Justia Civil Procedure Opinion Summaries

Micayla Augustyn, a student at Wall High School, received special education services under an individualized education plan (IEP). As she neared the end of her fourth year, a dispute arose between her mother and the Wall Township Board of Education regarding her graduation. The Board wanted her to graduate, while her mother believed she needed another year due to the Board's failure to implement required accommodations. Mediation failed, and Augustyn filed a Petition for Due Process before an Administrative Law Judge (ALJ), claiming the Board failed to provide a free and appropriate education (FAPE) as required by the Individuals with Disabilities Education Act (IDEA).The ALJ dismissed her grade revision claim, stating it was not suitable for a special education due process hearing. Augustyn appealed to the United States District Court for the District of New Jersey, which ruled in her favor, stating that a due process hearing was the appropriate venue for her grade revision claim. The District Court remanded the matter for further proceedings and awarded Augustyn attorneys' fees as a prevailing party under the IDEA, but significantly reduced the fee amount.The United States Court of Appeals for the Third Circuit reviewed the case. The court affirmed that Augustyn was a prevailing party entitled to attorneys' fees, as she successfully vindicated her statutory right to a due process hearing. However, the court found that the District Court erred in reducing the fee award based on improper considerations, such as the Board's financial ability to pay and the procedural nature of Augustyn's victory. The Third Circuit vacated the District Court's order and remanded for a recalculation of the appropriate lodestar reductions. View "Augustyn v. Wall Township Board of Education" on Justia Law

Minor Doe, Father Doe, and Mother Doe filed a lawsuit against the Western Dubuque Community School District and several school officials after Minor Doe was assaulted by another student during class. The plaintiffs claimed negligence, breach of fiduciary duty, and loss of consortium. The school did not contact medical personnel or the parents after the incident, and Minor Doe was later diagnosed with a concussion.The Iowa District Court for Dubuque County dismissed the case on four grounds: failure to meet the heightened pleading requirements of the Iowa Municipal Tort Claims Act (IMTCA), improper use of pseudonyms, failure of the breach of fiduciary duty claim as a matter of law, and the consortium claim failing without the underlying causes of action. The plaintiffs appealed the dismissal.The Iowa Supreme Court reviewed the case and concluded that the district court erred in dismissing the case based on the IMTCA’s qualified immunity provision and the use of pseudonyms. The court held that the IMTCA’s qualified immunity provision does not apply to common law claims and that pseudonymous petitions are generally disfavored but may be allowed in certain circumstances. The court found that the plaintiffs should have been given an opportunity to amend their petition to use their real names. However, the court affirmed the dismissal of the breach of fiduciary duty claim, stating that schools and their officials do not generally have fiduciary relationships with students.The Iowa Supreme Court reversed the district court’s dismissal of the negligence and consortium claims and remanded the case for further proceedings, while affirming the dismissal of the breach of fiduciary duty claim. View "Doe v. Western Dubuque Community School District" 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

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

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 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

Angalia B., the legal guardian and Educational Decision Maker (EDM) for J.B., a student at a Clark County School District (CCSD) elementary school, requested J.B.'s education records under FERPA and NRS 392.029(1). After receiving the records, Angalia suspected that certain emails were missing and requested all communications, including emails stored in CCSD's Google Vault. When CCSD did not respond, Angalia filed a motion to join CCSD to J.B.'s ongoing dependency case and to compel the production of the emails. CCSD opposed, arguing that the emails were not education records under FERPA and NRS 392.029(1) as they were not in J.B.'s permanent file. The district court ruled that the emails were education records and ordered CCSD to produce them.The Supreme Court of Nevada reviewed the case. The court determined that the emails stored in CCSD's Google Vault were maintained by CCSD, satisfying the second prong of the FERPA definition of education records. However, the court found that the district court erred in determining that the emails were directly related to J.B. without first reviewing their content. The Supreme Court of Nevada granted the petition for a writ of mandamus, directing the district court to vacate its order compelling CCSD to produce the emails.The Supreme Court of Nevada held that the district court must perform an in camera review of the emails to determine if they are directly related to J.B. If the emails are found to be directly related, they will qualify as education records under FERPA. The court emphasized that records are maintained when stored in a secure database, such as Google Vault, and that the definition of "maintained" should be interpreted broadly to accommodate future technological advancements. View "Clark County School District v. District Court" on Justia Law

