Justia Government & Administrative Law Opinion Summaries

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

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

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

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

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

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

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

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

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

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