Justia Education Law Opinion Summaries

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

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

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

An eight-year-old student, J.S., was sexually assaulted by her bus driver, Sergio Sandoval, multiple times over a month. J.S.'s parents filed a lawsuit against the Ocean Springs School District under the Mississippi Tort Claims Act, alleging negligence, negligent hiring, retention, supervision, and training, failure to adopt and follow policies, negligent infliction of emotional distress, and civil assault, battery, and false imprisonment. The Jackson County Circuit Court granted summary judgment in favor of the District, finding it was entitled to discretionary-function immunity and that Sandoval’s actions were not reasonably foreseeable.The plaintiff appealed the decision. The Mississippi Supreme Court reviewed the case and determined that while the District was protected by discretionary-function immunity regarding the failure to adopt sufficient policies and procedures, the claims related to negligent hiring, supervision, and training were not barred by this immunity. The court found that these claims involved simple negligence and did not involve policy decisions.The court also held that the plaintiff had demonstrated a genuine issue of material fact regarding the foreseeability of the injuries. The court noted that the District’s own measures to screen and monitor its bus drivers indicated that a person of ordinary intelligence could anticipate that failure to properly do so could lead to the type of injury sustained by J.S.The Mississippi Supreme Court affirmed the lower court’s decision in part, reversed it in part, and remanded the case for further proceedings consistent with its findings. View "J.S. v. Ocean Springs School District" on Justia Law

The case involves the State of Alaska's statutes that allow local school districts to operate correspondence study programs and provide public funds for educational expenses. Parents of public school students sued the State, arguing that these statutes violated the Alaska Constitution by allowing public funds to be used for private school tuition, which they claimed was unconstitutional.The Superior Court of Alaska ruled that the statutes were facially unconstitutional and invalidated them entirely. The court did not address the narrower question of whether the statutes were unconstitutional when applied to allow public funds to be used for private school tuition. The decision was appealed to the Supreme Court of Alaska.The Supreme Court of Alaska reviewed the case and determined that the Superior Court's ruling went too far. The Supreme Court noted that the statutes allowed for a substantial number of constitutionally valid uses of allotment funds, such as purchasing books, supplies, and other educational materials. The court emphasized that even if using allotment funds for private school tuition were unconstitutional, it would not justify invalidating the entire statutes.The Supreme Court vacated the Superior Court's judgment and remanded the case for further proceedings. The court instructed that the proper parties must be joined, and the Superior Court must first determine whether the statutes actually permit the use of allotment funds for private school tuition before addressing the constitutionality of such use. The Supreme Court did not decide whether using allotment funds for private school tuition is constitutional, leaving that question open for further consideration. View "State of Alaska, Dept. of Education & Early Development v. Alexander" on Justia Law

A transgender student, Rebecca Roe, and the Sexuality and Gender Alliance (SAGA) at Boise High School challenged Idaho Senate Bill 1100 (S.B. 1100), which mandates that public school students use restrooms and changing facilities corresponding to their "biological sex." They argued that the law violates the Equal Protection Clause, Title IX, and the right to informational privacy. Roe and SAGA sought a preliminary injunction to prevent the law from being enforced.The United States District Court for the District of Idaho denied the preliminary injunction, concluding that SAGA was unlikely to succeed on the merits of its claims. The court found that the State's interest in protecting student privacy was an important governmental objective and that S.B. 1100 was substantially related to achieving that objective. The court also determined that SAGA did not show that the State had clear notice that Title IX prohibited segregated access to facilities based on transgender status. Additionally, the court found that SAGA did not demonstrate that S.B. 1100 violated the right to informational privacy.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court's decision. The Ninth Circuit agreed that SAGA did not establish a likelihood of success on the merits of its equal protection claim, as the State's interest in protecting bodily privacy was deemed important and the means chosen were substantially related to that objective. The court also held that SAGA failed to show that the State had clear notice that Title IX prohibited the exclusion of transgender students from facilities corresponding to their gender identity. Lastly, the court concluded that SAGA did not demonstrate that S.B. 1100 violated the right to informational privacy, as the statute did not necessarily disclose a student's transgender status. View "ROE V. CRITCHFIELD" on Justia Law

Jason Earlywine was employed as a teacher by the Board of Education of Paris Independent School District (BEP) from August 2007 to June 2019. In 2011, a student accused him of inappropriate conduct, leading to his placement on paid administrative leave, which was later changed to unpaid leave. He faced a criminal charge of Sexual Abuse in the First Degree, but the trial court granted him a directed verdict in January 2015, and the charge was expunged. Earlywine was reinstated in February 2015 but was terminated in 2019 for unspecified reasons. In 2020, he sued BEP to recover lost wages during his unpaid leave.The Bourbon Circuit Court initially handled the case, determining that BEP was within the waiver of immunity under KRS 45A.245(1) but transferred the case to Franklin Circuit Court due to venue appropriateness. BEP appealed, arguing governmental immunity and failure to exhaust administrative remedies. The Court of Appeals ruled that BEP's immunity was waived under KRS 45A.245(1) but concluded that Earlywine's failure to exhaust administrative remedies deprived the court of subject matter jurisdiction.The Supreme Court of Kentucky reviewed the case, affirming that BEP is subject to the waiver of immunity under KRS 45A.245(1). However, it reversed the Court of Appeals' conclusion regarding the exhaustion of administrative remedies, stating that this issue is subject to exceptions and should not have been addressed on interlocutory appeal. The Supreme Court remanded the case to Franklin Circuit Court for further proceedings, allowing Earlywine to argue any applicable exceptions to the exhaustion requirement. View "BOARD OF EDUCATION OF PARIS, KENTUCKY V. EARLYWINE" on Justia Law

