphous, ad hoc advocacy group without authority to make or veto policy decisions. The Court emphasized that the Board’s informal structure, lack of consistent membership, and merely advisory role did not trigger open meetings requirements under Rhode Island law. View "Solas v. South Kingstown School Committee" on Justia Law

Sabatini v. Knouse

2026-05-20T04:04:19-08:00

A laboratory director at the Whitehead Institute for Biomedical Research and a tenured professor at MIT met a graduate student who later became a fellow at Whitehead. During her academic progression, the professor made sexualized comments to her and later engaged in a sexual relationship with her, which she felt unable to end due to his influence over her career. After the relationship ended, he continued making inappropriate comments. A culture survey at Whitehead suggested that he fostered or participated in sexually explicit and inappropriate discussions and threatened those who reported his conduct. An independent investigation found he had violated Whitehead policies, including its sexual harassment policy, leading to his resignation and MIT placing him on leave. While MIT’s investigation was ongoing, the professor sued the student, Whitehead, and its director for defamation and other claims. The student filed a counterclaim against the professor for sexual harassment under the Massachusetts sexual harassment statute (G. L. c. 214, § 1C). The Superior Court dismissed this counterclaim, holding that the statute did not permit claims against individuals, only institutions. The Appeals Court affirmed, reasoning the statute only applied to educational institutions. The Supreme Judicial Court of Massachusetts granted further appellate review and considered whether the sexual harassment statute permits claims against individual perpetrators in the academic context. The court held that the statute does allow such claims, noting its plain language and remedial purpose. The court reversed the Superior Court’s dismissal of the counterclaim and remanded for further proceedings, explicitly holding that victims of sexual harassment in academic settings may bring actions against individual harassers under the statute. View "Sabatini v. Knouse" on Justia Law

J.M. v. Illuminate Education, Inc.

2026-05-14T08:32:09-08:00

An educational technology company was contracted by a county office of education to provide software and technology services to school districts, which involved collecting and storing various types of student data, including medical information. In 2022, the company experienced a data breach that resulted in unauthorized access to student medical records, including those of a minor plaintiff. The minor, through a guardian, filed a class action lawsuit alleging violations of both the Confidentiality of Medical Information Act (CMIA) and the Customer Records Act (CRA), claiming the company was negligent in protecting confidential medical information and failed to provide timely disclosure of the breach. The Superior Court of Ventura County granted the company’s demurrer and dismissed the case, concluding that the plaintiff failed to state a claim under either statute, as the company was not a covered entity under the CMIA or CRA and the plaintiff was not a “customer” under the CRA. The California Court of Appeal, Second Appellate District, Division Six, reversed, finding that the company fell within the scope of both statutes and that the plaintiff had alleged sufficient facts to support both claims. The appellate court also determined that the trial court erred by denying leave to amend the complaint. The Supreme Court of California reversed the appellate decision. The Court held that the plaintiff did not sufficiently allege the company was a “provider of health care” under the CMIA, nor that he was the company’s “customer” under the CRA, so no claim was stated under either statute. However, the Court clarified that under the CMIA, a breach of confidentiality occurs when medical information is exposed to a significant risk of unauthorized access or use, and actual viewing by an unauthorized party is not required. The judgment was reversed and remanded for further proceedings. View "J.M. v. Illuminate Education, Inc." on Justia Law

Degenfelder v. Wyoming Education Association

2026-05-14T07:12:57-08:00

The Wyoming legislature enacted the Steamboat Legacy Scholarship Act in 2025, creating an education savings account (ESA) program. This program allows parents of eligible Wyoming school-aged children to apply for up to $7,000 annually to fund education expenses outside the public school system. The ESAs are funded from a state general fund appropriation, not from local or school district taxes. Plaintiffs, including the Wyoming Education Association (WEA) and several individual parents, challenged the Act’s constitutionality, claiming it violated provisions of the Wyoming Constitution related to public education and state appropriations. The plaintiffs argued that the Act would harm their children, particularly those with disabilities, because private schools receiving ESA funds could deny admission or fail to provide needed services. The District Court of Laramie County granted a preliminary injunction, preventing implementation and funding of the ESA program while the lawsuit proceeded. The district court found that the plaintiffs were likely to succeed on the merits of their constitutional claims and that they would suffer irreparable injury if funds were distributed under the Act. The court reasoned that the Act likely violated constitutional limitations on appropriations for educational purposes to entities not under state control, and infringed upon the fundamental right to education by diverting funds from the public system. On appeal, the Supreme Court of Wyoming reviewed the district court’s decision for abuse of discretion. The Supreme Court held that the plaintiffs had not made a clear showing of possible irreparable, personal injury required for preliminary injunctive relief, as they did not intend to participate in the ESA program and their alleged harms were speculative. The court also questioned the district court’s legal analysis but did not decide the case on the merits. The Supreme Court of Wyoming reversed the preliminary injunction and remanded the case for further proceedings. View "Degenfelder v. Wyoming Education Association" on Justia Law

Ibrahim Alzandani v. Hamtramck Public Schools

2026-05-12T13:00:34-08:00

Three Michigan parents alleged that a local public school district systematically denied their children access to special education services required by federal law. One child with autism reportedly received only a few hours of aide support each day, another autistic child was promised speech therapy that was not provided, and a third child with Down syndrome was allegedly denied evaluation and services altogether. In response, two parents filed complaints with the Michigan Department of Education, which found that the school district violated the children’s rights to a free and appropriate public education under the Individuals with Disabilities Education Act (IDEA) and issued corrective action plans. However, none of the parents pursued the IDEA’s due process complaint process. The parents and children instead filed a class action in the United States District Court for the Eastern District of Michigan against the school district, Wayne County Regional Educational Service Agency, and the Michigan Department of Education. They alleged violations of the IDEA, Americans with Disabilities Act, Rehabilitation Act, and Michigan law, seeking injunctive relief and damages. The defendants moved to dismiss, arguing the plaintiffs failed to exhaust IDEA administrative remedies. The district court denied the motion, holding that exhaustion was not required for “systemic” failures, and certified the issue for interlocutory appeal. The United States Court of Appeals for the Sixth Circuit reviewed the appeal and held that the IDEA does not recognize a “systemic violations” exception to its exhaustion requirement. The court ruled that parents must pursue the IDEA’s due process hearing before filing suit, even in cases alleging district-wide failures related to staffing and funding. The court concluded that none of the recognized exceptions to exhaustion applied and reversed the district court’s decision, foreclosing the lawsuit until administrative remedies are exhausted. View "Ibrahim Alzandani v. Hamtramck Public Schools" on Justia Law

FORD v. THE OKLAHOMA STATE DEPARTMENT OF EDUCATION

2026-05-12T06:49:39-08:00

A group of plaintiffs challenged the Oklahoma State Board of Education’s adoption of the 2025 Social Studies Standards, arguing the standards were improperly enacted and violated statutory and constitutional rights, including compelled viewpoint-specific speech in public education. After the Board approved the standards, the plaintiffs sought declaratory and injunctive relief to prevent their implementation, claiming both procedural errors in their adoption and substantive harms to students, parents, and teachers. The District Court for Oklahoma County heard the case and granted the defendants’ motions to dismiss, determining that the plaintiffs were unlikely to succeed and that their claims about the Oklahoma Administrative Code were incorrect. The District Court also denied the plaintiffs’ request for a preliminary injunction. The plaintiffs appealed, raising issues about administrative procedures, standing, and the denial of an opportunity to amend their petition. While the appeal was pending, the Oklahoma Supreme Court in Randall v. Fields, 2025 OK 91, held that the 2025 Social Studies Standards could not be enforced due to violations of the Oklahoma Open Meeting Act, rendering the standards void. In light of this, the Supreme Court of the State of Oklahoma determined that the plaintiffs’ claims for relief were now moot because the challenged standards no longer existed. The Court found that neither the “broad public interest” nor “capable of repetition yet evading review” exceptions to mootness applied. Accordingly, the Supreme Court dismissed the appeal as moot, reversed the District Court’s judgment, and directed the lower court to dismiss the plaintiffs’ petition without prejudice due to mootness. View "FORD v. THE OKLAHOMA STATE DEPARTMENT OF EDUCATION" on Justia Law

N. T. v Galesburg Community Unit School District No. 205

2026-05-06T12:30:40-08:00

A young elementary school student with disabilities was placed by agreement of his parents and local school district in a special education classroom at his neighborhood school due to behavioral struggles. Three weeks after this placement, the school district proposed an Individualized Education Plan (IEP) that would move the student to a private therapeutic day school in another district, requiring lengthy daily bus rides and removing him from his local environment and peers. The parents objected, believing that this more restrictive placement violated their son’s rights under the Individuals with Disabilities Education Act (IDEA), and requested a due process hearing. An independent hearing officer conducted several days of hearings and found in favor of the school district, concluding that the district had complied with the IDEA and that the proposed placement at the therapeutic day school was appropriate. The parents then sought judicial review in the United States District Court for the Central District of Illinois. At a bench trial, the district court considered new evidence, including testimony about the student's progress and potential benefits of additional supports in his current classroom. The district court found that the student had made significant progress and would benefit from a one-on-one aide, and concluded that the school district’s proposed placement would violate his right to an education in the least restrictive environment under the IDEA. On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the district court's decision for clear error, giving due weight to the administrative record but acknowledging the significance of new evidence introduced at trial. The Seventh Circuit held that the district court did not make mistakes of law or clearly err in finding that the student could receive a satisfactory education in his local special education classroom with additional supports, and affirmed the district court’s order requiring the school district to create an appropriate IEP for that placement. View "N. T. v Galesburg Community Unit School District No. 205" on Justia Law

Smith v. Albany County School District No. 1

2026-05-04T08:33:07-08:00

A high school student in Wyoming was repeatedly suspended and eventually arrested for refusing to comply with her school district’s indoor mask mandate, which was implemented during a local COVID-19 surge. The student and her parents sued the school district, various trustees, the superintendent, and the principal, alleging violations of their federal and state rights. Their federal claims asserted that the mask mandate compelled speech and resulted in unlawful retaliation against the student for protesting, both under the First Amendment, and that she was deprived of her property interest in a public education without due process, in violation of the Fourteenth Amendment. The case was initially filed in Wyoming state court and then removed to the United States District Court for the District of Wyoming. That court first dismissed the federal claims for lack of standing, but the United States Court of Appeals for the Tenth Circuit reversed, finding that the plaintiffs had alleged sufficient injury. On remand, the district court dismissed the federal claims for failure to state a claim and declined to exercise jurisdiction over the supplemental state-law claims. On appeal, the United States Court of Appeals for the Tenth Circuit affirmed the district court’s dismissal. The Tenth Circuit held that the plaintiffs did not adequately allege that the mask mandate compelled any specific message and thus failed to state a compelled-speech claim. The court also found that the student’s refusal to wear a mask was not expressive conduct protected by the First Amendment and that her participation in protest activities was not plausibly alleged to be the but-for cause of her discipline, defeating the retaliation claim. Regarding due process, the Tenth Circuit ruled that the student received sufficient notice and opportunity to be heard before her suspensions, satisfying procedural due process. The court also concluded that no substantive due process violation occurred. Finally, the Tenth Circuit found no abuse of discretion in the district court’s decision to dismiss the state-law claims. View "Smith v. Albany County School District No. 1" on Justia Law

WEBB CONSOLIDATED INDEPENDENT SCHOOL DISTRICT v. MARSHALL

2026-04-24T06:22:46-08:00

Two former school-board members of the Webb Consolidated Independent School District requested information from the district related to agenda items for an upcoming board meeting. When the district failed to provide this information, the board members sued the district under Texas Education Code Section 11.1512, seeking injunctive relief and attorney’s fees. The trial court granted a temporary injunction ordering the district to turn over specific documents. The district did not appeal this order. Before the case could proceed to trial, both members’ terms expired. Following the injunction, the plaintiffs amended their claims to address additional document requests and participated in a related administrative proceeding concerning their censure by the board. The Texas Commissioner of Education dismissed one of their claims for lack of jurisdiction. The district then moved to dismiss the lawsuit, arguing that the board members were no longer entitled to the information, that the members failed to exhaust administrative remedies, and that some claims were moot. The trial court denied the district’s motions, and the district appealed. The Court of Appeals for the Fourth District of Texas found that the claims for information were moot but held that the request for attorney’s fees remained live because the board members had obtained a temporary injunction. The Supreme Court of Texas reviewed the case and held that, in this specific statutory scheme, obtaining an injunction under Section 11.1512 ordering the district to produce information conferred prevailing-party status on the board members, entitling them to reasonable attorney’s fees for that portion of the case, even though the case was mooted before final judgment. The court also held that exhaustion of administrative remedies was not required before seeking injunctive relief under this statute. The court affirmed the court of appeals’ judgment and remanded for a determination of reasonable, recoverable attorney’s fees. View "WEBB CONSOLIDATED INDEPENDENT SCHOOL DISTRICT v. MARSHALL" on Justia Law

Hert v. MHSA

2026-04-22T18:18:30-08:00

A high school student attended Colstrip High School, participating in extracurricular activities, including basketball, until academic difficulties during the COVID-19 pandemic led him to repeat his sophomore year. His family consulted with the school’s athletic director, who suggested, but did not confirm, that he would be eligible to play basketball as a fifth-year senior. After repeating a grade, the student regained academic eligibility and continued to play basketball. However, before his fifth year, the school principal informed the student he would be ineligible to participate under the Montana High School Association’s (MHSA) “Semester Rule,” which limits eligibility to four consecutive years after entering ninth grade. The student’s family appealed to the MHSA Executive Board for a waiver, but the Board denied the request without providing written reasons directly to the family. The family filed suit in the Sixteenth Judicial District Court, seeking judicial review and declaratory and injunctive relief, arguing that the MHSA’s actions deprived the student of his constitutional right to participate in extracurricular activities and violated due process. The District Court denied their motion for a preliminary injunction, finding no constitutional right to participate in extracurricular sports, and later granted summary judgment to the MHSA, concluding the case was moot after the student’s graduation and the season’s end. The Supreme Court of the State of Montana reviewed the case. It held that the matter was not moot under the public interest exception to mootness, given the recurring nature and public importance of MHSA eligibility determinations. The Court reversed the District Court’s summary judgment, holding that Montana students have a constitutionally protected interest in participating in offered extracurricular activities and that the MHSA failed to provide constitutionally sufficient due process. The Supreme Court remanded the case for entry of declaratory relief, specifying that due process requires notice, a meaningful opportunity to be heard, and a written decision sufficient for judicial review. View "Hert v. MHSA" on Justia Law

J. R. V. VENTURA UNIFIED SCHOOL DISTRICT

2026-04-22T09:06:00-08:00

A child attended the Ventura Unified School District from 2012 to 2021. During this time, the district performed several psychoeducational assessments, identifying the child as having a specific learning disability but failing to assess for autism. The child’s parents, aware of his persistent academic and behavioral struggles, repeatedly collaborated with the district, sought private assessments, and requested additional services, which were denied. The child was ultimately diagnosed with autism in 2021, after which the parents initiated legal action seeking remedies for allegedly inadequate education dating back to 2012. After the parents filed a due process complaint in 2021, an Administrative Law Judge concluded that claims for services before April 8, 2019, were time-barred under the Individuals with Disabilities Education Act’s (IDEA) two-year statute of limitations, finding the parents knew or should have known of the district’s failure to assess for autism and of the child’s inadequate education before that date. The ALJ awarded relief only for the period after April 8, 2019. The parents then sought further review in the United States District Court for the Central District of California, which reversed the ALJ. The district court held that the statute of limitations did not begin until the autism diagnosis in 2021, reasoning the parents lacked the requisite knowledge to challenge the district’s actions earlier. The court also found both statutory exceptions to the limitations period applied and awarded remedies for the 2012–2019 period. The United States Court of Appeals for the Ninth Circuit reversed the district court. The court held that the IDEA’s two-year statute of limitations begins when parents knew or should have known both of the district’s action or inaction and that their child was being denied a free appropriate public education. It concluded that the parents’ claims for pre-2019 educational services were untimely. The appellate court vacated the district court’s remedial orders and remanded for further proceedings regarding attorneys’ fees. View "J. R. V. VENTURA UNIFIED SCHOOL DISTRICT" on Justia Law

Nathan v. Alamo Heights ISD

2026-04-21T21:01:07-08:00

A group of parents and religious leaders in Texas, representing a diversity of religious beliefs, challenged the enactment of a Texas law (S.B. 10) requiring public elementary and secondary schools to display a large poster of the Ten Commandments in every classroom. The law specified the text, size, and location of the display, allowed for both private donations and district-purchased displays, and was set to go into effect in September 2025. The plaintiffs argued that being compelled to send their children to schools with such displays violated the Establishment Clause by effectively endorsing religion, and the Free Exercise Clause by undermining their rights to direct their children’s religious upbringing and coercing their children to honor or revere the Commandments. The case was originally heard in the United States District Court for the Western District of Texas. After a hearing, the district court denied the school districts’ motion to dismiss and granted a preliminary injunction, blocking enforcement of S.B. 10. The court held the law unconstitutional under both the Establishment Clause—applying the “secular purpose” prong from Stone v. Graham and Lemon v. Kurtzman—and the Free Exercise Clause, finding that the law likely coerced religious observance and interfered with parental rights. The court’s opinion was also influenced by a since-vacated Fifth Circuit panel decision in a related Louisiana case. On appeal, the United States Court of Appeals for the Fifth Circuit, sitting en banc, held that S.B. 10 did not violate either the Establishment or Free Exercise Clause. The court concluded that Stone and Lemon no longer apply; the proper inquiry is whether the law bears hallmarks of a founding-era religious establishment, such as compelled worship, religious taxes, or government control over doctrine. The court found S.B. 10 lacked these features and that mere display of religious text did not amount to unconstitutional coercion. The court reversed the district court’s judgment, vacated the injunction, and dismissed all claims. View "Nathan v. Alamo Heights ISD" on Justia Law