In September 2016, a high school student, almost 16 years old, was involved in a fistfight during an art class. The teacher, who weighed 375 pounds and had a back condition, intervened to stop the fight. While pulling one of the boys away, the teacher lost his balance and fell onto the plaintiff, breaking the plaintiff’s leg. The plaintiff sued the teacher and the school district for negligence, arguing that the teacher should not have intervened due to his physical condition and that the school district failed to train its teachers on safely handling physical altercations.The Superior Court of Los Angeles County held a 15-day trial, during which the jury viewed a video of the incident multiple times. The jury concluded that neither the teacher nor the school district was negligent and found that the plaintiff and the other boy were each 50 percent responsible for the harm. The plaintiff’s motion for judgment notwithstanding the verdict (JNOV) and a new trial was denied.The California Court of Appeal, Second Appellate District, reviewed the case. The court found substantial evidence supporting the jury’s verdict that neither the teacher nor the school district was negligent. The court also upheld the trial court’s exclusion of the plaintiff’s expert witness on the grounds that the expert was not qualified to opine on classroom management and discipline. Additionally, the court found no error in the trial court’s refusal to give the plaintiff’s requested special jury instructions, as the standard instructions on negligence were deemed sufficient. The judgment and the order denying the plaintiff’s motion for JNOV and a new trial were affirmed. View "I.C. v. Compton Unified School Dist." on Justia Law

Edward M.R., a special-education student in Washington, D.C.'s public schools, filed an administrative due process complaint on June 19, 2020, alleging that his individualized education plans (IEPs) from 2015 through 2019 were insufficient to meet his needs under the Individuals with Disabilities Education Act (IDEA). He claimed deficiencies in speech/language therapy, occupational therapy, and other areas. The hearing officer dismissed his claims, finding that challenges to his 2015, 2016, and 2017 IEPs were untimely and that his 2018 and 2019 IEPs were appropriate.Edward then sued in the United States District Court for the District of Columbia, challenging the hearing officer's determinations regarding the 2017, 2018, and 2019 IEPs. The district court affirmed the hearing officer's decisions, leading Edward to appeal.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court held that Edward's challenge to his 2017 IEP was untimely, as it was filed more than two years after he knew or should have known about the alleged deficiencies. Regarding the 2018 and 2019 IEPs, the court found that Edward failed to prove by a preponderance of the evidence that the hearing officer was wrong in concluding that the IEPs were appropriate. The court noted that repeating goals in the IEPs was reasonable given Edward's severe memory issues and that the IEPs included new, appropriately ambitious goals.The court also rejected Edward's claims that his IEPs lacked research-based instruction, finding that he received such instruction even if it was not explicitly stated in the IEPs. Finally, the court did not consider Edward's claim regarding the implementation of Applied Behavior Analysis, as it was not exhausted through the administrative process. The court affirmed the district court's decision. View "M.R. v. District of Columbia" on Justia Law

Three former students of East Gaston High School, who were members of the wrestling team, filed a lawsuit against their coach, Gary Scott Goins, and the Gaston County Board of Education. They alleged that Goins subjected them to sexual abuse, physical violence, and psychological harm during the mid-1990s and early 2000s. Goins was criminally convicted in 2014 and sentenced to over thirty-four years in prison. The plaintiffs sought civil damages from the Board of Education, claiming it knew or should have known about the abuse. The claims were initially time-barred under the three-year statute of limitations, which began running on the victims' eighteenth birthdays.The Superior Court of Wake County, in a divided decision, declared the revival provision of the SAFE Child Act, which allowed previously time-barred claims to be filed during a two-year window, unconstitutional. The court held that the expiration of the statute of limitations created a vested right for the defendants, which the legislature could not retroactively alter.The North Carolina Court of Appeals reversed the lower court's decision, holding that the revival of the statute of limitations did not interfere with vested rights. The court reasoned that statutes of limitations are procedural and do not create property rights. Therefore, the legislature could retroactively alter them without violating the constitution.The Supreme Court of North Carolina affirmed the Court of Appeals' decision, holding that the running of a statute of limitations in a tort claim does not create a constitutionally protected vested right. The court emphasized that statutes of limitations are procedural and affect only the remedy, not the underlying right. The court concluded that the General Assembly has the authority to retroactively alter statutes of limitations for tort claims. View "McKinney v. Goins" on Justia Law