Justia Government & Administrative Law Opinion Summaries

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

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

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

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

Nathan Zent, who has spastic quadriplegic cerebral palsy, has been a student at Dickinson State University (DSU) since 2015, pursuing a Bachelor of Arts in English with a Political Science Minor. Zent, who uses a motorized wheelchair and an iPad with text-to-speech assistive technology, received vocational rehabilitation (VR) services from the North Dakota Department of Health and Human Services (DHHS) from 2015 until May 2023. His individualized plan for employment (IPE) identified an employment outcome of journalist or writer, which DHHS supported until 2022. However, DHHS discontinued Zent’s services, citing concerns about his ability to achieve competitive integrated employment due to his need for significant support.The Division of Vocational Rehabilitation of DHHS decided to discontinue Zent’s VR services, and an administrative law judge (ALJ) affirmed this decision. Zent appealed to the district court of Stark County, which also affirmed the ALJ’s decision. Zent then appealed to the North Dakota Supreme Court, arguing that DHHS’s decision was based on an erroneous interpretation of the statutes and regulations governing VR services and that the ALJ applied the incorrect standard of proof.The North Dakota Supreme Court reviewed the case and affirmed the district court’s judgment. The court held that DHHS did not misapply the statutes and regulations governing VR services in determining that Zent’s chosen employment outcome of journalist or writer was inconsistent with the goal of competitive integrated employment. The court also concluded that the ALJ correctly applied the preponderance of the evidence standard, as the clear and convincing standard only applies to eligibility determinations for VR services, not to determinations regarding specific employment outcomes. View "Zent v. NDDHHS" on Justia Law

Fiorisce, LLC, a limited liability company, filed a qui tam lawsuit against Colorado Technical University (CTU) under the False Claims Act (FCA), alleging that CTU misrepresented compliance with federal credit hour requirements to fraudulently obtain federal student aid funds. Fiorisce claimed that CTU's online learning platform, Intellipath, provided insufficient educational content and falsified learning hour calculations to meet federal standards. Fiorisce's principal, a former CTU faculty member, created the company to protect their identity while exposing the alleged fraud.The United States District Court for the District of Colorado reviewed the case. CTU moved to dismiss the complaint, arguing that the FCA’s public disclosure bar precluded the suit because the allegations were substantially similar to previously disclosed information. The district court denied CTU’s motion, finding that Fiorisce’s specific claims about misrepresentation of credit hours and the use of Intellipath were not substantially the same as prior disclosures. The court also suggested that Fiorisce might qualify as an original source of the information.CTU appealed the district court’s denial of its motion to dismiss to the United States Court of Appeals for the Tenth Circuit, seeking interlocutory review under the collateral order doctrine. The Tenth Circuit concluded that the collateral order doctrine did not apply, as the public disclosure bar did not confer a right to avoid trial and could be effectively reviewed after final judgment. The court emphasized that expanding the collateral order doctrine to include such denials would undermine the final judgment rule and dismissed CTU’s appeal for lack of jurisdiction. View "Fiorisce, LLC v. Colorado Technical University" on Justia Law

William A., a dyslexic student, graduated from high school with a 3.4 GPA but was unable to read. His parents filed a complaint under the Individuals with Disabilities Education Act (IDEA), claiming the school failed to provide him with a free appropriate public education (FAPE). The school had developed an individualized education plan (IEP) for William, which included language therapy and one-on-one instruction, but he made no progress in reading fluency throughout middle and high school. His parents eventually arranged for private tutoring, which helped him make some progress.An administrative law judge (ALJ) held a due-process hearing and found that the school had violated William's right to a FAPE under the IDEA. The ALJ ordered the school to provide 888 hours of dyslexia tutoring. William's parents then sought an order in federal court for the tutoring to be provided by a specific tutor, Dr. McAfee. The school counterclaimed, seeking reversal of the ALJ's order. The district court, applying a "modified de novo" standard of review, affirmed the ALJ's findings and ordered the same relief but denied the request for Dr. McAfee specifically.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court found that the school had not provided William with a FAPE, as his IEPs focused on fluency rather than foundational reading skills necessary for him to learn to read. The court noted that William's accommodations masked his inability to read rather than addressing it. The court affirmed the district court's judgment, holding that the school failed to provide an education tailored to William's unique needs, as required by the IDEA. View "William A. v. Clarksville-Montgomery County School System" on Justia Law