Smiley v. Jenner

2026-04-21T07:30:40-08:00

A teacher in Indiana, who was preparing to begin teaching grades 1–3, filed a lawsuit challenging a new state statute that prohibits public schools and teachers from providing “instruction” on “human sexuality” to students in prekindergarten through third grade. While the law allows teachers to answer students’ questions and to teach academic subjects and child abuse prevention, it does not define the key terms “instruction” or “human sexuality.” The teacher argued that the statute would chill or restrict her protected speech, such as including certain books in her classroom library, displaying pro-LGBTQ+ stickers, and addressing students’ use of pejorative language related to sexual identity. She also claimed the law is unconstitutionally vague, fearing she might inadvertently violate it and risk losing her teaching license. The United States District Court for the Southern District of Indiana denied her request for a preliminary injunction. The district court concluded that the teacher had not shown a likelihood of success on the merits of her First Amendment and Fourteenth Amendment claims. The court reasoned that most of the speech affected by the statute—classroom instruction and related communications—was official speech not protected by the First Amendment, and that any protected speech affected was not substantial enough to make the law overbroad. It also found that the terms “instruction” and “human sexuality” had a discernible core of meaning, so the law was not unconstitutionally vague. The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s decision. The Seventh Circuit held that the teacher had not demonstrated that the statute prohibits a substantial amount of protected speech or is impermissibly vague. The court concluded that any ambiguity at the margins does not render the statute facially invalid and emphasized that challenges to specific applications of the law could be brought in the future if necessary. View "Smiley v. Jenner" on Justia Law

State v. Bunag

2026-04-20T12:11:20-08:00

A substitute teacher sexually assaulted a thirteen-year-old student on multiple occasions in a classroom, recorded at least two of the assaults, and shared one of the videos with adults in an online chatroom. The Federal Bureau of Investigation found child pornography on his phone and evidence of further distribution. The student confirmed multiple instances of abuse, which significantly impacted his mental health. The teacher was subsequently federally prosecuted and sentenced to seventeen and a half years for production of child pornography. In parallel state proceedings, he was indicted on several charges, pled guilty to three, and was sentenced to an aggregate thirty years in prison, with some terms ordered to run consecutively and concurrently. In the Circuit Court of the First Circuit, the court granted the State’s oral motion for consecutive sentences at sentencing but provided only a brief, generalized rationale focused on the teacher-student relationship and harm to the victim. It did not address the distinct nature of the offenses or provide a detailed explanation for departing from the presumptive concurrent sentencing. After the defendant appealed, the court issued a written order—drafted by the prosecution and adopted verbatim—offering a more comprehensive justification for the consecutive sentences. The Intermediate Court of Appeals (ICA) affirmed the sentence, relying heavily on this post-sentencing written order. The Supreme Court of the State of Hawai‘i vacated the ICA’s judgment and the portion of the circuit court’s sentence imposing consecutive terms. The court held that a sentencing court must state its reasons for imposing consecutive sentences on the record at the time of sentencing, not in a later written order, and must not simply adopt the prosecutor’s arguments. The case was remanded to the circuit court for resentencing. View "State v. Bunag" on Justia Law

Cleare v. Super. Ct.

2026-04-17T08:31:34-08:00

A group of teachers working in schools with persistent teacher vacancies filed administrative complaints asserting that their school district was unlawfully using long-term and rotating substitute teachers to cover these vacancies instead of pursuing all available legal avenues to staff classrooms with permanent, credentialed teachers. The affected schools served high-poverty communities and had challenges recruiting and retaining qualified teachers. The teachers alleged that the district failed to implement sufficient processes for recruiting, hiring, and supporting permanent teachers, and did not fully utilize statutory options or support programs to address the shortages. After the district responded to the complaints by acknowledging its noncompliance but attributing it to an inability to hire enough qualified teachers, the teachers sought judicial relief in the Superior Court of Contra Costa County. They requested a writ of mandate to compel the district to alter its staffing practices and comply with all legal requirements. The district argued that it was impossible to comply due to persistent teacher shortages, and the trial court denied the petition, finding the district was making good-faith efforts to fill vacancies. On review, the Court of Appeal of the State of California, First Appellate District, Division Two, determined that the trial court erred by accepting the district’s impossibility defense without first requiring the district to demonstrate that it had exhausted all statutory alternatives, including seeking waivers from the Commission on Teacher Credentialing and the State Board of Education. The appellate court held that the doctrine of impossibility was not available unless the district showed it had pursued all available options without success. The court ordered issuance of a peremptory writ of mandate directing the trial court to vacate its prior order and reconsider the petition consistent with this ruling. View "Cleare v. Super. Ct." on Justia Law

Female Athletes United v. Keith Ellison

2026-04-15T07:30:56-08:00

A high school student, who is a transgender girl but was assigned male at birth, played on a varsity girls’ softball team in Minnesota under a 2016 state athletic bylaw permitting students to participate in sporting activities consistent with their gender identity. Female Athletes United (FAU), an organization advocating for women’s sports, sued Minnesota officials and local school boards, alleging that permitting the student’s participation violated the rights of its members under Title IX by denying them effective accommodation and equal treatment. FAU claimed its members suffered various harms, such as lost athletic opportunities and emotional distress, and sought a preliminary injunction to prohibit “male athletes” from competing against its members in girls’ sports involving contact or competitive skill. The United States District Court for the District of Minnesota found that FAU had standing because one member’s team was scheduled to play against the transgender athlete’s team. However, the district court denied the preliminary injunction on two grounds: first, that FAU lacked a private right of action for its Title IX claims, because they were based on a disparate impact (rather than intentional discrimination) theory, and second, that FAU failed to satisfy the requirements for preliminary injunctive relief. On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the district court’s decision. The appellate court agreed that, under Title IX and controlling Supreme Court precedents, there is only a private right of action for claims of intentional discrimination, not for disparate impact. It found FAU’s claims were based on allegations of negative effects rather than intentional disparate treatment or deliberate indifference. The court concluded that FAU’s allegations did not support a claim of intentional discrimination. Thus, the Eighth Circuit affirmed the denial of the preliminary injunction, holding that FAU lacked a private right of action for its Title IX claims. View "Female Athletes United v. Keith Ellison" on Justia Law

Walton v. Victor Valley Community College District

2026-04-15T07:10:11-08:00

A nursing student was required to complete clinical rotations at local hospitals as part of her coursework in 2017. She alleged that her supervisor, the director of the nursing program, subjected her to severe sexual harassment and retaliated against her when she rejected his advances by giving her a failing grade and refusing to discuss it. After the student reported these incidents, the district placed the supervisor on administrative leave and initiated an independent investigation. The investigation confirmed inappropriate conduct by the supervisor, who did not return to his position. The student later withdrew from the program and completed her degree out of state. Through counsel, she notified the district of her intent to pursue claims and sought damages. The Superior Court of San Bernardino County granted summary judgment for the community college district, holding that the student lacked standing under the Fair Employment and Housing Act (FEHA), failed to comply with the Government Claims Act for her non-FEHA claims, and that the district was not deliberately indifferent under the Education Code. The court also excluded the student’s attorney’s declaration due to a technical omission, and entered judgment for the district on all claims. The California Court of Appeal, Fourth Appellate District, Division Three, reversed the judgment. The court found the trial court abused its discretion by refusing to allow the attorney’s declaration to be corrected, which was a curable procedural defect. The appellate court held that a postsecondary student serving in a clinical capacity qualifies as an “unpaid intern” under FEHA, conferring standing. The court further found the student’s notice to the district satisfied the Government Claims Act requirements, and concluded that triable issues existed regarding whether the district acted with deliberate indifference. The court affirmed summary adjudication for the district only on the Civil Code cause of action, but otherwise denied summary judgment and remanded for further proceedings. View "Walton v. Victor Valley Community College District" on Justia Law

Doe v University of Southern Indiana

2026-04-13T12:33:57-08:00

A former student at the University of Southern Indiana was accused of sexual assault during the 2020–21 academic year. After a hearing, a university panel found the alleged victim’s account more credible than the student’s, noting her consistency over time, and concluded that the student committed rape and forcible fondling. The student was suspended for three semesters and did not return to the university. He subsequently filed a lawsuit against the university and other defendants, alleging sex discrimination in violation of Title IX, deprivation of due process, and intentional infliction of emotional distress. During discovery, the student learned of undisclosed records that suggested his account may have been consistent over time, contrary to the panel’s finding. The United States District Court for the Southern District of Indiana granted summary judgment to the defendants on all claims. In the course of the litigation, a magistrate judge ordered the student to proceed using his real name, not a pseudonym. The student objected, but the district judge overruled the objection, though the district court stayed its order pending this appeal. The student filed multiple appeals, which were consolidated for argument. The United States Court of Appeals for the Seventh Circuit reviewed whether the district court abused its discretion by denying the student’s use of a pseudonym. The court reaffirmed the strong presumption that adult parties litigate under their real names in federal court and found that the student did not present sufficient evidence of a substantial risk of physical harm or retaliation to justify use of a pseudonym. The court declined to broaden the standard to include mental health risks or to consider the merits of the underlying claims in deciding the pseudonym issue. The Seventh Circuit affirmed the district court’s order. View "Doe v University of Southern Indiana" on Justia Law

O.W. v. Carr

2026-04-09T11:00:26-08:00

A 13-year-old male student at a Virginia Beach middle school received a sexually explicit photo from a female classmate and, several months later, showed the image to other students during the school day. After teachers reported the incident, the assistant principal removed the student from class, questioned him, and searched his phone’s photo gallery. The school resource police officer was notified and began a criminal investigation. The student ultimately showed the explicit photo to the officer, was read his Miranda rights, arrested, and charged in juvenile court with possession of child pornography. The juvenile court found sufficient evidence for guilt but deferred disposition; the charge was dismissed after the student completed court-imposed conditions. The student, through his mother and later counsel, sued the assistant principal, the school resource officer, the Virginia Beach School Board, and the City of Virginia Beach in the United States District Court for the Eastern District of Virginia. He alleged violations of his Fourth, Fifth, and Fourteenth Amendment rights, as well as conspiracy and Monell claims. The district court granted summary judgment to all defendants, finding the phone search reasonable under New Jersey v. T.L.O., the confession voluntary, no evidence of unlawful conspiracy, and no underlying constitutional violations to support Monell liability. On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the case de novo. The court affirmed the district court’s judgment, holding that the assistant principal’s search of the student’s phone was justified at its inception and reasonable in scope under T.L.O., and that Riley v. California did not displace this standard in the school context. The court also held the student’s confession was voluntary under the Fifth and Fourteenth Amendments, found no evidence of a conspiracy to violate constitutional rights, and determined Monell liability could not attach absent an underlying constitutional violation. The court therefore affirmed summary judgment for all defendants. View "O.W. v. Carr" on Justia Law

Perry v. Marteney

2026-04-08T10:30:26-08:00

A married couple, acting on behalf of their minor child, challenged West Virginia’s compulsory vaccination law after their daughter was disenrolled from a public virtual school because she was not fully vaccinated. The parents sought a religious exemption from the vaccination requirement, but were informed that only medical exemptions—based on specific medical contraindications or precautions certified by a physician—are permitted under state law. After being denied a religious exemption, the parents filed suit, claiming that the absence of a religious exemption violated their First Amendment right to freely exercise their Christian faith. They requested a preliminary injunction to allow their daughter’s re-enrollment in the virtual academy during the litigation. The United States District Court for the Northern District of West Virginia granted the preliminary injunction, finding that the parents were likely to succeed on their free exercise claim. The district court applied the test from Employment Division, Department of Human Resources of Oregon v. Smith, concluding that the vaccination law was not generally applicable, and thus subject to strict scrutiny, which it found the law did not survive. On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s grant of preliminary relief. The Fourth Circuit held that West Virginia’s compulsory vaccination law is a neutral and generally applicable measure enacted under the state’s police power to protect public health, as recognized in longstanding Supreme Court precedent including Jacobson v. Massachusetts and Prince v. Massachusetts. The court found that the medical exemption process does not constitute a “mechanism for individualized exemptions” that would undermine general applicability under cases such as Fulton v. City of Philadelphia. The Fourth Circuit concluded that the law is subject to rational basis review, which it easily satisfies, and that the Free Exercise Clause does not require religious exemptions simply because medical exemptions exist. The court reversed the district court’s preliminary injunction and remanded the case. View "Perry v. Marteney" on Justia Law

Iowa Safe Schools v. Reynolds

2026-04-06T07:01:30-08:00

Several educators, parents, students, and a nonprofit organization challenged two provisions of an Iowa law affecting public schools. The law restricts classroom instruction on gender identity and sexual orientation for students in kindergarten through sixth grade and requires school officials to notify parents if a student requests accommodations affirming their gender identity, such as using a different pronoun. The plaintiffs, asserting facial constitutional challenges, argued the provisions were overbroad and vague, infringing on First Amendment and due process rights. Previously, the United States District Court for the Southern District of Iowa granted a preliminary injunction against these provisions. The district court found that the terms “program” and “promotion” in the instruction restriction were overly broad and infringed on protected speech, and determined that the parental notification law was impermissibly vague due to the undefined use of “accommodation.” The district court severed what it considered unconstitutional portions of the statutes and enjoined their enforcement. The United States Court of Appeals for the Eighth Circuit reviewed the district court’s decision. It held that the statutes, when read with the canon of constitutional avoidance, could reasonably be interpreted in a way that avoided constitutional problems and that the statutory language was sufficiently clear. The appellate court found the plaintiffs did not demonstrate that unconstitutional applications of the laws substantially outweighed constitutional ones in their facial challenge. It further determined that the term “accommodation” was not unconstitutionally vague. The Eighth Circuit concluded that the district court abused its discretion in granting the preliminary injunction and vacated that injunction as to all challenged provisions, remanding the case for further proceedings on the merits. View "Iowa Safe Schools v. Reynolds" on Justia Law

Penguin Random House, LLC v. Robbins

2026-04-06T07:01:29-08:00

A group of plaintiffs, including publishers, authors, educators, and a parent of a student, challenged provisions of an Iowa law (Senate File 496) requiring public school libraries to remove books containing “descriptions or visual depictions of a sex act.” The law also imposed penalties on educators who failed to comply. The plaintiffs argued that these provisions violated their First Amendment rights, both as to students’ access to information and as to the right of authors and publishers to communicate with their intended audience. The United States District Court for the Southern District of Iowa initially granted a preliminary injunction, preventing enforcement of the challenged provisions. The court concluded that the plaintiffs were likely to prevail, holding that the unconstitutional applications of the law substantially outweighed constitutional ones. It declined to apply the standard set out in Hazelwood School District v. Kuhlmeier, instead relying on the obscenity standard from Ginsberg v. State of New York and the “substantial and reasonable government interest” test from the plurality in Board of Education, Island Trees Union Free School District No. 26 v. Pico. On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s decision. The Eighth Circuit held that the Hazelwood standard—whether the restrictions are “reasonably related to legitimate pedagogical concerns”—applies to school library curation. The court determined that the Iowa law’s book restrictions addressed legitimate pedagogical concerns and were neither amorphous nor unreasonable. Because the plaintiffs could not show a likelihood of success on the merits under the correct standard, the Eighth Circuit vacated the preliminary injunction and remanded the case for further proceedings on the merits. View "Penguin Random House, LLC v. Robbins" on Justia Law

Hoke Cnty. Bd. of Educ. v. State

2026-04-02T07:38:04-08:00

A group of students, their parents or guardians, and local school boards from several low-wealth and urban school districts in North Carolina brought suit against the State and the State Board of Education in 1994. They claimed that the State’s method of funding education deprived students in their districts of their constitutional right to the opportunity for a sound basic education, focusing on perceived inadequacies in the implementation and funding of the Basic Education Program (BEP) as it then existed. The plaintiffs did not allege that the statewide education system was unconstitutional on its face, but rather that it was unconstitutional as applied to their specific districts due to disparities in resource allocation. After various procedural developments, including intervention by additional parties and the dismissal of some claims, the case reached the Supreme Court of North Carolina, which previously clarified that the right at issue belonged only to students, not school boards. The Supreme Court held in Leandro v. State that the constitution guarantees every child the opportunity for a sound basic education, and remanded the case for as-applied determinations regarding whether that right was denied in the named districts. In Hoke County Board of Education v. State, the Supreme Court affirmed a trial court finding that at-risk students in Hoke County had been deprived of their right, but otherwise found the statewide education system generally constitutional as then structured. The Supreme Court remanded for further as-applied proceedings in the other named districts, but no further trials occurred. Over time, the case’s subject matter shifted, and the trial court, with the parties’ acquiescence, began addressing a statewide, facial challenge to the current education system, including ordering the implementation of a statewide remedial plan without a new or amended complaint raising such a claim. The Supreme Court of North Carolina, reviewing an order entered on 17 April 2023, held that the trial court lacked subject matter jurisdiction to adjudicate a facial challenge to the statewide education system, since no party had properly invoked jurisdiction over such a claim by amending the pleadings or following the statutory procedure. The Court vacated the trial court’s order and dismissed the action with prejudice, concluding that any orders entered after 24 July 2017, when the litigation’s nature changed, were void for lack of subject matter jurisdiction. View "Hoke Cnty. Bd. of Educ. v. State" on Justia Law

Cleare v. Super. Ct.