Petitioner, a student at Stony Brook University, challenged the University's determination that he violated the University's Code of Student Responsibility by committing sexual misconduct against another student, S.G. The University conducted an investigation after receiving a report of the incident, during which S.G. provided a written statement detailing the encounter. P.C. declined to meet with the investigator. He was charged with sexual harassment, nonconsensual sexual contact, and nonconsensual sexual intercourse. A hearing was held, and the Review Panel found P.C. responsible for the charges, leading to his suspension.P.C. appealed the decision, arguing that the evidence did not support the findings and that the Review Panel improperly considered his decision to remain silent. The Appeals Committee upheld the Review Panel's determination and the disciplinary penalty. P.C. then commenced a CPLR article 78 proceeding, asserting that the determination lacked substantial evidence and was arbitrary and capricious.The Supreme Court transferred the case to the Appellate Division, which granted the petition, annulled the Appeals Committee's determination, dismissed the charges, and directed the University to expunge the matter from P.C.'s academic record. The Appellate Division majority found that substantial evidence did not support the conclusion that S.G. did not consent to the sexual activity and that the Review Panel improperly relied on P.C.'s decision not to answer questions.The Court of Appeals of New York reversed the Appellate Division's order, holding that substantial evidence supported the University's determination that P.C. violated the Code of Student Responsibility. The Court found that S.G.'s testimony and P.C.'s text messages provided sufficient evidence of nonconsensual sexual activity. The Court also rejected P.C.'s argument that the University's determination was arbitrary and capricious, concluding that the University followed its rules and procedures. The petition was dismissed. View "Matter of P.C. v Stony Brook Univ." on Justia Law

A school principal used the school's printer after hours to create a coaster as a retirement gift for a friend. The coaster design contained the School District's official logo but altered the District's motto in a disrespectful manner. A custodian took pictures of the coaster, which were shared on social media, leading to public outrage. The principal left the community the next day. The District proposed to terminate him for incompetence and violating anti-harassment policies. After a brief pretermination hearing, the District terminated the principal. The principal appealed, and the Board upheld the termination following an additional hearing.The principal then appealed to the superior court, which also affirmed his termination. The court found that the District had grounds to terminate the principal due to substantial noncompliance with District rules and regulations and that the community's reaction to the coaster was reasonable. The court also rejected the principal's free speech arguments, stating that his speech was not protected under the First Amendment. The court acknowledged that the pretermination hearing process was flawed but deemed the error harmless due to the subsequent post-termination hearing.The Supreme Court of the State of Alaska reviewed the case. The court held that the Board had a reasonable basis to terminate the principal for incompetency under AS 14.20.170(a)(1) due to his inability to perform his duties effectively after the incident. The court also concluded that the principal's termination did not violate his free speech rights under AS 14.20.095 or the First Amendment. However, the court found that the pretermination hearing process did not provide sufficient due process, as the principal was not informed of his right to call witnesses. The court affirmed the termination but reversed the superior court's decision denying back pay, awarding back pay through the date of the Board's post-termination hearing decision. View "Stirling v. North Slope Borough School District" on Justia Law

A tenured professor at the University of Illinois Chicago School of Law, Jason Kilborn, included an expurgated racial slur in a law school exam question. This led to an investigation by university officials, who found that Kilborn had created a racially hostile environment and violated the university's nondiscrimination policy. Consequently, Kilborn was suspended from teaching until he completed a diversity training program and was denied a two percent raise. Kilborn sued several university officials, alleging violations of his constitutional rights to free speech and due process.The United States District Court for the Northern District of Illinois dismissed Kilborn's federal claims with prejudice, finding that his speech was not constitutionally protected. The court also declined to exercise supplemental jurisdiction over his state law claims, dismissing them without prejudice. Kilborn appealed the decision.The United States Court of Appeals for the Seventh Circuit reviewed the case and reversed the dismissal of Kilborn's First Amendment retaliation claim, concluding that his speech was constitutionally protected under the Supreme Court's decisions in Connick v. Myers and Pickering v. Board of Education. The court found that Kilborn's speech addressed matters of public concern and that the university's actions could be seen as pretextual. However, the court affirmed the dismissal of Kilborn's remaining federal claims, including his compelled speech and procedural due process claims. The court also vacated the dismissal of Kilborn's state law claims for further consideration by the district court. View "Kilborn v. Amiridis" on Justia Law