Justia Government & Administrative Law Opinion Summaries

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

Plaintiff Curtis Hier requested records from the Slate Valley Unified School District related to incidents of restraint and seclusion of students at Fair Haven Grade School. Specifically, he sought redacted copies of "Rule 4500 forms" from January to April 2021, documents related to the use of certain rooms between 2015 and 2022, and any redacted restraint and seclusion documents concerning the assistant principal. The school district denied the requests, claiming the records were student records and thus exempt from disclosure under the Public Records Act.The Superior Court, Rutland Unit, Civil Division, denied the school district's motion for summary judgment and granted summary judgment to the plaintiff. The court found that the Rule 4500 forms were not student records but were meant for monitoring the use of restraint and seclusion in schools. It ordered the school district to disclose the forms with specific redactions to protect student privacy. The court also denied the plaintiff's motion to amend the judgment to remove certain redactions.The Vermont Supreme Court reviewed the case and reversed the trial court's decision. The Supreme Court held that the Rule 4500 forms are categorically exempt from disclosure as student records under the Public Records Act. The court emphasized that the language of the student records exception is broad and unqualified, similar to its previous ruling in Caledonian-Record Publishing Co. v. Vermont State Colleges. The court concluded that the forms, which contain information related to specific students and incidents, fall squarely within the statutory exception for student records and are not subject to redaction or disclosure. View "Hier v. Slate Valley Unified School District" on Justia Law

The Austin American-Statesman requested the University of Texas at Austin to disclose the final results of disciplinary hearings involving sex offenses. The University refused to provide the information without seeking a decision from the Office of the Attorney General (OAG). The Statesman sued the University, seeking a writ of mandamus to compel the disclosure of the records.The trial court granted the Statesman’s motion for summary judgment, ordering the University to produce the requested information. The court found that the University was required to seek an OAG decision and that its failure to do so raised the presumption that the information was subject to disclosure. The court of appeals affirmed the trial court’s decision, holding that the University did not establish a compelling reason for withholding the information and that Section 552.114(b) of the Texas Public Information Act (PIA) did not give the University discretion to withhold the records. The court of appeals also reversed the trial court’s denial of attorney fees to the Statesman.The Supreme Court of Texas reviewed the case and held that Section 552.026 of the PIA grants educational institutions discretion to disclose information in education records if the disclosure is authorized by the Family Educational Rights and Privacy Act (FERPA). The Court concluded that the PIA does not require the release of such information. Additionally, the Court held that the University was not required to seek an OAG decision before withholding the information, as Section 552.114(d) allows educational institutions to redact information without requesting an OAG decision. The Supreme Court of Texas reversed the court of appeals’ judgment and rendered judgment for the University. View "THE UNIVERSITY OF TEXAS AT AUSTIN v. GATEHOUSE MEDIA TEXAS HOLDINGS II, INC." on Justia Law

K.N., an eight-year-old boy with multiple disabilities, lives in a non-wheelchair-accessible apartment in the District of Columbia. His mother, Margda Pierre-Noel, requested that the District and his school, Bridges Public Charter School, provide assistance to move K.N. from their apartment door to the school bus. The District denied the request, citing its policy that staff only retrieve students from the outermost door of their dwelling and do not physically lift or carry students.The Office of the State Superintendent of Education (OSSE) hearing officer ruled that it was beyond his authority to order the requested assistance but required OSSE to offer transportation services to and from the outer door of K.N.'s apartment building. Pierre-Noel then filed a lawsuit in the United States District Court for the District of Columbia, which granted summary judgment in favor of the District, ruling that the service requested was not a transportation service under the Individuals with Disabilities Education Act (IDEA).The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court held that the IDEA requires the District to provide door-to-door transportation services for K.N., as such services are necessary for him to benefit from his special education. The court found that the term "transportation" under the IDEA includes moving a child from their apartment door to the vehicle that will take them to school. The court vacated the district court's grant of summary judgment and remanded the case for further proceedings consistent with its opinion. The appeal was dismissed as moot with respect to Bridges Public Charter School, as K.N. was no longer enrolled there. View "Pierre-Noel v. Bridges Public Charter School" on Justia Law