2026-03-27T10:09:49-08:00

Four teachers working at three schools in a public school district with high poverty and significant staffing challenges filed formal complaints under California’s “Williams Uniform Complaint Procedure.” Their complaints alleged that the district was unlawfully filling persistent teacher vacancies with rolling substitutes and failing to utilize all lawful options for recruiting and assigning permanent, authorized teachers, including credential waivers and intern programs. The district acknowledged it was out of compliance with state law but claimed it could not comply due to a systemic teacher shortage beyond its control. The teachers’ complaints were denied by the school district’s Board of Education. Subsequently, the teachers filed a petition for writ of mandate, declaratory relief, and injunctive relief in the Superior Court of Contra Costa County, seeking an order to compel compliance with statutory teacher assignment requirements. The district argued it had exercised all reasonable efforts to fill vacancies, including broad recruitment and use of alternative credential paths, but that hiring qualified teachers remained impossible. The trial court denied the writ, finding the district was not refusing to comply with the law and was doing its best under the circumstances. The Court of Appeal of the State of California, First Appellate District, Division Two, converted the appeal to an extraordinary writ proceeding due to the absence of an appealable order. The appellate court concluded that the district had not demonstrated it exhausted all statutory options for filling vacancies, such as seeking waivers from the Commission on Teacher Credentialing or the State Board of Education. The court held that unless and until the district exhausts these options, it cannot invoke the defense of impossibility. The court ordered the trial court to vacate its prior ruling and to grant the teachers’ petition for a writ of mandate. View "Cleare v. Super. Ct." on Justia Law

Mitchell v. Bering Strait School District

2026-03-27T10:01:30-08:00

A teacher employed by a school district in a remote Alaska village rented housing from the district. After the district removed a railing from the stairs of the teacher’s residence and did not repair it despite complaints, the teacher fell while taking out the trash and was injured. The teacher notified the school principal of his injury, but she declined to assist or allow him to seek medical help. There were additional conflicts between the teacher and the principal, including disciplinary actions and allegations of policy violations. The teacher later reported the principal to her supervisors and the state’s Professional Teaching Practices Commission. Following these events, the district decided not to rehire the teacher for the following school year. The teacher filed a negligence lawsuit against the district and the principal, later amending his complaint to add claims for whistleblower retaliation, wrongful termination, defamation, intentional infliction of emotional distress (IIED), and workplace safety violations. The Bering Strait School District, after being sued, reported the injury as work-related to the Alaska Workers’ Compensation Board and moved to dismiss the lawsuit, arguing that the teacher’s exclusive remedy was through workers’ compensation. The Superior Court for the Second Judicial District, Nome, dismissed the case in its entirety, concluding that the teacher failed to state a claim, and later awarded attorney’s fees to the district. The Supreme Court of the State of Alaska reviewed the case and held that, taking the teacher’s allegations as true, it was not clear that his injury was within the course and scope of his employment or that workers’ compensation was his exclusive remedy. The court reversed dismissal of the negligence, whistleblower, wrongful termination, IIED, and defamation claims, finding the complaint stated viable claims. The court affirmed dismissal of the workplace safety claim and vacated the attorney’s fees award, remanding the case for further proceedings. View "Mitchell v. Bering Strait School District" on Justia Law

AM. CIVIL LIBERTIES UNION OF NEV. VS. CLARK CNTY. SCHOOL DIST.

2026-03-26T10:07:14-08:00

A video showing a Clark County School District police officer forcefully detaining a juvenile outside a Las Vegas high school prompted public concern. The American Civil Liberties Union of Nevada requested records related to the incident from the school district. In response, the district provided only limited information, citing statutory privileges and ongoing internal investigations as grounds for withholding additional documents. The ACLU reiterated its request, seeking a detailed privilege log and specific justifications for each withheld record. After the school district produced a privilege log and maintained that certain records were exempt due to their role in an ongoing employment investigation, the ACLU filed a petition for a writ of mandamus in the Eighth Judicial District Court of Clark County. Following briefing and a hearing, the district court ordered disclosure of certain records, such as body-worn camera footage, an incident report, and a dispatch log, with redactions. However, the court held that the internal affairs investigation report and the bulk of the investigative file were confidential under Nevada law and not subject to disclosure. The ACLU appealed this ruling. The Supreme Court of the State of Nevada reviewed the case. It interpreted the Nevada Public Records Act and NRS 289.080, concluding that an internal investigative file about a peace officer is confidential and exempt from public disclosure unless the investigating agency recommends punitive action against the officer. The Court reasoned that releasing records to the public when the subject officer does not have access would be illogical and inconsistent with legislative intent. The Supreme Court of Nevada affirmed the district court’s judgment, holding that such investigative files are exempt from disclosure to the same extent that their disclosure is barred under NRS 289.080. View "AM. CIVIL LIBERTIES UNION OF NEV. VS. CLARK CNTY. SCHOOL DIST." on Justia Law

West Contra Costa Unified School Dist. v. Super. Ct.

2026-03-25T15:01:57-08:00

A group of teachers working in three schools within a California school district experienced chronic teacher vacancies, which the district addressed by employing long-term and rotating substitutes rather than permanent, qualified teachers. These schools faced heightened challenges, including high poverty rates, a large proportion of English learners, and low graduation rates. The teachers, acting under a statutory complaint procedure known as a “Williams complaint,” alleged the district’s staffing practices violated state law and demanded that the district cease its use of rolling substitutes, instead implementing processes to recruit, hire, and assign legally authorized teachers. After the district responded by acknowledging its non-compliance but claiming an inability to hire enough qualified teachers due to statewide shortages, the teachers unsuccessfully appealed to the district’s Board of Education. They then filed a petition for traditional mandate, declaratory, and injunctive relief in the Superior Court of Contra Costa County. At the hearing, the district asserted it had made all reasonable efforts to fill vacancies but was still unable to do so, and the trial court denied the writ, finding the district was not refusing to comply with the law but faced circumstances beyond its control. The California Court of Appeal, First Appellate District, Division Two, reviewed the case. The court determined that the trial court’s denial of the writ was premature and erroneous because the district had not demonstrated it had exhausted all statutory options for filling teacher vacancies, including seeking waivers from relevant state agencies. The appellate court held that the doctrine of impossibility was not available to the district until all required steps had been tried and found wanting. The court issued a peremptory writ of mandate, directing the trial court to vacate its order and denying the petition, with instructions to comply with statutory requirements. View "West Contra Costa Unified School Dist. v. Super. Ct." on Justia Law

Pechkis v. Trustees of the Cal. State University

2026-03-24T10:02:14-08:00

Two married tenured professors at California State University, Chico alleged that they were subjected to harassment and discrimination by their department chair, with one professor experiencing conduct targeted at her gender and Korean ancestry. Despite their reports to university administration, the university did not intervene. As a result, one professor suffered serious mental health consequences, leading their doctor to recommend that she not work in the same environment as the chair. The university’s lack of response allegedly forced both professors to resign and accept positions at another university. After their resignation, the university initiated an investigation into one professor for an alleged violation of student privacy laws and communicated these allegations to the new employer, which the professors claimed was intended to sabotage their new employment. There were also alleged delays in transferring their lab equipment. The professors filed suit in the Superior Court of Butte County, asserting, among other claims, retaliation and whistleblower retaliation under California law. The university filed a special motion to strike these two causes of action under California’s anti-SLAPP statute, arguing that the claims were based in part on communications protected by the statute. The trial court denied the motion, finding the university’s actions involved an official proceeding but also concluding that the professors demonstrated a likelihood of prevailing on their claims. The California Court of Appeal, Third Appellate District, reviewed the case and affirmed the trial court’s denial of the anti-SLAPP motion. The appellate court held that the university failed to carry its burden to show that all actions underlying the challenged causes of action were protected activity. The court clarified that the presence of some protected communications within the allegations does not mean the entire cause of action arises from protected activity. The judgment denying the anti-SLAPP motion was therefore affirmed. View "Pechkis v. Trustees of the Cal. State University" on Justia Law

Hellman v. Department of Elementary and Secondary Education

2026-03-20T13:30:05-08:00

The case involves parents of two children with disabilities, both of whom attend private religious schools in Massachusetts. State law entitles all students with disabilities, including those in private schools, to publicly funded special education services. However, a state regulation requires that while public school students can receive these services at their school of enrollment, private school students may only receive them at a public school or another public or neutral location. The parents, who observe Jewish law and prefer their children’s education be informed by Judaism, found it burdensome and disruptive to transport their children to and from different locations for services and chose to forgo the publicly funded services. The parents sued the Massachusetts Department of Elementary and Secondary Education, individual board members, and the commissioner in the United States District Court for the District of Massachusetts. They alleged that the regulation violated the Due Process, Equal Protection, and Privileges or Immunities Clauses of the Fourteenth Amendment by interfering with their fundamental right to direct the upbringing and education of their children. The district court dismissed the complaint for failure to state a claim under Federal Rule of Civil Procedure 12(b)(6). On appeal, the United States Court of Appeals for the First Circuit affirmed the dismissal. The Court held that while parents have a fundamental right to choose private schooling, the regulation does not restrict that right but merely defines the terms under which the state provides public benefits. The regulation does not ban or penalize private schooling or deprive meaningful access to it. Instead, it survives rational basis review because it is rationally related to the legitimate state interest of providing special education services while complying with the Massachusetts Constitution’s prohibition on aiding private schools. The court also rejected the Equal Protection and Privileges or Immunities claims. View "Hellman v. Department of Elementary and Secondary Education" on Justia Law

D.C. v. Fairfax County School Board

2026-03-19T10:30:30-08:00

Two students with disabilities, their parents, and an advocacy organization brought a lawsuit against the Virginia Department of Education and the Fairfax County School Board. The plaintiffs alleged systemic violations of the Individuals with Disabilities Education Act (IDEA), claiming that the defendants deprived eligible students of a free appropriate public education (FAPE) and failed to provide proper procedural safeguards, including fair due process hearings and impartial hearing officers. The complaint sought declaratory and injunctive relief under the IDEA, as well as constitutional claims for due process and equal protection. The United States District Court for the Eastern District of Virginia reviewed the case. It found that one student, D.C., and his parents had not exhausted IDEA's administrative remedies before filing suit, as they had not pursued a due process hearing regarding their complaints. The other student, M.B., and his parents had a separate, duplicative federal lawsuit pending that addressed the same issues, and the court dismissed their claims to avoid duplicative litigation. The advocacy organization, Hear Our Voices, Inc., was found to lack standing to sue either on behalf of its members or in its own right, as it had not identified any member with a viable claim and its alleged injury was not sufficient to confer organizational standing. On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court's rulings. The appellate court held that the exhaustion requirement of the IDEA applied to all claims, regardless of whether they were statutory or constitutional in nature and regardless of whether the claims were alleged to be systemic. It also affirmed the dismissal of duplicative claims and found the advocacy organization lacked both representational and organizational standing. The judgment of the district court was affirmed. View "D.C. v. Fairfax County School Board" on Justia Law

Foster v. King

2026-03-18T07:33:08-08:00

Dr. Lana Foster, a lifelong resident of Echols County, Georgia, was among the first Black students and later one of the first Black educators in the county’s school district. Over the years, she experienced various forms of racial discrimination, including being reassigned to a less desirable teaching position and being stripped of leadership duties, which led her to sue the school district. That lawsuit was settled in 2011, with the district agreeing to reinstate her role and pay damages. However, Foster alleged continued racial hostility, culminating in her termination in 2018. Subsequent investigations found no probable cause for her firing based on the cited ethical violations. Foster then filed complaints with state and federal agencies, resulting in another settlement in 2020 that required the district to revise its hiring practices and take additional steps to remedy discrimination. Foster later discovered, through an open records request, that the school district had not complied with the settlement's terms. She filed suit in the United States District Court for the Middle District of Georgia against the district, the school board, and several school officials, alleging violations of her rights under federal and state law, including claims under 42 U.S.C. § 1981 and § 1983 for denial of her right to make and enforce contracts based on her race. The district court dismissed some claims but allowed others to proceed, including her § 1981 claim against the individual officials, and denied their motion to dismiss based on qualified immunity. The United States Court of Appeals for the Eleventh Circuit reviewed the denial of qualified immunity. It held that the law was clearly established that government officials may not interfere with contractual rights because of race. The court concluded that uncertainty about possible personal liability under § 1981 does not entitle officials to qualified immunity. The Eleventh Circuit affirmed the district court’s decision denying qualified immunity. View "Foster v. King" on Justia Law

PAYAN V. LOS ANGELES COMMUNITY COLLEGE DISTRICT

2026-03-11T08:01:41-08:00

Two blind individuals, after enrolling at a community college in Los Angeles, were approved for disability accommodations, including accessible course materials and technology. Despite these approvals, they faced repeated barriers in accessing required textbooks, online platforms, library resources, and other educational tools. They also experienced difficulties in receiving their approved accommodations, such as accessible test-taking and note-taking support. These obstacles led to their inability to participate fully in their courses and, in one case, being steered away from certain classes due to their disability. After a jury trial in the United States District Court for the Central District of California, the jury found the college district liable on multiple counts and awarded damages for intentional violations of Title II of the Americans with Disabilities Act (ADA). The district court, however, reduced the damages to only out-of-pocket expenses, concluding that the jury’s award could only be for emotional distress or lost educational opportunities—both of which it believed were not recoverable. The district court also issued injunctive relief. The plaintiffs appealed the reduction of damages. The United States Court of Appeals for the Ninth Circuit reviewed the case. It held that, under Supreme Court precedent, emotional distress damages are not available under Title II of the ADA because the statute’s remedies are coextensive with those of the Rehabilitation Act and Title VI of the Civil Rights Act, which do not permit such damages. However, the Ninth Circuit concluded that plaintiffs may recover compensatory damages for loss of educational opportunities resulting from ADA violations. The court found that the jury’s award was supported by evidence and the instructions given. The Ninth Circuit reversed the district court’s remittitur, vacated its judgment as to damages, and remanded with instructions to reinstate the original jury awards. View "PAYAN V. LOS ANGELES COMMUNITY COLLEGE DISTRICT" on Justia Law

Simpkins v. South Orange-Maplewood School District

2026-03-11T06:07:13-08:00

Several individuals brought lawsuits against New Jersey public school districts, alleging that they were sexually abused by teachers when they were high school students. One plaintiff alleged that a science teacher sexually abused him at the teacher’s home when he was fifteen years old, and claimed the school board was vicariously liable for the abuse and had breached a fiduciary duty. Three other plaintiffs alleged that a different teacher sexually assaulted them during and after school hours, including on school property, and sought to hold the school district vicariously liable under the Child Victims Act. In the Superior Court of New Jersey, Law Division, the trial court denied the school board’s motion to dismiss the vicarious liability and fiduciary duty claims in the first case, but the Appellate Division reversed, holding the claims could not proceed. In the three consolidated cases, the trial court granted the school district’s motion to dismiss, and the Appellate Division affirmed, finding that the statute did not allow for vicarious liability for sexual abuse outside the scope of employment. The Supreme Court of New Jersey reviewed the cases. It held that the relevant provision of the Child Victims Act, N.J.S.A. 59:2-1.3(a)(1), does not categorically bar vicarious liability claims against public entities for sexual abuse by employees outside the scope of employment, and such claims should not be dismissed at the pleading stage. The Court adopted a new standard for determining such liability, requiring a fact-specific inquiry. However, it also held that a public school does not owe a fiduciary duty to a student. The Court affirmed in part and reversed in part the Appellate Division’s decision in the first case, and reversed in the three consolidated cases, remanding all matters for further proceedings under the new standard. View "Simpkins v. South Orange-Maplewood School District" on Justia Law

Doe v. Regents of the Univ. of California

2026-03-06T16:03:24-08:00

A university student faced disciplinary action after three fellow students reported separate incidents in which, while intoxicated, he allegedly engaged in nonconsensual and increasingly violent sexual conduct. Following these reports, the student was placed on interim suspension and criminally charged with multiple felonies. The criminal proceedings included a preliminary hearing where two complainants testified under oath and were rigorously cross-examined by the student’s attorney. The criminal case concluded with a plea agreement. While the criminal case was ongoing, the university initiated its own disciplinary process. This included a multi-stage investigation and hearing pursuant to university policy. At the fact-finding hearing, the complainants chose not to testify or participate. The hearing officer relied on the prior sworn testimony from the criminal proceeding and other evidence, ultimately finding the student responsible for violating university policies with respect to two complainants. The student was expelled, and his university appeal was denied. The student then sought review in Alameda County Superior Court, arguing that he was denied due process because he could not cross-examine the complainants at the university hearing and that the university’s delay prejudiced his defense. The superior court denied his petition, finding that due process was satisfied by the opportunity for cross-examination at the criminal proceeding and that the delay was justified and not prejudicial. On appeal, the California Court of Appeal, First Appellate District, Division Two, affirmed the superior court’s judgment. The court held that due process does not require live cross-examination of complainants at a university disciplinary hearing when such an opportunity was provided during prior criminal proceedings, and that any procedural delay was supported by good cause and did not result in prejudice to the student. The judgment for the university was affirmed. View "Doe v. Regents of the Univ. of California" on Justia Law

Stepp v. Lockhart

2026-03-03T11:07:53-08:00

A fifth-grade student, J.S., attended a local Oklahoma elementary school where, in August 2022, the administration implemented a policy segregating fifth-grade students into all-boys and all-girls homerooms. J.S. was placed in the boys’ class, taught by Mr. McClain. During the initial weeks, Mr. McClain allegedly targeted J.S. with severe discipline, derogatory language, and inappropriate sexual comments. After J.S. and his parents complained about this treatment and the sex-segregated policy, J.S. was removed from his classroom and placed on a modified schedule, then ultimately withdrawn from the school by his parents, who cited ongoing retaliation and lack of safety. The parents also filed a Title IX complaint, but alleged that the school’s investigation was inadequate and retaliatory actions followed, including public shaming and further mistreatment of J.S. The United States District Court for the Eastern District of Oklahoma granted in part and denied in part various defendants’ motions to dismiss, finding some claims barred by qualified immunity but allowing others to proceed. The court found that school district officials and Mr. McClain could not claim qualified immunity on certain equal protection and retaliation claims, but dismissed some due process and conspiracy claims. On appeal, the United States Court of Appeals for the Tenth Circuit reviewed the district court’s denial of qualified immunity. The Tenth Circuit held that school officials were entitled to qualified immunity on the procedural due process claim but not on the equal protection claim related to sex-based class segregation. Principal Anderson and Mr. Blair were properly denied qualified immunity on retaliation claims, while others were dismissed. Mr. McClain was granted qualified immunity on the substantive due process claim but not on the equal protection claim for alleged sexual harassment. The court affirmed in part, reversed in part, dismissed in part for lack of jurisdiction, and remanded for further proceedings. View "Stepp v. Lockhart" on Justia Law

Mirabelli v. Bonta

2026-03-03T06:15:06-08:00

Parents and teachers in California challenged state policies that require schools to keep information about students’ gender transitioning confidential from parents unless the students consent. The parents objected to being excluded from knowledge and decisions regarding their children’s gender presentation at school, especially when those actions conflicted with their religious beliefs or their desire to participate in their children’s mental health care. Several parents described situations in which they were not informed about their children’s gender identity at school until after significant mental health crises occurred. Teachers objected to being compelled to use students’ preferred names and pronouns contrary to the wishes of parents and their own beliefs. The case was initiated in the United States District Court for the Southern District of California, where two teachers first challenged district policies. As litigation unfolded, the case expanded to include state officials as defendants and parents as additional plaintiffs. The District Court certified parent and teacher classes, granted summary judgment for the plaintiffs, and entered a permanent injunction that prohibited schools from withholding information from parents and required adherence to parental directions on names and pronouns. The District Court also ordered state-created instructional materials to include notice of the rights protected by the injunction. The United States Court of Appeals for the Ninth Circuit granted a stay of the injunction pending appeal, expressing procedural concerns about class certification under Federal Rule of Civil Procedure 23 and skepticism regarding the merits of the constitutional claims. The Supreme Court of the United States vacated the Ninth Circuit’s stay as to the parent plaintiffs, concluding that the parents seeking religious exemptions are likely to succeed on their Free Exercise and Due Process claims. The Court found the parents face irreparable harm and that equities favor them. The procedural objections raised by the Ninth Circuit were deemed unlikely to prevail. The application to vacate was otherwise denied. View "Mirabelli v. Bonta" on Justia Law

Williams v. Addison Community Schools

2026-03-02T13:01:02-08:00

Scott Williams was elected to serve on the Addison Community School Board for a six-year term and was chosen by his fellow board members to act as president for one year. During his presidency, Williams had a dispute with a staff member, leading to allegations that he harassed staff and improperly requested confidential information. Following an investigation and resolution drafted by board members, the Board voted to censure Williams and remove him from the presidency. Williams was not informed of the allegations against him before the meeting where his removal was voted upon. Williams filed suit in the United States District Court for the Eastern District of Michigan, alleging, among other claims, a violation of the Fair and Just Treatment clause of the Michigan Constitution and asserting that the school district was liable under respondeat superior. The district court granted summary judgment to the defendants on all claims, including the federal constitutional claims, and denied Williams’s motion for partial summary judgment on his Fair and Just Treatment claim. The district court chose to exercise supplemental jurisdiction over the state law claims after dismissing the federal claims. The United States Court of Appeals for the Sixth Circuit reviewed the case and determined that the district court abused its discretion by retaining supplemental jurisdiction over Williams’s Fair and Just Treatment claim. The appellate court found that the state law claim presented a novel and complex issue under Michigan law, particularly because Michigan courts have not yet determined whether a private right of action exists under the Fair and Just Treatment clause. The court held that, given the dismissal of all federal claims and the complexity of the remaining state constitutional issue, the district court should have declined to exercise supplemental jurisdiction. As a result, the Sixth Circuit vacated the district court’s judgment on the Fair and Just Treatment claim and remanded with instructions to dismiss this claim without prejudice. View "Williams v. Addison Community Schools" on Justia Law

L.B. V. SAN DIEGO UNIFIED SCHOOL DISTRICT

2026-02-27T13:31:27-08:00

A middle school student with significant mental health needs struggled academically and emotionally while enrolled in a public school district during the COVID-19 pandemic, when instruction was provided virtually. His parents, finding that the school’s Individualized Education Program (IEP) was inadequate to address his needs during this period, placed him in two successive out-of-state private residential treatment centers offering in-person education and mental health services. Throughout this time, the parents participated in several meetings with the district’s IEP Team and communicated their concerns about the insufficiency of the educational program provided. Afterward, the parents sought reimbursement from the school district for the costs associated with the residential placements, arguing that the district failed to offer their child a free appropriate public education (FAPE) as required under the Individuals with Disabilities Education Act (IDEA). An Administrative Law Judge (ALJ) denied their claim, concluding that the district had no duty to offer a FAPE during the relevant period because the parents had not expressly requested a new IEP document, and instead, had only requested IEP meetings. The United States District Court for the Southern District of California affirmed this determination, also reasoning that the parents’ requests for meetings did not obligate the district to develop or offer a new IEP. The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that under both federal and California law, the purpose of an IEP meeting is to develop or revise an IEP that offers a FAPE. The court concluded that it was irrelevant whether the parents had requested an IEP “meeting” or an IEP “document,” and that participation in IEP meetings triggered the district’s ongoing obligation to offer a FAPE. The Ninth Circuit reversed the district court’s decision and remanded for further proceedings to determine whether the IEP offered satisfied the IDEA’s requirements and, if not, whether the student was entitled to reimbursement or other remedies. View "L.B. V. SAN DIEGO UNIFIED SCHOOL DISTRICT" on Justia Law

Smitherman v. Roberts

2026-02-27T06:30:54-08:00

A teacher who had previously attained tenure in the Montgomery County public-school system resigned from that position in September 2019 after accepting an offer for a probationary teaching job with the Alabama Department of Youth Services School District (DYS). The teacher received an email in mid-September confirming the job offer, with instructions to begin work on October 7, 2019, after completing mandatory training. The teacher’s salary, benefits, and job responsibilities with DYS all began on October 7, and he completed multiple school years in the new role before receiving notice in April 2023 that his contract would not be renewed. The teacher filed suit in the Montgomery Circuit Court, seeking a declaration that he had acquired tenure under the Students First Act of 2011, which would entitle him to due-process protections before dismissal. The trial court held a bench trial and concluded that the teacher was tenured at the time of his nonrenewal, reasoning that his employment was “effective” upon the agreement in September 2019 and, in the alternative, that DYS was estopped from denying him tenure because he relied on the September email when resigning from his previous tenured position. On appeal, the Supreme Court of Alabama reversed the trial court’s decision. It held that, for purposes of the Students First Act, “effective employment” occurs when a teacher is required to report for work and is paid, not at the time of an offer or acceptance. Because the teacher’s employment with DYS became effective on October 7, 2019—after the statutory October 1 cutoff—he did not accrue a “complete” school year for 2019-2020 and did not acquire tenure before his contract was nonrenewed. The Court also rejected the application of equitable estoppel, finding no misleading conduct by DYS. The judgment was reversed and the case remanded. View "Smitherman v. Roberts" on Justia Law

Castille v. Port Arthur Independent School District

2026-02-24T16:30:29-08:00

A school administrator responsible for special education at a high school in Texas alleged that his employment was terminated in retaliation for reporting incidents of child abuse by teachers under his supervision and for cooperating with a subsequent Child Protective Services (CPS) investigation. He reported the incidents to his principal, participated in a CPS interview, and raised concerns about disciplinary actions and workplace conduct. After additional workplace conflicts and an EEOC complaint, his contract was ultimately terminated by the district’s Board of Trustees following a hearing, and his administrative appeal was unsuccessful. The United States District Court for the Eastern District of Texas reviewed the administrator’s claims, which included constitutional violations under the First and Fourteenth Amendments, retaliation for whistleblowing, and a civil conspiracy to violate his rights. The district court granted the defendants’ motions to dismiss for failure to state a claim, denied leave to amend the complaint, and denied a motion to alter or amend the judgment. On appeal, the United States Court of Appeals for the Fifth Circuit affirmed the district court’s judgment. The Fifth Circuit held that the administrator’s speech—reporting child abuse to his supervisor, participating in the CPS investigation, and refusing to characterize events as his supervisor wished—was made in his official capacity as an employee, not as a citizen, and was therefore not protected by the First Amendment. The court also found that he received appropriate procedural due process related to his termination and did not state a claim for substantive due process. The individual defendants were entitled to qualified immunity, and the civil conspiracy claim failed because there was no underlying constitutional violation. The court also concluded that the district court did not abuse its discretion in declining to take judicial notice of the administrative record and found other claims waived. View "Castille v. Port Arthur Independent School District" on Justia Law

C.B. v. Henry County School District

2026-02-19T12:33:04-08:00

A student with Down syndrome, C.B., attends school in the Henry County School District in Georgia. Under the Individuals with Disabilities Education Act (IDEA), the school district was required to develop an individualized education program (IEP) for C.B. After reviewing C.B.’s progress in fourth grade, the school district’s IEP team decided to move C.B. from an interrelated resource (IRR) class to a mild intellectual disability (MID) class for language arts and math. C.B.’s parents disagreed with this new placement, believing the IRR class was less restrictive and more appropriate. They also objected to the school district’s decision to place C.B. on an alternative assessment track, rather than the regular statewide assessment. Following the school district’s decision, C.B.’s parents requested a due process hearing before the Georgia Office of State Administrative Hearings. The administrative law judge conducted a five-day hearing and found that the school district had complied with IDEA in making the placement decision and that the Georgia Alternate Assessment was appropriate for C.B. The United States District Court for the Northern District of Georgia affirmed the administrative law judge’s findings regarding the placement, concluding that the least restrictive environment requirement under IDEA did not apply to the choice between different types of special education classes. The district court also found C.B.’s claim regarding the alternative assessment moot, since C.B. was no longer required to take the alternative assessment. On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s decision regarding the placement in the MID class, holding that the least restrictive environment requirement under IDEA does not apply to placement decisions among special education classes. However, the court reversed the district court’s mootness determination on the assessment claim and remanded the case for further proceedings on that issue. View "C.B. v. Henry County School District" on Justia Law

Christianson v. Grand Forks Public School District

2026-02-19T12:06:19-08:00

David Christianson was employed during the 2023-24 school year as a teacher at Grand Forks Red River High School, holding both a standard teaching contract and two additional “director contracts” for Pep Band Director and Music-Instrumental Head Director. After two pranks occurred under his supervision at graduation events, Christianson was reassigned to a different school and his director contracts were not renewed. He pursued a grievance with the School District, culminating in a formal hearing and a School Board denial of his appeal. The School Board subsequently issued a written decision two days after the contractual deadline, prompting Christianson to formally object. The case was reviewed by the District Court of Grand Forks County, Northeast Central Judicial District. Both parties moved for summary judgment. The School District argued Christianson was required to arbitrate his grievance before pursuing litigation, while Christianson claimed the School District failed to follow mandatory nonrenewal procedures. The district court found that the School District had waived its right to enforce arbitration by not complying with contractual notice requirements and determined that Christianson’s director contracts were extracurricular, not curricular. Therefore, statutory nonrenewal procedures did not apply. Summary judgment was granted in favor of the School District. Upon appeal, the Supreme Court of the State of North Dakota reviewed the case de novo. The Court affirmed the district court’s judgment, holding that the School District’s failure to timely provide written notice constituted a waiver of its right to require arbitration. The Court further held that Christianson’s director contracts were extracurricular and not subject to teacher contract nonrenewal protections under North Dakota law. The judgment of the district court was affirmed. View "Christianson v. Grand Forks Public School District" on Justia Law

COMMONWEALTH OF KENTUCKY V. COUNCIL FOR BETTER EDUCATION, INC.

2026-02-19T07:04:56-08:00

A nonprofit organization and several school boards challenged Kentucky House Bill 9, which authorized state funding for charter schools, alleging it violated Sections 183, 184, and 186 of the Kentucky Constitution. The bill permitted charter schools to receive public funds but allowed them to operate independently from local school districts, with enrollment caps and admissions preferences that could exclude some eligible children. Charter schools were also exempt from certain state and district regulations applicable to public schools. The Franklin Circuit Court reviewed the case and found that HB 9 was inconsistent with the constitutional requirement for an efficient system of common schools. The court concluded that using tax dollars to support charter schools violated constitutional provisions reserving education funding for common schools and public schools only. As a result, the circuit court enjoined the implementation of HB 9 and prohibited the expenditure of tax dollars for charter schools under the statute. The Supreme Court of Kentucky granted motions to transfer the appeals directly to its docket. Upon review, the Court held that charter schools authorized by HB 9 do not qualify as “common schools” or “public schools” as contemplated by Sections 183, 184, and 186 of the Kentucky Constitution. The Court determined that charter schools’ admission limitations, lack of local district oversight, and exemption from certain regulations placed them outside the constitutionally protected common school system. Therefore, funneling public education funds to charter schools under HB 9 is unconstitutional. The Court affirmed the Franklin Circuit Court’s decision, upholding the prohibition on public funding for charter schools unless voter approval is obtained as provided in Section 184. View "COMMONWEALTH OF KENTUCKY V. COUNCIL FOR BETTER EDUCATION, INC." on Justia Law

Cruz v Banks

2026-02-17T07:36:16-08:00

The case concerns a dispute between a parent and the New York City Department of Education regarding the appropriate special education classroom placement for a student, O.F., who has severe disabilities including cerebral palsy, visual impairment, seizure disorder, and scoliosis. In 2020, O.F.’s Committee on Special Education (CSE) recommended a 6:1:1 placement in a specialized public school. The following year, after O.F. had not attended school during the pandemic, the CSE recommended a 12:1+(3:1) class configuration, considering O.F.’s lack of progress and his need for more individualized and specialized instruction. The parent challenged this recommendation, seeking tuition reimbursement for O.F.’s placement at a private school. After a due process complaint, the matter was reviewed in an administrative hearing before an impartial hearing officer (IHO), who found the 12:1+(3:1) class appropriate for O.F. Upon appeal, the State Review Officer (SRO) upheld the IHO’s finding. The parent then brought the case to the United States District Court for the Southern District of New York, which granted summary judgment in favor of the City DOE, agreeing the placement was suitable based on O.F.’s needs and the regulatory requirements. The parent appealed, and the United States Court of Appeals for the Second Circuit certified a question to the New York Court of Appeals regarding the interpretation of 8 NYCRR 200.6 (h) (4). The New York Court of Appeals held that 8 NYCRR 200.6 (h) (4) sets forth a list of mutually exclusive alternatives for special education class sizes and staffing. The court determined that a CSE must select the listed alternative that best meets a student’s individual needs, rather than fulfilling multiple class size constraints simultaneously. The certified question was answered accordingly. View "Cruz v Banks" on Justia Law

Haskell v. Grand Forks Public Schools

2026-02-12T08:36:09-08:00

A field consultant for a public teachers’ union brought a lawsuit after a school board held a closed executive session during a grievance hearing involving a teacher’s transfer and removal of extracurricular duties. The board’s attorney presented the school district’s legal position and rationale in an open meeting before the board entered executive session to receive additional legal advice. The board later voted in public to deny the grievance, and the plaintiff, who was not the aggrieved teacher, claimed the executive session violated North Dakota’s open meetings laws. She sought disclosure of the executive session recording as a remedy. The District Court of Grand Forks County granted summary judgment to the school district, finding no waiver of the right to enter executive session, that the requirements for the attorney consultation exemption were met, and that the plaintiff’s due process rights were not violated by her lack of access to the executive session transcript. The court declined to review the executive session recording, relying instead on declarations from board representatives and the parties’ stipulation that no material facts were in dispute. On appeal, the Supreme Court of the State of North Dakota affirmed in part and reversed in part. The court held that the school board did not waive its right to an executive session by publicly stating its legal position and that the statutory requirements for entering executive session were satisfied. The court also found no due process violation from not providing the plaintiff access to the transcript. However, the Supreme Court concluded that the district court abused its discretion by not conducting an in camera review of the executive session recording before granting summary judgment. The judgment of dismissal and the award of costs to the school district were reversed, and the case was remanded for the district court to review the recording and proceed accordingly. View "Haskell v. Grand Forks Public Schools" on Justia Law