J.B., a student with multiple disabilities, was enrolled in the Kyrene Elementary School District. Due to concerns about the school's handling of J.B.'s behavioral issues, J.B.'s parent, L.B., withdrew J.B. from the District and placed J.B. in a private school, Brightmont Academy. The District attempted to conduct evaluations to update J.B.'s Individualized Education Program (IEP), but L.B. refused to consent to these evaluations, proposing instead that the District use video recordings for assessments.The Administrative Law Judge (ALJ) found that the District did not violate the Individuals with Disabilities Education Act (IDEA) and ruled in favor of the District. L.B. appealed to the U.S. District Court for the District of Arizona, which affirmed the ALJ's decision. The District Court found that L.B. refused to consent to the District's evaluations and made it clear that she did not intend to re-enroll J.B. in the District.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the District Court's judgment. The Ninth Circuit held that the District did not deny a Free Appropriate Public Education (FAPE) to J.B. because L.B.'s refusal to consent to evaluations relieved the District of further obligations under IDEA. Additionally, the court found that the District's procedural error in stating that no further IEP meetings would occur because J.B. was not enrolled in the District was harmless, as it did not result in a deprivation of educational opportunity for J.B. Consequently, L.B. was not entitled to reimbursement for private school tuition and related expenses. View "J.B. V. KYRENE ELEMENTARY SCHOOL DISTRICT NO. 28" on Justia Law

The case involves several states suing the President of the United States, the Secretary of Education, and the U.S. Department of Education to prevent the implementation of a plan to forgive approximately $475 billion in federal student loan debt. The plan, known as SAVE, significantly alters the existing income-contingent repayment (ICR) plan by lowering payment amounts, often to $0 per month, and forgiving principal balances much sooner than previous plans.The United States District Court for the Eastern District of Missouri granted a preliminary injunction in part, finding that Missouri had standing through its state instrumentality, MOHELA, which faced certain irreparable harm. The court concluded that the states had a fair chance of success on the merits, particularly that loan forgiveness under SAVE was not statutorily authorized and violated the separation of powers under the major-questions doctrine. However, the court only enjoined the ultimate forgiveness of loans, not the payment-threshold provisions or the nonaccrual of interest.The United States Court of Appeals for the Eighth Circuit reviewed the case and agreed with the district court that Missouri had standing. The court found that the states demonstrated a fair chance of success on the merits, noting that the SAVE plan's scope was even larger than a previously contested loan-cancellation program. The court also found that the Government's actions had rendered the district court's injunction largely ineffective. Balancing the equities, the court decided to grant in part and deny in part the states' motion for an injunction pending appeal, prohibiting the use of the hybrid rule to circumvent the district court's injunction. The injunction will remain in effect until further order of the court or the Supreme Court of the United States. View "State of Missouri v. Biden" on Justia Law

The case involves several special education students who alleged that their teacher physically and emotionally abused them. The students, who have various disabilities affecting their communication abilities, were assigned to the same classroom at Elm Street Elementary School in Coweta County, Georgia. The teacher, Catherine Sprague, was hired by the principal, Dr. Christi Hildebrand, despite lacking special education certification. Throughout the fall of 2019, the students exhibited signs of distress, and their parents noticed behavioral changes and physical signs of mistreatment. A paraprofessional, Nicole Marshall, reported multiple instances of abuse by Sprague to Hildebrand, who delayed reporting these allegations to law enforcement and the students' parents.The United States District Court for the Northern District of Georgia dismissed the students' complaint. The court ruled that emotional distress damages are not recoverable under Title II of the Americans with Disabilities Act (ADA) following the Supreme Court's decision in Cummings v. Premier Rehab Keller, P.L.L.C. The court also found that the students failed to state a constitutional violation against Hildebrand and the school district, and that Hildebrand was entitled to qualified immunity. The court declined to exercise supplemental jurisdiction over the state law negligence claim.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court affirmed that emotional distress damages are not recoverable under Title II of the ADA, as Title II incorporates the remedies of the Rehabilitation Act, which the Supreme Court in Cummings ruled does not allow for emotional distress damages. However, the appellate court found that the district court erred by not considering whether the students might be entitled to other forms of relief under Title II, such as damages for physical harm or nominal damages. The appellate court also affirmed the dismissal of the section 1983 claims, ruling that the alleged abuse did not meet the "shock-the-conscience" standard required for a substantive due process violation. The case was remanded for further proceedings to consider other potential relief under Title II. View "A.W. v. Coweta County School District" on Justia Law