Navy v. Sch Bd of St. Mary Prsh

2026-02-10T10:30:53-08:00

In 1965, individuals filed a class action lawsuit against the public schools in St. Mary Parish, Louisiana, seeking to end segregation and secure injunctive relief. The district court granted an injunction requiring desegregation and oversight, with subsequent orders and modifications over the years as the parties and courts responded to compliance issues and changes in the law. After a period of inactivity, new representatives and counsel stepped in around 2018–2019, seeking to further modify the original injunction. The School Board responded by filing motions challenging the procedural propriety of the new plaintiffs, the court’s subject matter jurisdiction, and the ongoing validity of the injunction. The United States District Court for the Western District of Louisiana allowed the substitution of new plaintiffs, denied the Board’s motions to dismiss, and recertified the class, despite acknowledging factors that weighed against doing so. The Board did not appeal immediately but later renewed its objections, moving to dissolve the decades-old injunction and to strike or dismiss the new plaintiffs’ motions for further relief. The district court denied the Board’s motions to dismiss and to strike, and clarified that the Board could not present certain arguments under Rule 60(b)(5) at an upcoming hearing. The Board appealed these rulings. The United States Court of Appeals for the Fifth Circuit reviewed whether it had appellate jurisdiction under 28 U.S.C. § 1292(a)(1), which allows interlocutory appeals of orders granting, continuing, modifying, or refusing to dissolve injunctions. The Fifth Circuit held that the district court’s orders did not have the practical effect of continuing, modifying, or refusing to dissolve the injunction, but merely maintained the status quo pending further proceedings. As such, the appellate court determined it lacked jurisdiction to consider the appeal and dismissed it for want of appellate jurisdiction. View "Navy v. Sch Bd of St. Mary Prsh" on Justia Law

Committee to Protect and Preserve v. State

2026-02-06T09:07:01-08:00

Several organizations and individuals petitioned to prevent the Idaho State Tax Commission from implementing a newly enacted parental choice tax credit. This tax credit, established in 2025, provides refundable credits to parents, guardians, and foster parents for certain private educational expenses, including private school tuition and related services, for dependent students not enrolled in public schools. The law caps total annual credits and includes prioritization based on income and previous participation. The petitioners, including advocacy groups, a school district, and parents, argued that the statute creates a separate, non-public education system funded by public resources, allegedly violating the Idaho Constitution’s mandate for a single, general, uniform, and thorough system of public schools. They also claimed the statute failed the “public purpose doctrine,” asserting it primarily benefits private rather than public interests. Before the Idaho Supreme Court, the petitioners sought a writ of prohibition, which would prevent the Tax Commission from carrying out the law. The respondents, including the State and the Idaho Legislature, contested the petitioners’ standing and the merits of the constitutional claims. The Supreme Court determined that the petitioners lacked traditional standing but, given the urgency and importance of the constitutional question and the absence of another suitable challenger, relaxed standing requirements to address the merits. The Supreme Court of Idaho denied the petition. It held that Article IX, section 1 of the Idaho Constitution does not restrict the legislature from enacting educational measures beyond the required public school system, so long as the public system remains intact and constitutionally sufficient. The Court also found that the tax credit serves a legitimate public purpose—supporting parental choice in education—even if private entities benefit. The petition was dismissed, and the Tax Commission was awarded attorney fees and costs. View "Committee to Protect and Preserve v. State" on Justia Law

Newport School Committee v. Rhode Island Department of Education

2026-02-03T13:29:07-08:00

Two children were placed in the temporary custody of the Department of Children, Youth, and Families (DCYF) by the Family Court in 2018. The Family Court determined that Newport and Cumberland were responsible municipalities for the children’s education, as they were the residences of the custodial parents. DCYF placed the children in residential treatment facilities where they received general education services, but not special education services. DCYF requested orders from the Commissioner of Elementary and Secondary Education that Newport and Cumberland reimburse DCYF for education costs at the per-pupil special-education rate. The commissioner agreed and ordered the municipalities to pay at that rate. Both municipalities appealed to the Council on Elementary and Secondary Education, which denied their appeals. The municipalities then appealed to the Rhode Island Superior Court under the Administrative Procedures Act. The Superior Court consolidated the cases and found that the statute required the municipalities to pay their share of educational costs, but not at the special-education rate unless special education services were provided. The trial justice also held that, even after statutory amendments removed references to general education, the municipalities were still responsible for the per-pupil general-education rate for children not receiving special education. On review, the Supreme Court of Rhode Island considered whether the municipalities were obligated to pay the general-education rate after the statutory reference to general education was removed. The Court held that the plain language of the statute only requires reimbursement for special education costs and does not obligate municipalities to pay for general education where no special education services are provided. The Supreme Court quashed the decision of the Superior Court. View "Newport School Committee v. Rhode Island Department of Education" on Justia Law

Sargent v. School District of Philadelphia

2026-02-02T10:00:14-08:00

Three parents of students in Philadelphia challenged the School District’s 2022 Admissions Policy for four selective public high schools. Prior to 2022, admissions decisions were made by individual schools using academic criteria, attendance, and sometimes additional requirements such as interviews and writing samples. After a report identified geographic disparities in school representation, and following the School District’s public commitments to anti-racism and equity, a new centralized policy was adopted. This policy introduced revised academic standards, eliminated certain prior requirements, and implemented a zip code preference favoring applicants from six areas with high Black and Hispanic populations. Qualified applicants from these zip codes received automatic admission, while others had to enter a lottery for remaining seats. The parents, whose children lived outside the preferred zip codes and met the new criteria but were not admitted to their first-choice schools, filed suit in the United States District Court for the Eastern District of Pennsylvania. They alleged violations of Title VI, the Equal Protection Clause, and related state constitutional provisions, arguing that the new process was racially discriminatory. The District Court granted summary judgment for the School District, finding that no reasonable factfinder could conclude the policy had a racially discriminatory purpose or impact. The court applied rational basis review, holding the policy was rationally related to legitimate interests such as increasing access for underrepresented geographic areas. On appeal, the United States Court of Appeals for the Third Circuit held that, viewing the evidence in the light most favorable to the parents, a reasonable factfinder could conclude the Admissions Policy had both discriminatory purpose and impact. The Third Circuit vacated the District Court’s judgment and remanded for further proceedings, directing that strict scrutiny must be applied if a discriminatory purpose and impact are found. View "Sargent v. School District of Philadelphia" on Justia Law

Hogan v. Kennebec Valley Community College

2026-01-29T08:26:11-08:00

A student was enrolled in a respiratory therapy program at a community college from 2017 to 2022. During her final year, supervisors at several hospitals where she completed clinical rotations reported concerns about her clinical performance, including patient safety issues and unprofessional conduct. After a series of incidents, she was suspended and ultimately dismissed from the program for violating the student code of conduct, specifically for conduct that endangered patient safety. The student argued that her difficulties were due to academic deficiencies rather than misconduct and also claimed she experienced discrimination based on her race and national origin. After her initial dismissal, the student sought review in the Somerset County Superior Court, which found the administrative record insufficient and remanded the matter for a new hearing. The college’s disciplinary committee held a second hearing, reviewed evidence from both the student and the administration, and again upheld her dismissal, explicitly finding no evidence of discrimination or bias. The student then brought a three-count action in the Superior Court: (1) an administrative appeal of her dismissal under Rule 80B, (2) a claim under 42 U.S.C. § 1983 for violation of procedural due process, and (3) a claim of unlawful educational discrimination under Maine law. The Maine Supreme Judicial Court held that the college’s decision to dismiss the student was not arbitrary or capricious and that the disciplinary process afforded her meaningful notice and an opportunity to be heard. The Court affirmed dismissal of the § 1983 and discrimination claims as duplicative of the administrative appeal, finding that her grievances were properly addressed through Rule 80B review, and that there was no evidence of discrimination or due process violations. The judgment of the Superior Court was affirmed. View "Hogan v. Kennebec Valley Community College" on Justia Law

Vallejo City Unified School Dist. v. Superior Court

2026-01-27T16:01:51-08:00

An 11-year-old student, Therese, died by suicide at her father's home during her school’s winter break. Her parents brought claims against the school district, alleging negligent hiring, supervision, and training of staff, failure to protect Therese from bullying, and inadequate response to her expressions of suicidal ideation. They argued the district failed to fulfill its duty to supervise students and to inform them of Therese’s condition. The parents also pursued a survival claim for Therese’s pre-death suffering, alleging harm occurred on campus due to the district’s negligence. The Superior Court of Solano County denied the school district’s motion for summary judgment, finding triable issues of fact as to whether the district exercised reasonable care and whether Therese suffered injury on campus due to the district’s negligence. The court relied on the California Supreme Court’s decision in Hoyem v. Manhattan Beach City School District, determining that statutory immunity under Education Code section 44808 did not apply because there were factual questions about on-campus harm and failure to exercise reasonable care. The Court of Appeal of the State of California, First Appellate District, Division Four, reviewed the case on a petition for writ of mandate. The appellate court held that under section 44808, the district is immune from liability for harms resulting from Therese’s off-campus suicide, as she was not under the district’s supervision at the time. However, the court determined that this immunity does not extend to the survival claim, which concerns alleged on-campus harm while Therese was under the district’s supervision. The appellate court ordered the trial court to grant summary adjudication in favor of the district on the wrongful death and related claims but allowed the survival claim to proceed. View "Vallejo City Unified School Dist. v. Superior Court" on Justia Law

Bell v. Wilkinsburg SD

2026-01-21T06:39:43-08:00

The case involved a dispute between a public school district and several charter schools, along with a resident, regarding the mode of free transportation provided to charter school students. Previously, the district had provided school bus transportation to all students, including those attending charter schools within ten miles of the district. However, to reduce costs, the district switched to giving charter school students free passes to use public buses operated by the county transit authority, a move that resulted in significant savings due to differences in state reimbursement. The charter schools continued to provide private transportation for younger students but not for older ones, who used the public transit passes. After the change, the charter schools and the resident sued in the Allegheny County Court of Common Pleas, seeking a declaration that the district’s provision of public bus passes did not constitute “free transportation” as required by state law and an injunction to stop the practice. The trial court, after a non-jury trial, ruled in the district’s favor, holding that state statutes allowed school districts to use common carriers for student transportation and that the law did not require identical modes of transportation for charter and district students. On appeal, the Commonwealth Court initially reversed on a procedural issue but, after remand from the Supreme Court, ultimately affirmed the trial court, finding no violation of the relevant statutes. The Supreme Court of Pennsylvania reviewed whether state law requires school districts to provide the same mode of free transportation to charter school students as to traditional public school students. The court held that the statute entitles charter school students to “free transportation” but does not require that the mode of transportation be identical to that provided to other public school students. The court affirmed the order of the Commonwealth Court, ruling that the district’s use of public bus passes for charter school students was permissible under the law. View "Bell v. Wilkinsburg SD" on Justia Law

Thompson v. Central Valley School District No 365

2025-12-29T11:31:29-08:00

A former assistant principal at a middle school in the Central Valley School District posted a Facebook comment about the Democratic National Convention that included epithets, slurs, and violent language. The post, though made on his private account and shared with Facebook friends, was seen by other school district employees and quickly forwarded to administrators. Within days, the assistant principal was placed on paid administrative leave, prohibited from contacting district staff or students, and ultimately transferred to a non-administrative teaching position. The school district’s investigation revealed additional concerns about derogatory comments he had made at work. The district offered him a voluntary transfer if he signed a release of claims, which he rejected, leading to further administrative proceedings and the final transfer decision. Previously, the United States District Court for the Eastern District of Washington reviewed the case. The court initially denied summary judgment to individual administrators on qualified immunity, a decision affirmed by the Ninth Circuit on interlocutory appeal. After further discovery and cross-motions for summary judgment, the district court granted summary judgment to the school district and the individual administrators. The court found the plaintiff had established a prima facie First Amendment retaliation claim but held that the district’s interests outweighed the plaintiff’s under the Pickering balancing test. Qualified immunity was also found to apply to the individual defendants. The United States Court of Appeals for the Ninth Circuit affirmed the district court’s rulings. It held that while the plaintiff’s Facebook post was private speech on a matter of public concern and he made a prima facie case for retaliation, the school district showed a reasonable prediction of disruption and its interest in maintaining a safe and inclusive environment outweighed the plaintiff’s First Amendment interests. The court also affirmed qualified immunity for the individual administrators. View "Thompson v. Central Valley School District No 365" on Justia Law

Halasz v. Cass City Public Schools

2025-12-18T14:00:13-08:00

After a fatal school shooting occurred at a high school in Michigan, H.H., an eighth-grade student at a different school, was reported by several classmates to have made threatening comments about possessing or bringing a gun to campus. The school administration, in response to these reports and heightened safety concerns, questioned H.H. with assistance from law enforcement, searched his person, backpack, and locker, and ultimately found no firearm. Despite this, the administration determined that H.H. had violated the school district’s code of conduct and referred him for an expulsion hearing, which resulted in his expulsion for 180 days. Following the expulsion, H.H.’s parents filed a lawsuit in the United States District Court for the Eastern District of Michigan against the school district and various officials. They raised claims under 42 U.S.C. § 1983 for alleged violations of H.H.’s Fourth Amendment rights (unlawful search and seizure), procedural and substantive due process, and also asserted state law tort claims. The district court granted summary judgment in favor of the defendants on all claims, finding no constitutional violations and determining that the defendants were immune from state law liability. The United States Court of Appeals for the Sixth Circuit reviewed the case de novo. The court held that the search and seizure of H.H. were reasonable under the circumstances, given the nature of the reported threat and school safety concerns. It found that the procedures afforded to H.H. during the expulsion process satisfied due process requirements, and there was no evidence of bias or arbitrary conduct by the school board. The court also concluded that the individual defendants were entitled to qualified immunity, and that governmental immunity barred the state tort claims. The Sixth Circuit affirmed the district court’s judgment in full. View "Halasz v. Cass City Public Schools" on Justia Law

RANDALL v. FIELDS

2025-12-16T11:15:28-08:00

A group of Oklahoma taxpayers, parents of public school children, teachers, and clergy challenged the adoption of the 2025 Oklahoma Academic Standards for Social Studies. They argued that the new standards promoted Christianity over other religions, required teaching religious stories as historical fact, and included instructions to question the legitimacy of the 2020 Presidential Election and the origins of COVID-19. The petitioners claimed these standards violated state statutes, the Oklahoma Constitution, and their rights as parents and citizens. They further alleged that the procedure used to adopt the standards violated the Oklahoma Open Meeting Act, as the public and several Board members received the final version less than twenty-four hours before the Board meeting where the standards were approved. No lower court reviewed this case prior to the current proceeding. The petitioners brought their claims directly to the Supreme Court of the State of Oklahoma by seeking original jurisdiction, requesting declaratory, injunctive, and mandamus relief, and a stay of enforcement. The Supreme Court previously issued a temporary stay to prevent the implementation of the 2025 Standards while considering the matter. The Supreme Court of the State of Oklahoma assumed original jurisdiction due to the statewide importance and urgency of the controversy. The Court held that the 2025 Oklahoma Academic Standards for Social Studies were adopted in violation of the Oklahoma Open Meeting Act, specifically because the public and Board members did not receive proper notice of the content to be considered and acted upon. The Court determined that legislative “deemed approval” did not cure this procedural violation. As a result, the Court declared the 2025 Standards unenforceable, dissolved the earlier stay, and reinstated the 2019 standards until new standards are properly adopted and reviewed. The request for mandamus relief was withheld without prejudice. View "RANDALL v. FIELDS" on Justia Law

J.M. v. New York City Dept. of Ed.

2025-12-09T08:00:07-08:00

Several parents of disabled children brought a class action against the New York City Department of Education, the Board of Education of the City School District of New York, and the Chancellor, alleging that the defendants violated the Individuals with Disabilities Education Act (IDEA). The plaintiffs claimed the defendants maintained a policy of discontinuing special education services to disabled students before their twenty-second birthday, despite federal and state guidance and previous case law indicating that such services should continue until that age. The United States District Court for the Southern District of New York dismissed the suit, finding that it lacked subject-matter jurisdiction because the plaintiffs had not exhausted administrative remedies as generally required under the IDEA. The district court agreed with the defendants’ argument that exhaustion was necessary and rejected the plaintiffs’ contention that exhaustion would be futile due to the existence of a blanket, citywide policy. On appeal, the United States Court of Appeals for the Second Circuit reviewed the district court’s dismissal. The appellate court clarified that the IDEA’s exhaustion requirement is not jurisdictional but is instead a claim-processing rule, meaning that failure to exhaust is not a bar to the court’s power to hear the case. The Second Circuit held that exhaustion of administrative remedies is excused when plaintiffs challenge a policy or practice of general applicability that is contrary to law and when the purposes of exhaustion—such as developing a factual record or utilizing agency expertise—would not be served. Because the plaintiffs’ claims raised a purely legal question regarding the validity of a blanket policy, the court found that exhaustion would be futile. The Second Circuit vacated the district court’s dismissal and remanded the case for further proceedings. View "J.M. v. New York City Dept. of Ed." on Justia Law

In the Matter of the Verified Petition for the Proposed Creation of a PK-12 All-Purpose Regional School District

2025-12-08T07:38:29-08:00

The Borough of Sea Bright previously operated as a non-operating school district, sending its kindergarten through eighth-grade students to the Oceanport School District and its high school students to Shore Regional High School District. In 2009, following legislative changes, Sea Bright merged with Oceanport for K-8 education, while continuing its relationship with Shore Regional for grades 9-12. In 2022, Sea Bright sought to withdraw from both Oceanport and Shore Regional in order to join with the Boroughs of Highlands and Atlantic Highlands and Henry Hudson Regional High School to form an all-purpose regional school district serving all grade levels. Sea Bright adopted a resolution supporting this proposal. After Sea Bright and other municipalities filed a joint petition for regionalization with the New Jersey Commissioner of Education, Oceanport and Shore Regional challenged Sea Bright’s authority to seek withdrawal under N.J.S.A. 18A:13-47.11(a). The Commissioner of Education determined that Sea Bright was empowered by statute to pursue withdrawal from the two districts. Oceanport and Shore Regional appealed, arguing that merged districts were not included in the statutory authorization for withdrawal. The Superior Court, Appellate Division, affirmed the Commissioner’s decision, holding that Sea Bright was eligible to seek withdrawal and that statutory terms such as “consolidated” and “merged” were not intended to be distinct for this purpose. The Supreme Court of New Jersey reviewed the case and affirmed the Appellate Division’s judgment. The Court held that, based on the plain language of the relevant statutes and the legislative intent to promote regionalization, a municipality in Sea Bright’s position is a governing body authorized to pursue withdrawal from a school district to form or enlarge a regional school district under N.J.S.A. 18A:13-47.11(a). The Court did not address whether Sea Bright satisfied other statutory criteria, leaving that determination to the Commissioner of Education if Sea Bright files a petition. View "In the Matter of the Verified Petition for the Proposed Creation of a PK-12 All-Purpose Regional School District" on Justia Law

North East Independent School District v. I.M.

2025-11-21T16:30:13-08:00

An elementary school student with autism, intellectual disability, and a speech impediment exhibited severe behavioral issues, including frequent elopement from school and toileting problems, which impeded his academic and social development. The student communicated primarily through gestures and a specialized iPad, and his academic performance lagged significantly behind grade level. The school district developed an individualized education program (IEP) that included special classes, therapy, and behavioral interventions. While the IEP initially included a limited extended-school-year (ESY) program to combat regression over breaks, the student continued to regress, particularly after school vacations, resulting in dangerous incidents and increasing parental concern. After disagreements arose regarding the adequacy of summer ESY services, the student’s parent requested a due process hearing, seeking more robust ESY support and additional accommodations. The hearing officer found that the school district had failed to provide a free appropriate public education under the Individuals with Disabilities Education Act (IDEA), ordering full-summer ESY services and year-round access to a communication device. The school district appealed the decision to the United States District Court for the Western District of Texas, which upheld the hearing officer’s findings, determining that the IEP was not sufficiently individualized and did not adequately address the student’s behavioral regression. On appeal, the United States Court of Appeals for the Fifth Circuit reviewed whether the district court erred in finding the IEP deficient under IDEA standards. The Fifth Circuit affirmed the district court’s judgment, holding that the IEP was insufficiently individualized given the student’s severe behavioral regression and that the educational benefits provided—while academically positive—were outweighed by the failure to address nonacademic, safety-critical needs. The court concluded that the school district’s refusal to provide more effective ESY services denied the student an IDEA-appropriate education. View "North East Independent School District v. I.M." on Justia Law

Haase v. Kankakee School District 111

2025-11-20T07:33:34-08:00

A student at Kankakee Junior High School sustained a serious arm injury during a gym class soccer game. The physical education teacher, Dayhoff, was accused of failing to adequately supervise the class, specifically neglecting to monitor a student known as “Student A,” who allegedly had a history of physical aggression. The injured student and his parent filed suit against both the school district and Dayhoff, claiming willful and wanton conduct in supervision and seeking damages for medical expenses. The Circuit Court of Kankakee County granted summary judgment for the defendants—the school district and Dayhoff—finding they were immune from liability under the Local Governmental and Governmental Employees Tort Immunity Act. The court concluded that Dayhoff’s actions fell within discretionary policy determinations, and the plaintiffs’ allegations did not rise to willful and wanton conduct, but at most described negligence, which is immunized under the Act. The court also found no basis for recovery under the Family Expense Act. The Appellate Court of Illinois, Third District, reversed the circuit court’s ruling, holding that disputed issues of fact regarding Student A’s disciplinary history and the defendants’ knowledge thereof precluded summary judgment on the question of willful and wanton conduct. On appeal, the Supreme Court of Illinois reviewed the record de novo and determined that the plaintiffs failed to provide evidence that Dayhoff knew or should have known of Student A’s history of aggression, and did not plead an independent claim against the district for failing to inform teachers. The Supreme Court held that the facts supported only a claim of negligent supervision, not willful and wanton conduct, and that section 3-108 of the Tort Immunity Act immunized the defendants. The Supreme Court reversed the appellate court and affirmed summary judgment for the defendants. View "Haase v. Kankakee School District 111" on Justia Law

Fogle v. Clay Elementary School-Southeast Polk Community School District

2025-11-14T07:03:06-08:00

The case involves claims brought by the parents of a minor child, P.F., who was allegedly bullied, harassed, and assaulted by another student at Clay Elementary School during the 2022–2023 school year due to his sexual orientation. The parents assert that the school district and three employees were aware of these incidents but failed to protect P.F. or notify his parents, instead blaming P.F. or dismissing the other student’s conduct. After removing P.F. from the school and filing reports with authorities, the parents pursued legal action, first filing a complaint with the Iowa Civil Rights Commission (ICRC), which issued a right-to-sue letter. The parents then filed an amended petition in the Iowa District Court for Polk County, asserting three claims under the Iowa Civil Rights Act (ICRA) and three common law tort claims. The defendants moved to dismiss all claims, arguing that the heightened pleading requirements and qualified immunity provisions of the Iowa Municipal Tort Claims Act (IMTCA), as amended by Iowa Code section 670.4A, applied. The Iowa District Court for Polk County denied the motion, finding that the ICRA claims were not torts subject to the IMTCA and that the common law claims met the IMTCA’s pleading standard. The defendants appealed, asserting a right to immediate appeal under section 670.4A(4). The Iowa Supreme Court reviewed the appeal and held that the IMTCA’s qualified immunity and heightened pleading requirements do not apply to claims brought under the ICRA or to common law tort claims, as clarified in Doe v. Western Dubuque Community School District. Because section 670.4A did not apply to any of the claims, the defendants were not entitled to an appeal as of right. The court dismissed the appeal for lack of appellate jurisdiction and remanded the case. View "Fogle v. Clay Elementary School-Southeast Polk Community School District" on Justia Law

A.P. v. Pearland Independent School District

2025-11-10T16:30:15-08:00

A.P. was a student in Pearland Independent School District who, after a period of homeschooling, returned to the District and began experiencing significant attendance problems. Despite passing her classes with targeted intervention, her absenteeism persisted, and she failed multiple advanced courses that her parents insisted she take against the District’s advice. Her teachers consistently attributed her academic struggles to poor attendance rather than any suspected learning disability. The District recommended less challenging courses and additional support programs, but her parents declined these options and continued to excuse her absences for non-serious reasons. After withdrawing A.P. from the District and homeschooling her, her parents requested a due process hearing, alleging that the District failed to identify and evaluate her for learning disabilities under the Individuals with Disabilities in Education Act (IDEA). The District offered to conduct an evaluation, but her parents refused consent. Instead, they obtained an independent evaluation, which found some learning disabilities but lacked classroom observations and teacher input. The District determined it did not have enough information to assess her eligibility for special education services. A Special Education Hearing Officer found no IDEA violation, and the United States District Court for the Southern District of Texas affirmed, concluding that the District met its child find obligation and that A.P.’s academic issues were primarily due to absenteeism. The United States Court of Appeals for the Fifth Circuit reviewed the case, applying de novo review to mixed questions of law and fact and clear error review to factual findings. The Fifth Circuit held that the District’s child find duty was not triggered by A.P.’s absenteeism or poor grades alone, and that her parents failed to prove she qualified for special education under IDEA. The court affirmed the district court’s judgment. View "A.P. v. Pearland Independent School District" on Justia Law

Arnold v. Barbers Hill Independent School District

2025-11-03T16:30:14-08:00

Several former students and their parents challenged a school district’s policy restricting the length of male students’ hair, alleging that the policy constituted race and sex discrimination and violated constitutional and statutory rights. The school district amended its hair policy during the 2019–2020 school year, removing language that previously allowed certain hairstyles, such as cornrows or locs, if they complied with other requirements. The plaintiffs argued that the enforcement of this policy infringed upon their rights under the Fourteenth Amendment, the First Amendment, Title VI, Title IX, and Texas law. The case was initially heard in the United States District Court for the Southern District of Texas. During discovery, the plaintiffs sought to depose the superintendent and a former board president. The school district moved for a protective order, asserting legislative privilege to prevent inquiries into the subjective motivations of board members regarding the hair policy. The district court partially denied the motion, establishing a procedure where deponents could assert the privilege but would still be required to answer, with disputed portions of testimony marked confidential for later review. The district court declined to rule on the privilege’s applicability until specific questions were asked during depositions. On appeal, the United States Court of Appeals for the Fifth Circuit reviewed whether the district court erred in its handling of the legislative privilege and the protective order. The Fifth Circuit held that none of the appellants—including the school district, the board of trustees, and the individual former officials—had standing to appeal the district court’s order because the privilege holders had not personally invoked the privilege or participated adequately in the proceedings. As a result, the Fifth Circuit dismissed the appeal for lack of jurisdiction and also dismissed the pending motion to stay as moot. View "Arnold v. Barbers Hill Independent School District" on Justia Law

IntegrateNYC, Inc. v State of New York

2025-10-23T07:08:28-08:00

A group of student and parent organizations, along with individual students, brought suit against state and city officials responsible for New York City’s public education system. They alleged that admissions and screening policies, curriculum content, and a lack of teacher diversity in the city’s schools discriminated against Black and Latino students, resulting in segregation, unequal educational opportunities, and poor educational outcomes. The plaintiffs claimed these practices violated the New York State Constitution’s Education Article, the State Equal Protection Clause, and the New York State Human Rights Law, seeking declaratory and injunctive relief to eliminate admissions screens and address alleged discrimination. The Supreme Court, New York County, dismissed the complaint, finding the issues nonjusticiable as they involved educational policy decisions reserved for the legislature. The Appellate Division, First Department, modified that decision, holding that the claims were justiciable and that the complaint stated viable causes of action under the Education Article, the Equal Protection Clause, and, as to the City defendants, the Human Rights Law. The Appellate Division granted leave to appeal and certified the question of whether its order was properly made. The New York Court of Appeals reviewed the sufficiency of the complaint under the standard for motions to dismiss. The Court held that the plaintiffs failed to adequately plead a deprivation of a sound basic education, as their allegations of deficient resources and discriminatory policies were vague, conclusory, and did not demonstrate a district-wide failure or causation. The Court also found that the equal protection claim lacked sufficient allegations of intentional discrimination, and the Human Rights Law claim was not supported by specific facts. The Court of Appeals modified the Appellate Division’s order and dismissed the complaint, answering the certified question in the negative. View "IntegrateNYC, Inc. v State of New York" on Justia Law

Appeal of Pittsfield Sch. Dist.

2025-10-17T05:10:53-08:00

A student, E.A., resided in the Pittsfield School District, which operates its own middle and high school. E.A. applied to and was accepted by Prospect Mountain School, an open enrollment public school located outside the district. When Prospect Mountain requested tuition payment from the Pittsfield School District for E.A.’s attendance, the district refused, asserting that because it had not adopted the provisions of RSA chapter 194-D, it was not obligated to pay tuition for students attending open enrollment schools outside its district. E.A.’s parents appealed the superintendent’s decision to the Pittsfield School Board, which denied their request. They then appealed to the New Hampshire State Board of Education. After a hearing, a hearing officer recommended upholding the school board’s decision, reasoning that the district was not required to pay tuition unless it had formally adopted an open enrollment program. However, after oral argument, the State Board rejected this recommendation. The State Board interpreted the statute to require a resident district to pay tuition for students attending an open enrollment school in another district, regardless of whether the sending district had adopted the statute. The Pittsfield School District’s motion for rehearing was denied, and it appealed to the Supreme Court of New Hampshire. The Supreme Court of New Hampshire reviewed the statutory language and recent legislative amendments. The court held that under RSA chapter 194-D, a sending school district must pay tuition to an open enrollment receiving school in another district, even if the sending district has not adopted an open enrollment program. The court found that the statutory scheme and recent clarifying amendments support this interpretation. The court affirmed the State Board’s decision. View "Appeal of Pittsfield Sch. Dist." on Justia Law

PILATO v. STATE OF GEORGIA

2025-10-15T04:10:20-08:00

After their property in DeKalb County was annexed by the City of Atlanta, two parents sought to enroll their children in Atlanta Public Schools (APS). APS, however, denied enrollment, citing a 2021 Georgia law (SB 209) that prevents the expansion of APS boundaries to include newly annexed areas unless specifically authorized. The City of Atlanta had approved the annexation and expressed its intent for the APS boundaries to expand accordingly, but APS maintained that SB 209 prohibited such an extension. The parents and the City of Atlanta filed a petition for declaratory and injunctive relief against the State of Georgia, arguing that SB 209 was unconstitutional under the Georgia Constitution’s Single Subject Rule. The case was initially filed in Fulton County, transferred to DeKalb County, and then refiled in Fulton County against the State after the plaintiffs voluntarily dismissed the DeKalb action. The DeKalb County School District (DCSD) was allowed to intervene as a plaintiff. The trial court denied motions to dismiss, found that the plaintiffs had standing, determined there was a justiciable controversy, and ruled that SB 209 violated the Single Subject Rule, granting declaratory and injunctive relief to the plaintiffs. On appeal, the Supreme Court of Georgia reviewed whether the trial court had jurisdiction to grant relief. The Supreme Court of Georgia held that the plaintiffs failed to establish an actual or justiciable controversy with the State, as the alleged harm stemmed from APS’s actions, not from any enforcement by the State. Because the dispute did not involve the parties before the court, the Supreme Court of Georgia vacated the trial court’s judgment and remanded the case with instructions to dismiss the petition. View "PILATO v. STATE OF GEORGIA" on Justia Law

Jacobs v. Salt Lake City School District

2025-10-09T08:00:56-08:00

Two elementary school students with intellectual disabilities, through their legal guardians, and a disability advocacy organization challenged the educational placement practices of a public school district. The plaintiffs alleged that the district automatically assigned students with intellectual disabilities to self-contained special education classes in a limited number of designated schools, based solely on IQ-based categories, without conducting individualized assessments to determine whether a general education classroom with supplementary services might be more appropriate for each student. The plaintiffs claimed this practice violated the Individuals with Disabilities Education Act (IDEA), the Americans with Disabilities Act (ADA), and Section 504 of the Rehabilitation Act (RA). After the students’ parents pursued administrative due process hearings under the IDEA, hearing officers dismissed their ADA claims for lack of jurisdiction and, in one case, denied a hearing on the IDEA claim due to lack of parental consent for services. The other student’s hearing officer found that the district had made an appropriate individualized placement. The plaintiffs, joined by the advocacy organization, then filed suit in the United States District Court for the District of Utah, seeking declaratory and injunctive relief on behalf of themselves and similarly situated students. The district court dismissed all claims, construing the complaint as seeking only placement in neighborhood schools—a form of relief previously held unavailable under Tenth Circuit precedent—and dismissed the RA claim for failure to exhaust administrative remedies. The United States Court of Appeals for the Tenth Circuit reversed. The court held that the plaintiffs’ allegations that the district failed to make individualized educational placement determinations stated plausible claims under the IDEA, ADA, and Section 504. The court also found that exhaustion of administrative remedies for the RA claim would have been futile. The case was remanded for further proceedings. View "Jacobs v. Salt Lake City School District" on Justia Law

Johnson v. Mount Pleasant Public Schools

2025-09-30T11:30:19-08:00

A sixth-grade student with behavioral disabilities, X.M., attended Mount Pleasant Public Schools under an Individualized Education Plan that allowed him to use a breakroom to manage stress. In the fall of 2021, after a student reported that X.M. had brought a gun to school, school officials, including special-education teacher Jason Russell, searched X.M.’s locker and questioned him, but found nothing. The next day, after X.M. made a comment about not having his gun at school, officials again searched his belongings. According to X.M., Russell then ordered him to pull down his trousers and lift his shirt in a search for a gun. Days later, after X.M. was suspended for violence, he claimed Russell locked him in the breakroom for over 20 minutes. Cheyenne Johnson, X.M.’s mother, sued Russell, the school district, and other officials, alleging violations of X.M.’s constitutional rights. The United States District Court for the Eastern District of Michigan granted summary judgment to all defendants except Russell, denying him qualified immunity on the Fourth Amendment claims. The district court found that disputed facts—specifically, whether Russell conducted a strip search and locked X.M. in the breakroom—required a jury’s determination. The United States Court of Appeals for the Sixth Circuit reviewed the case on interlocutory appeal. The court held that, even accepting X.M.’s version of events, Russell did not violate clearly established Fourth Amendment rights. The court found that Russell’s search was justified at its inception and not clearly excessive in scope given the suspicion of a gun. It also concluded that it was not clearly established that locking a student in a breakroom for 20 minutes under these circumstances constituted an unreasonable seizure. The Sixth Circuit reversed the district court’s denial of qualified immunity and remanded with instructions to dismiss the Fourth Amendment claims against Russell. View "Johnson v. Mount Pleasant Public Schools" on Justia Law