The City of Helena appealed a decision by the Shelby Circuit Court that allowed the Pelham Board of Education (PBE) to acquire, develop, and use a piece of real property within Helena's corporate limits for an athletic field and parking lot to serve Pelham High School students. The property, purchased by the PBE in 2021, is adjacent to Pelham High School but located within Helena. Helena argued that the PBE lacked the authority to construct and operate school facilities outside Pelham's corporate limits and that the project violated Helena's zoning ordinance.The Shelby Circuit Court ruled in favor of the PBE, stating that city zoning ordinances do not apply to governmental functions performed by a government body. The court found that the PBE's construction of the athletic field was a governmental function related to public education, which is exempt from local zoning regulations. Helena appealed, arguing that the PBE's actions were not authorized under Alabama Code § 16-11-9 and that the project did not comply with Helena's zoning ordinance.The Supreme Court of Alabama affirmed the circuit court's decision. The court held that § 16-11-9 does not restrict a city board of education's powers to the geographic boundaries of the city it serves. The court also concluded that the PBE's construction and operation of the athletic field constituted a governmental function related to public education, which is exempt from municipal zoning ordinances. Therefore, Helena's zoning ordinance could not be enforced against the PBE's project. The court affirmed the circuit court's order, allowing the PBE to proceed with the development and use of the property. View "City of Helena v. Pelham Board of Education" on Justia Law

The plaintiffs, current or retired public school superintendents and administrators, filed a lawsuit against the Office of Retirement Services (ORS) alleging that ORS violated the Public School Employees Retirement Act by using salary schedules it created to determine their retirement allowances. The plaintiffs, who worked under personal employment contracts rather than collective bargaining agreements (CBAs), argued that the Retirement Act did not authorize ORS to create these normal salary increase (NSI) schedules and apply them to their pension calculations.The Court of Claims granted summary disposition in favor of the defendants on all claims except for a violation of the Administrative Procedures Act (APA). After cross-motions for summary disposition, the Court of Claims also ruled in favor of the defendants on the APA claim. The plaintiffs appealed, and the Court of Appeals reversed, holding that ORS lacked statutory authority to create NSI schedules and that MCL 38.1303a(3)(f) did not apply to employees under personal employment contracts. The Michigan Supreme Court affirmed the lack of authority for ORS to create NSI schedules but reversed the Court of Appeals' interpretation of MCL 38.1303a(3)(f), remanding the case for further proceedings.The Michigan Supreme Court held that the term "normal salary schedule" is a written document established by statute or approved by a reporting unit’s governing body, indicating the time and sequence of compensation, and applying to a generally applicable job classification rather than a specific employee. The Court clarified that this term is not limited to CBAs and applies to public school employees regardless of their employment contract type. The case was remanded to the Court of Claims to determine whether the plaintiffs were subject to a normal salary schedule as defined. View "Batista v. Office Of Retirement Services" on Justia Law

The case involves the Newport School Committee and the Cumberland School Committee (collectively, plaintiffs) and the Rhode Island Department of Education and the Rhode Island Council on Elementary and Secondary Education (collectively, defendants). The dispute arose when the plaintiffs refused to reimburse the Department of Children, Youth, and Families (DCYF) at the "per-pupil special-education" rate for the cost of educating children who were placed in residential treatment programs by DCYF but were not receiving special-education services. The Family Court had placed two children in the temporary custody of DCYF and designated Newport and Cumberland as the residences of the children's custodial parents for the purpose of determining the municipalities' financial responsibility for the children's education.The Commissioner of Elementary and Secondary Education agreed with DCYF's argument that the municipalities were required to pay the per-pupil special-education rate according to the unambiguous language of the relevant statutes. The Commissioner issued two decisions ordering Newport and Cumberland to reimburse DCYF for the cost of educational services provided to the children at the special-education rate. After the Council on Elementary and Secondary Education denied the municipalities' independent appeals of the Commissioner's decisions, the municipalities appealed to the Superior Court. The trial justice consolidated the two cases and issued a written decision, determining that the clear and unambiguous language of the statute required the designated city or town to pay its share of the cost of educational services to DCYF rather than the higher, per-pupil special-education rate.The Supreme Court of Rhode Island reviewed the case and found that there is nothing in the relevant statutes that expressly obligates a municipality to pay the per-pupil special-education rate when the child in question is not actually receiving special-education services. The court concluded that municipalities are not required to reimburse DCYF at the per-pupil special-education rate when there were no special education services rendered and thus, no special education costs incurred. The court directed the parties to file supplemental briefs to resolve the remaining question of what reimbursement, if any, DCYF should receive for the educational cost of non-special-education students placed in residential treatment programs that include the delivery of educational services. View "Newport School Committee v. Rhode Island Department of Education" on Justia Law