GPat Patterson v. Kent State University

2025-09-12T11:00:17-08:00

A tenured English professor at a public university in Ohio, who identifies as transgender, became involved in discussions about leading the university’s Center for the Study of Gender and Sexuality during a period of departmental restructuring. Although the professor expressed interest in directing the Center and was considered a strong candidate, the position was not open as the Center had gone dormant. The professor was offered a partial teaching load reallocation to help develop a new gender-studies major, but after a series of profanity-laden and disparaging social media posts targeting colleagues and administrators, the offer was rescinded. The professor also sought a tenure transfer to the main campus, which was denied by faculty committees after considering collegiality and departmental needs, with no discussion of gender identity. The United States District Court for the Northern District of Ohio granted summary judgment for the university and individual defendants on all claims. The court found no genuine dispute of material fact and concluded that the university’s actions were based on legitimate, nondiscriminatory reasons, including the professor’s unprofessional conduct and the department’s academic requirements. The professor appealed, challenging the district court’s rulings on claims of sex discrimination and retaliation under Title VII, First Amendment retaliation under 42 U.S.C. § 1983, and perceived-disability discrimination under the Rehabilitation Act. The United States Court of Appeals for the Sixth Circuit affirmed the district court’s summary judgment. The court held that there was no direct or circumstantial evidence of discrimination or retaliation, that the professor’s social media posts did not constitute protected speech on matters of public concern under the First Amendment, and that there was insufficient evidence to support a perceived-disability claim. The court clarified that adverse employment actions under Title VII need only cause some harm, but found the university’s reasons for its decisions were not pretextual. View "GPat Patterson v. Kent State University" on Justia Law

WOOLARD V. THURMOND

2025-09-11T08:30:45-08:00

Parents and guardians of students enrolled in independent study programs at two California charter schools requested that the schools purchase and allow the use of sectarian curricular materials for instruction. The schools denied these requests, citing California laws that prohibit the teaching of sectarian or denominational doctrine in public schools, including charter schools. The plaintiffs argued that the independent study programs were essentially homeschooling and that the denial of their requests violated their rights under the Free Exercise and Free Speech Clauses of the First Amendment. The United States District Court for the Eastern District of California dismissed the complaint for failure to state a claim. The court found that charter schools are part of California’s public school system and are permitted to provide strictly secular education. It concluded that the plaintiffs were not being excluded from a generally available public benefit because of their religious exercise, as the case involved state-funded public schools rather than private schools. The court also held that a public school’s curriculum constitutes government speech, which is not subject to scrutiny under the Free Speech Clause. On appeal, the United States Court of Appeals for the Ninth Circuit affirmed the district court’s dismissal. The Ninth Circuit held that, even assuming the funding and materials provided in independent study programs are a generally available public benefit, the programs are sufficiently public to allow California to require the use of secular curricula. The court further held that the curriculum decisions of public schools are government speech and thus not subject to the Free Speech Clause. The judgment of the district court was affirmed. View "WOOLARD V. THURMOND" on Justia Law

Mid Vermont Christian School v. Saunders

2025-09-09T06:30:12-08:00

A private Christian school in Vermont forfeited a girls’ basketball playoff game because it objected, on religious grounds, to playing against a team with a transgender athlete. The school believes that requiring its female athletes to compete against biological males would violate its religious convictions about the immutability of sex. Following the forfeit, the Vermont Principals’ Association (VPA), which oversees extracurricular activities for Vermont schools, expelled the school from all state-sponsored extracurricular activities, including both athletic and non-athletic events. After the expulsion, the school and several students and parents filed suit in the United States District Court for the District of Vermont, seeking a preliminary injunction to reinstate the school’s VPA membership and alleging a violation of their rights under the Free Exercise Clause of the First Amendment. The district court denied the motion, finding that the VPA’s policies regarding transgender athletes were neutral and generally applicable, and thus subject only to rational-basis review. The court concluded that the plaintiffs were unlikely to succeed on the merits of their claim. On appeal, the United States Court of Appeals for the Second Circuit reviewed the district court’s denial of a preliminary injunction. The Second Circuit held that the plaintiffs are likely to succeed in showing that the VPA’s expulsion was not neutral, as it was accompanied by official expressions of hostility toward the school’s religious beliefs. The court found that the plaintiffs also satisfied the requirements of irreparable harm and public interest. Accordingly, the Second Circuit reversed the district court’s order and remanded the case with instructions to grant a preliminary injunction reinstating the school’s VPA membership pending further proceedings. View "Mid Vermont Christian School v. Saunders" on Justia Law

Doe R.L. v. Merced City School District

2025-09-08T12:00:58-08:00

A plaintiff alleged that, between 1965 and 1969, while he was a young child attending an elementary school in a California school district, he was repeatedly sexually assaulted by the school’s principal. The complaint stated that school staff and faculty were aware or suspected the abuse, and that similar abuse occurred to other students. The plaintiff claimed ongoing psychological and emotional harm as a result. He brought four negligence-based causes of action against the school district, asserting that he was not required to present a government tort claim before filing suit due to statutory changes exempting such claims. The Superior Court of Merced County sustained the school district’s demurrer without leave to amend, dismissing the complaint. The court found that the plaintiff’s failure to comply with the Government Claims Act’s claim presentation requirement was fatal to his case, and concluded that legislative changes extending the statute of limitations for childhood sexual assault did not alter the deadline for filing a claim against a public entity. On appeal, the California Court of Appeal, Fifth Appellate District, reviewed whether Assembly Bill No. 218’s retroactive waiver of the Government Claims Act’s claim presentation requirement for claims under Code of Civil Procedure section 340.1 violated the California Constitution’s gift clause. The appellate court held that the retroactive waiver did not create a new liability or cause of action, but merely removed a procedural barrier to suit. The court further found that the legislative purpose of aiding victims of childhood sexual assault served a valid public purpose and did not constitute an unconstitutional gift of public funds. The judgment of dismissal was reversed and the case remanded for further proceedings. View "Doe R.L. v. Merced City School District" on Justia Law

Larsen v. Sarpy Cty. Sch. Dist. No. 77-0027

2025-09-05T05:38:16-08:00

An 11-year-old child with significant disabilities, including autism and other disorders, attended a public elementary school where staff were aware of his special needs and history of leaving school grounds when unsupervised. Despite this knowledge, the child was left alone multiple times, and on May 17, 2021, he walked out of the school unattended and was never seen again. His mother, acting as his legal guardian, alleged that the school district and staff negligently supervised her son, leading to his disappearance and likely death or serious harm. She also claimed severe emotional distress resulting from the incident. The mother filed suit in the District Court for Sarpy County under the Political Subdivisions Tort Claims Act (PSTCA), naming the school district and three staff members as defendants. The defendants moved to dismiss, arguing the claims were barred by sovereign immunity under the PSTCA’s due care and discretionary function exemptions, and that the complaint failed to state a claim for negligent infliction of emotional distress. The district court granted the motion, finding both exemptions applied and that the emotional distress claim was either barred or insufficiently pled. The court dismissed the complaint without leave to amend. On appeal, the Nebraska Supreme Court reviewed the dismissal de novo. The court held that, based solely on the complaint’s allegations and reasonable inferences, it could not determine whether the PSTCA exemptions applied, as a more developed factual record was needed. The court also found the complaint alleged sufficient facts to state plausible claims for negligent supervision and negligent infliction of emotional distress. The Nebraska Supreme Court reversed the district court’s dismissal and remanded the case for further proceedings. View "Larsen v. Sarpy Cty. Sch. Dist. No. 77-0027" on Justia Law

Doe v. Mount Pleasant Elementary School District

2025-08-29T15:31:00-08:00

A public elementary school district arranged for its students to attend a four-day overnight outdoor science camp operated by the county office of education. The county office provided direct overnight supervision, while district teachers were present but only on call. A student alleged that, during her attendance at the camp as a fifth grader, she was repeatedly sexually assaulted by a county office employee who served as a night monitor. The student claimed that both the district and the county office knew or should have known of the employee’s prior misconduct and failed to protect her. The student filed a negligence claim against the district, the county office, and the employee. The district moved for summary judgment in the Santa Clara County Superior Court, arguing that it was immune from liability under Education Code sections 35330 and 44808. The district contended that the camp was a “field trip or excursion” subject to a statutory waiver of claims and that, alternatively, it could not be liable because its employees were not providing immediate and direct supervision at the time of the alleged assaults. The trial court granted summary judgment for the district based solely on section 35330, finding the statutory waiver applied. The California Court of Appeal, Sixth Appellate District, reviewed the case de novo. It held that the district failed to establish as a matter of law that the camp was a “field trip or excursion” under section 35330, as the program was part of the required science curriculum rather than a recreational or observational departure. The court also found the district did not meet its burden under section 44808 to show that no district employee should have been providing immediate and direct supervision, especially in light of allegations that the district knew of risks posed by the county employee. The appellate court reversed the summary judgment in favor of the district. View "Doe v. Mount Pleasant Elementary School District" on Justia Law

Chen v. Hillsdale College

2025-08-28T09:31:03-08:00

Two students at a private college in Michigan alleged that they were sexually assaulted by fellow students—one incident occurring in an on-campus dormitory and the other in an off-campus apartment. Both students reported the assaults to college officials, who initiated investigations led by outside lawyers. The students claimed that the college’s response was inadequate: one student’s assailant received no additional punishment due to a prior infraction, and the other’s assailant was disciplined but later allowed to rejoin the baseball team. Both students experienced emotional distress and academic or personal setbacks following the incidents. The students filed suit in the United States District Court for the Western District of Michigan, asserting state-law claims for negligence, intentional infliction of emotional distress, and sex discrimination under Michigan’s civil rights statute, on behalf of themselves and a proposed class. The district court granted the college’s motion to dismiss for failure to state a claim, finding that the plaintiffs had not alleged sufficient facts to support any of their claims. On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the dismissal de novo. The court held that Michigan law does not impose a general duty on colleges to protect students from criminal acts by third parties, absent a special relationship or foreseeability of imminent harm to identifiable individuals, neither of which was present here. The court also found that the alleged conduct by the college did not rise to the level of “extreme and outrageous” required for an intentional infliction of emotional distress claim. Finally, the court concluded that the plaintiffs failed to allege facts showing either disparate treatment or disparate impact based on sex under Michigan’s civil rights law. Accordingly, the Sixth Circuit affirmed the district court’s dismissal of all claims. View "Chen v. Hillsdale College" on Justia Law

Mackey v. Krause

2025-08-28T07:17:55-08:00

A teacher at a public charter school in Utah was terminated after a series of events involving a student and the student's parent. The teacher, a former Air Force veteran, reprimanded the student for disruptive behavior, leading the student to quit the team and report the incident to his father. The parent, dissatisfied with the teacher's conduct, began raising concerns about the teacher's alleged inappropriate behavior, including claims of physical and verbal abuse, to school administrators and at a school board meeting. The parent also communicated these concerns to the school superintendent and, according to the teacher, made a report to local police. Investigations by both the police and the Division of Child and Family Services found no evidence of abuse, and the teacher was ultimately terminated without a stated reason. The teacher filed suit in the Third District Court, Salt Lake County, alleging defamation, intentional infliction of emotional distress (IIED), abuse of process, and tortious interference with economic relations. The parent moved for early dismissal under Utah’s Uniform Public Expression Protection Act (UPEPA), arguing the statute protected his speech and actions. The district court denied the motion, finding UPEPA inapplicable and concluding that the teacher had stated prima facie cases for all claims. On direct appeal, the Supreme Court of the State of Utah held that the district court erred in finding UPEPA did not apply, as the parent’s statements concerned a matter of public concern. The Supreme Court also found that the teacher failed to state prima facie cases for IIED and abuse of process, requiring dismissal of those claims. The court vacated the denial of the special motion as to defamation and tortious interference, remanding for further consideration of whether the teacher could establish a prima facie case, particularly regarding privilege. The court ordered costs and fees related to the motion be awarded as provided by UPEPA. View "Mackey v. Krause" on Justia Law

O.B. v. L.A. Unified School Dist.

2025-08-27T12:31:13-08:00

In 2021, a plaintiff filed a complaint against a public school district, alleging that she was repeatedly sexually assaulted by a teacher while attending middle and high school. The complaint asserted that the teacher’s abusive conduct was widely known within the school and that the district either knew or should have known about the abuse but failed to act, allowing the teacher to remain employed. The plaintiff brought claims for negligence and negligent hiring, retention, and supervision, relying on statutory provisions that exempt certain childhood sexual assault claims from the usual requirement to present a claim to the public entity before filing suit. The Superior Court of Los Angeles County reviewed the case after the school district moved for judgment on the pleadings. The district argued that the plaintiff’s claims were only possible due to Assembly Bill 218 (AB 218), which retroactively eliminated the claims presentation requirement for childhood sexual assault claims against public entities. The district contended that AB 218 violated the gift clause of the California Constitution by imposing liability for past acts where no enforceable claim previously existed. The trial court agreed, finding that AB 218 retroactively created liability and constituted an unconstitutional gift of public funds, and dismissed the complaint with prejudice. The California Court of Appeal, Second Appellate District, Division One, reviewed the trial court’s decision de novo. The appellate court held that AB 218 does not violate the gift clause because it did not create new substantive liability; rather, it removed a procedural barrier to enforcing pre-existing liability for negligence and negligent hiring, retention, and supervision. The court reversed the trial court’s order and remanded with directions to deny the school district’s motion for judgment on the pleadings. View "O.B. v. L.A. Unified School Dist." on Justia Law

DUDLEY V. BOISE STATE UNIVERSITY

2025-08-27T08:31:19-08:00

A university revoked a student’s bachelor’s degree in social work after being informed by a state agency that, during her internship, she accessed confidential information in a state database without authorization. The university retroactively changed her grade for the internship course to failing, notified her that her degree and diploma were invalid, and initiated disciplinary proceedings. The student, who had already graduated and obtained a social work license, challenged the university’s actions, arguing that her procedural and substantive due process rights under the Fourteenth Amendment were violated. The United States District Court for the District of Idaho dismissed the student’s complaint for failure to state a claim. The court found that she did not have a protected property interest in her degree, grade, or the disciplinary process, and that, even if such an interest existed, the university provided adequate process. The court also concluded that she failed to plausibly allege that she was unable to pursue a career in social work, and held that the defendants were entitled to qualified immunity because any rights at issue were not clearly established. The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that the student’s university degree is a property interest protected by the Fourteenth Amendment and that the university failed to provide adequate process before revoking it. Specifically, the court found that the student plausibly alleged she was denied sufficient time to present her defense and was not allowed to cross-examine university-affiliated witnesses at her conduct hearing. The court reversed the district court’s dismissal of the procedural due process claim on these grounds and remanded for further proceedings. The court affirmed the dismissal of the substantive due process claim and the grant of qualified immunity to the defendants for monetary relief. The appeal of the denial of a preliminary injunction was dismissed as moot. View "DUDLEY V. BOISE STATE UNIVERSITY" on Justia Law

Hedgepeth v Britton

2025-08-26T06:30:43-08:00

A high school social studies teacher with a history of disciplinary issues was terminated after posting inflammatory messages on her Facebook account, which was followed primarily by former students. The posts, made during nationwide protests following the killing of George Floyd, included comments and memes that were perceived as racially insensitive and vulgar. Although the teacher had set her account to private and did not accept friend requests from current students, the posts quickly circulated within the school community, prompting complaints from students, parents, staff, and widespread media attention. The school district cited her prior suspensions for similar conduct, the disruption caused by her posts, and her failure to appreciate the impact of her comments as reasons for her dismissal. After her termination, the teacher requested a review hearing before the Illinois State Board of Education, where she argued that her Facebook posts were protected by the First Amendment. The hearing officer applied the Pickering balancing test and found that her dismissal did not violate her constitutional rights. Subsequently, the teacher filed suit in the United States District Court for the Northern District of Illinois, Eastern Division, against the school district and associated individuals under 42 U.S.C. § 1983, alleging a First Amendment violation. The district court granted summary judgment for the defendants, finding that she was collaterally estopped from bringing her claim and, alternatively, that her claim failed on the merits. On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s judgment. The Seventh Circuit held that the teacher failed to present sufficient evidence for a reasonable juror to find in her favor on her First Amendment claim. Applying the Pickering balancing test, the court concluded that the school district’s interest in addressing actual and potential disruption outweighed the teacher’s interest in free expression, and her posts were not entitled to First Amendment protection. View "Hedgepeth v Britton" on Justia Law

Malick v. Croswell-Lexington Dist. Schs.

2025-08-25T07:30:16-08:00

A student, C.M., experienced repeated racial harassment by peers while attending public school in Michigan, including being subjected to racial slurs, threats, and physical assault. The harassment occurred during her sixth, seventh, and ninth grades, prompting her to transfer to another school district in her freshman year. C.M. and her parents alleged that the school district and its officials failed to adequately respond to her complaints, asserting violations of federal law (Title VI of the Civil Rights Act and the Equal Protection Clause) and Michigan’s Elliott-Larsen Civil Rights Act. The United States District Court for the Eastern District of Michigan reviewed the case and granted summary judgment in favor of the school district and its officials. The district court found that, even when viewing the facts in the light most favorable to C.M., the school’s responses to the reported incidents did not amount to deliberate indifference under the applicable legal standards. C.M. appealed this decision to the United States Court of Appeals for the Sixth Circuit. The United States Court of Appeals for the Sixth Circuit affirmed the district court’s judgment. The appellate court assumed, without deciding, that deliberate indifference claims are cognizable under Title VI for student-on-student racial harassment. Applying the deliberate indifference standard, the court held that the school’s responses to each reported incident were not clearly unreasonable and reflected good faith efforts, including investigations, disciplinary actions, and proactive measures. The court concluded that C.M. failed to establish deliberate indifference, and therefore her claims under Title VI, the Equal Protection Clause, and the Elliott-Larsen Civil Rights Act could not succeed. The judgment of the district court was affirmed. View "Malick v. Croswell-Lexington Dist. Schs." on Justia Law

Doe v. DC

2025-08-19T06:32:52-08:00

A high school student in the District of Columbia was sexually assaulted by a classmate in a school bathroom. The student’s mother reported the incident to school officials, prompting an investigation by the District. The District ultimately found the assault claim credible and took steps to support the student, including offering counseling and a school transfer. However, the school principal, before any investigation, expressed disbelief in the student’s claim, made derogatory remarks about her, and attempted to undermine the investigation, even after video evidence corroborated the student’s account. The principal’s conduct included misleading superiors and withholding information. The student and her mother later learned of these actions, which caused them significant distress. The United States District Court for the District of Columbia dismissed the student’s claim for negligent infliction of emotional distress (NIED) for failure to state a claim, finding that the school-student relationship alone did not create a special duty under D.C. law. After discovery, the court granted summary judgment to the defendants on the intentional infliction of emotional distress (IIED) and Title IX claims, holding that the District’s response was not deliberately indifferent and that the principal’s conduct did not meet the standard for IIED because the remarks were made outside the student’s presence. The United States Court of Appeals for the District of Columbia Circuit affirmed the dismissal of the NIED claim and the grant of summary judgment to the District on the Title IX claims, finding the District’s overall response was not clearly unreasonable and that the principal’s actions could not be attributed to the District for Title IX retaliation. However, the appellate court reversed the grant of summary judgment on the IIED claim against the principal, holding that a reasonable jury could find her conduct was extreme and outrageous, intended or recklessly caused severe emotional distress, and remanded for further proceedings on that claim. View "Doe v. DC" on Justia Law

Penncrest SD v. Cagle

2025-08-19T05:15:20-08:00

A high school in a Pennsylvania school district displayed approximately 70 books in its library, some of which addressed LGBTQ+ issues in anticipation of Pride Month. A third-party contractor photographed the display and posted it on Facebook. Two school board members, David Valesky and Luigi DeFrancesco, shared the post on their personal Facebook accounts, with Valesky adding commentary critical of the display. This sparked public debate, including a newspaper article and discussions at subsequent school board meetings. Thomas Cagle, a local resident, submitted a request under Pennsylvania’s Right-to-Know Law (RTKL) seeking, among other things, all Facebook posts and comments by the two board members related to homosexuality and the school district. The school district partially denied the request, providing some emails but refusing to disclose any social media content, arguing that the posts were on personal accounts and not within the district’s possession. Cagle appealed to the Pennsylvania Office of Open Records (OOR), which ordered disclosure, reasoning that the content, not the ownership of the account, determined whether the posts were public records. The district sought judicial review in the Court of Common Pleas of Crawford County, which agreed with the OOR and ordered disclosure, finding that the posts documented district business and were thus subject to the RTKL. On appeal, the Commonwealth Court vacated the trial court’s order and remanded for further proceedings, instructing the lower court to consider additional factors to determine whether the posts were “of the agency” under the RTKL. The Supreme Court of Pennsylvania reviewed the case and held that the RTKL’s two-part test—whether the information documents a transaction or activity of an agency and was created, received, or retained in connection with agency business—applies to all forms of communication, including social media. The Court affirmed the Commonwealth Court’s order to remand for further fact-finding, clarifying that no special test applies to social media, but relevant facts must be considered in each case. View "Penncrest SD v. Cagle" on Justia Law

E.D. v Noblesville School District

2025-08-14T13:30:18-08:00

A high school student sought to establish a pro-life student club at her public high school. The school promptly approved the club after she followed the required procedures, including securing a faculty sponsor and submitting a club questionnaire. The student actively promoted the club at the school’s activities fair, wearing pro-life apparel and displaying related signs. The dispute arose when the student submitted flyers containing political slogans and images for posting on school walls. Administrators instructed her to revise the flyers to comply with the school’s neutral content policy, which limited flyers to the club’s name and meeting details and excluded political content. Instead of revising the flyers, the student and her mother approached another administrator to seek approval, which led the principal to suspend the club’s status for the semester, citing concerns that the club was no longer student-led and that established procedures had been violated. The student was allowed to reapply, and the club was later reinstated. The student and her parents filed suit in the United States District Court for the Southern District of Indiana, alleging violations of the First Amendment and the Equal Access Act, claiming that the rejection of the flyers and the club’s suspension were motivated by hostility to her pro-life views. The district court granted summary judgment to the school district and officials, finding no constitutional or statutory violations. The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s judgment. The Seventh Circuit held that the school’s restriction on political content in student club flyers was a reasonable, viewpoint-neutral policy related to legitimate pedagogical concerns under Hazelwood School District v. Kuhlmeier. The court also found that the temporary suspension of the club was based on neutral, conduct-related reasons and not on the student’s viewpoint. The court further held that there was no violation of the Equal Access Act and that the plaintiffs had not preserved a separate claim regarding the flyers under that statute. View "E.D. v Noblesville School District" on Justia Law

FOOTHILLS CHRISTIAN MINISTRIES V. JOHNSON

2025-08-14T08:00:43-08:00

Three California churches sought to challenge the California Child Day Care Facilities Act and its regulations, which require child day care facilities to be licensed, ensure that children are free to attend religious services or activities of their choice as decided by a child’s authorized representative, and provide notice to parents of this right. The churches, which either had their license revoked or had not yet applied for one, alleged that these requirements conflicted with their religious beliefs and practices, particularly their desire to operate preschools with mandatory religious curricula and without state licensure. Previously, the United States District Court for the Southern District of California dismissed the churches’ Free Speech and Free Exercise claims for lack of standing, and their Establishment Clause and Due Process claims for failure to state a claim. The district court entered judgment in favor of the state officials after the churches declined to amend their complaint. The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that the churches lacked standing to challenge the religious services provision under the Free Exercise Clause because there was no credible threat of enforcement against their intended conduct, given the state’s disavowal of such enforcement and the absence of any history of similar prosecutions. However, the court found that the churches had standing to challenge the licensure requirement under the Free Exercise Clause, but concluded that the requirement was neutral and generally applicable, thus subject only to rational basis review, which it satisfied. The court also rejected the Establishment Clause challenge, finding that the statutory exemptions were based on program type, not religion. The court found standing for the Free Speech challenge to the notice requirement but held that the compelled disclosure was factual, uncontroversial, and reasonably related to a substantial government interest. The Due Process challenge was also rejected. The court affirmed the district court’s judgment but remanded to amend the judgment so that the dismissal of the Free Exercise challenge to the religious services provision would be without prejudice. View "FOOTHILLS CHRISTIAN MINISTRIES V. JOHNSON" on Justia Law

LONG V. COMMONWEALTH OF KENTUCKY

2025-08-14T06:15:04-08:00

Several individuals who allegedly owed debts to Kentucky public institutions—either for medical services at the University of Kentucky or for educational services at the University of Kentucky, Morehead State University, or the Kentucky Community & Technical College System—challenged the referral of their debts to the Kentucky Department of Revenue for collection. The plaintiffs argued that the statutes used to justify these referrals did not apply to their debts and that the Department unlawfully collected the debts, sometimes without prior court judgments or adequate notice. The Department used its tax collection powers, including garnishments and liens, to recover these debts, and in some cases, added interest and collection fees. In the Franklin Circuit Court, the plaintiffs sought declaratory and monetary relief, including refunds of funds collected. The Circuit Court ruled that the Department was not authorized by statute to collect these debts and held that sovereign immunity did not protect the defendants from the plaintiffs’ claims. The court also certified the medical debt case as a class action. The Court of Appeals reviewed these interlocutory appeals and held that while sovereign immunity did not bar claims for purely declaratory relief, it did bar all claims for monetary relief, including those disguised as declaratory relief. The Supreme Court of Kentucky reviewed the consolidated appeals. It held that sovereign immunity does not bar claims for purely declaratory relief or for a refund of funds that were never due to the state, nor does it bar constitutional takings claims. However, the court held that sovereign immunity does bar claims for a refund of funds that were actually due to the state, even if those funds were unlawfully or improperly collected. The court affirmed in part, reversed in part, and remanded for further proceedings to determine which funds, if any, were never due to the state and thus subject to refund. The court also found that statutory changes rendered prospective declaratory relief in the medical debt case moot, but not retrospective relief. View "LONG V. COMMONWEALTH OF KENTUCKY" on Justia Law

Keene Publ'g Corp. v. Fall Mountain Reg'l Sch. Dist.

2025-08-12T05:12:54-08:00

A newspaper requested records from a school district related to an investigation into allegations that a long-time employee had sexually harassed other employees. The district hired a law firm to conduct a Title IX investigation, which resulted in a report. The district and the employee entered into a settlement agreement ending his employment, with the district paying him a lump sum and a portion of his health insurance. The newspaper sought all documents related to the investigation and settlement, but the district repeatedly denied the requests, citing statutory exemptions for confidential and personnel records. The Superior Court of New Hampshire reviewed the case after the newspaper filed suit. The court granted the district’s request for in camera review of the records, conducted the review without counsel present, and ordered redacted records to be distributed. It found that some records were protected by attorney-client privilege or the attorney work product doctrine and exempt under RSA 91-A:5, XII. The court also found that the remaining records, including the settlement agreement, were exempt as confidential or personnel files under RSA 91-A:5, IV. The court denied the newspaper’s request for attorney’s fees and costs, concluding the district had satisfied its obligations regarding records of payments to the employee. The Supreme Court of New Hampshire held that in camera review without counsel present is permissible when disclosure may cause an invasion of privacy. It affirmed that records protected by attorney-client privilege or the attorney work product doctrine are exempt from disclosure without a balancing test. However, it found the lower court erred in applying the exemption for confidential and personnel files, holding that the public interest in disclosure outweighed privacy concerns if identifying information was redacted. The court also held that the district must disclose unaltered records of payments made to the employee and awarded attorney’s fees and costs for that violation. The case was affirmed in part, reversed in part, and remanded. View "Keene Publ'g Corp. v. Fall Mountain Reg'l Sch. Dist." on Justia Law

Blair v. Appomattox County School Board

2025-08-07T10:30:32-08:00

A 14-year-old student, S.B., who had a history of trauma and mental health challenges, began high school in Appomattox County, Virginia, in August 2021. S.B. identified as male at school and was advised by a counselor that he could use the boys’ restroom. Following this, S.B. was subjected to harassment, threats, and sexual assault by male students. School staff, including counselors, were aware of the harassment and S.B.’s mental health vulnerabilities but did not inform S.B.’s adoptive mother, Blair, about the gender identity issues, the bullying, or the school’s responses. Instead, staff continued to affirm S.B.’s male identity without parental notification and failed to take effective action to stop the harassment. After a series of escalating incidents, S.B. suffered a breakdown, ran away, and was subsequently victimized by sex traffickers. Blair filed suit in the United States District Court for the Western District of Virginia against the school board and staff, alleging deliberate indifference to sexual harassment under Title IX, Monell liability for unconstitutional policy or failure to train, and violations of substantive due process rights. The district court dismissed all claims, finding insufficient allegations of deliberate indifference or Monell liability, and granted qualified immunity to the individual defendants on the due process claims. On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s dismissal de novo. The Fourth Circuit held that Blair’s Title IX claim for deliberate indifference against the school board was sufficiently pleaded and should not have been dismissed, as the complaint alleged the school’s response to known harassment was clearly unreasonable. However, the court affirmed dismissal of the Monell and substantive due process claims, finding the allegations were conclusory or the rights not clearly established. The case was affirmed in part, reversed in part, and remanded for further proceedings on the Title IX claim. View "Blair v. Appomattox County School Board" on Justia Law

Roe v. Marshall University Board of Governors

2025-07-31T11:01:18-08:00

The case involves Jane Roe, a student at Marshall University, who was sexually assaulted by her ex-boyfriend, John Doe, at an off-campus party following a football game in September 2022. Roe reported the incident to the police, who then informed the university. The university's Title IX office reviewed the case but determined it fell outside their jurisdiction as the incident occurred off-campus and was not part of a university-sponsored event. The matter was referred to the Office of Student Conduct, which investigated and disciplined both Doe and Roe for their respective violations of the Student Code. In the United States District Court for the Southern District of West Virginia, Roe filed a lawsuit against the Marshall University Board of Governors, alleging deliberate indifference and retaliation under Title IX. The district court granted summary judgment in favor of the university, finding that the university's response did not amount to deliberate indifference and that the university did not retaliate against Roe for reporting the assault. The United States Court of Appeals for the Fourth Circuit reviewed the case de novo. The court affirmed the district court's decision, holding that the university did not have substantial control over the context of the harassment, as the incident occurred at a private off-campus residence. Additionally, the court found that Roe failed to provide sufficient evidence to show that the university's reasons for disciplining her were pretextual. The court concluded that the university's actions were not retaliatory and upheld the summary judgment in favor of the university. View "Roe v. Marshall University Board of Governors" on Justia Law

Doe v. University of Massachusetts

2025-07-25T13:30:07-08:00

A graduate student and resident advisor (RA) at the University of Massachusetts, John Doe, was found responsible for sexual misconduct by the University in 2023. The University sanctioned him based on complaints from four female RAs about his interactions with them. Doe filed a federal lawsuit against the University, its trustees, and the members of the hearing panel, alleging that the University violated his First Amendment rights by punishing him for protected speech and expressive conduct. He sought a preliminary injunction, which the district court considered on a "case stated" basis, consolidating the preliminary injunction hearing with the trial on the merits. The district court ruled against Doe, finding that his First Amendment rights had not been violated. The court applied the Tinker standard, determining that the University's actions were justified because Doe's conduct caused or would cause a substantial disruption and invaded the rights of others. The court also held that the Individual Defendants were entitled to qualified immunity for monetary damages. Doe appealed the decision. The United States Court of Appeals for the First Circuit reviewed the case. The court found that the record lacked evidence of substantial disruption to the academic environment or the complainants' jobs. The court also concluded that Doe's conduct did not constitute a pervasive pattern of unwelcome conduct. Therefore, the court held that the University's actions were not justified under the Tinker standard. However, the court affirmed the district court's ruling that the Individual Defendants were entitled to qualified immunity, as the law was not clearly established that their actions violated Doe's First Amendment rights. The judgment was reversed in part and affirmed in part. View "Doe v. University of Massachusetts" on Justia Law

N.G.B. v. New York City Department of Education

2025-07-24T07:00:12-08:00

N.G.B., on behalf of her child J.B., filed a due process complaint against the New York City Department of Education (DOE) alleging that DOE failed to provide J.B. with a free appropriate public education (FAPE) for the 2019-2020 school year. An impartial hearing officer ruled in favor of N.G.B. Subsequently, N.G.B. sought attorneys' fees under the Individuals with Disabilities Education Act (IDEA). The district court found the claimed hourly rates and hours expended by N.G.B.'s counsel to be unreasonable and adjusted them. However, it also found that N.G.B. was substantially justified in rejecting a settlement offer from DOE, allowing her to recover fees and costs incurred post-rejection. The United States District Court for the Southern District of New York granted in part and denied in part N.G.B.'s motion for summary judgment. The court reduced the claimed hourly rates and hours but found that DOE's settlement offer did not account for significant work performed by N.G.B.'s counsel. The court concluded that N.G.B. was substantially justified in rejecting the offer, as it was based on outdated billing records and did not reflect the actual work done. The United States Court of Appeals for the Second Circuit reviewed the case. The court affirmed the district court's judgment, holding that the district court applied the correct standard in determining substantial justification. The appellate court agreed that a prevailing parent under the IDEA can be substantially justified in rejecting a settlement offer if they have a good-faith, reasonable belief that the offer does not adequately compensate for the work performed. The court found no abuse of discretion in the district court's findings and reasoning, concluding that the rejection of DOE's offer was substantially justified. View "N.G.B. v. New York City Department of Education" on Justia Law

Royan v. Chicago State University

2025-07-22T11:30:16-08:00

Ayla Royan, a student in Chicago State University's (CSU) Doctor of Pharmacy program, was dismissed after failing two clinical rotations. Royan, who has clinical depression and an eating disorder, claimed her dismissal was due to her disabilities. CSU had accommodated her conditions by granting exam and assignment extensions and a yearlong medical leave. Despite these accommodations, Royan failed her first clinical rotation under Dr. Patel and her second under Dr. Kerner, leading to her dismissal. The United States District Court for the Northern District of Illinois granted summary judgment in favor of CSU, finding that Royan failed to present sufficient evidence that her dismissal was solely based on her disability. The court held that CSU had accommodated her disabilities and applied its academic standards without discrimination. The United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The appellate court held that Royan was not "otherwise qualified" for the program as she failed to meet the academic requirements, specifically passing the clinical rotations. The court also found no evidence of pretext in CSU's stated reasons for her dismissal. Additionally, the court concluded that no reasonable jury could find that CSU dismissed Royan solely because of her disabilities, as required under Section 504 of the Rehabilitation Act. The court emphasized that academic institutions have broad discretion in setting and enforcing academic standards, and CSU's actions were consistent with its policies and procedures. View "Royan v. Chicago State University" on Justia Law