Justia Civil Procedure Opinion Summaries

The case involves Susan George, a teacher who had worked for the Susanville Elementary School District for several years before resigning to teach at another school district. She later returned to the District. Upon her return, the District did not credit her for the years of experience she gained at the other school district following her resignation. George filed a petition for writ of mandate arguing the District violated the uniformity requirement of Education Code section 45028 and the restoration requirement of section 44931 when placing her on the salary schedule without accounting for the years of experience she gained while outside the District after her resignation.The trial court found that the District complied with the Education Code. It ruled that the collective bargaining agreement prevented George from acquiring credit for the two years she worked for another school district. The trial court further found the uniformity requirement did not afford George relief and the District complied with the restoration requirement by restoring George to her prior position. Consequently, the trial court denied George’s petition for writ of mandate.The Court of Appeal of the State of California Third Appellate District reversed the trial court's decision. The appellate court held that the District violated the uniformity requirement by failing to place George at step 15 of the District’s salary schedule. The court disagreed with the District's argument that the uniformity requirement is inapplicable to George’s placement on the salary schedule because the restoration requirement controls the placement of teachers rehired within 39 months. The court found that the District must credit George with up to 12 years of out-of-district experience. The court remanded the case with directions to issue a writ compelling the District to place George on its salary schedule in compliance with Education Code section 45028 as construed herein, with appropriate back pay and benefits. The District was ordered to pay costs on appeal. View "George v. Susanville Elementary School District" on Justia Law

The case involves Shannon Blick, a former principal of an elementary school in the Ann Arbor Public School District. In 2019, Blick was placed on paid leave while the school district investigated her role in a custodian's over-billing scheme. The leave lasted two years, and the school district eventually terminated Blick's contract. Blick filed a lawsuit while still on leave, alleging that various officials violated her freedoms of speech and association under the First Amendment. She also brought race-discrimination, due-process, and conspiracy claims against these officials. The district court rejected Blick's First Amendment claims at the summary-judgment stage and dismissed the other claims on the pleadings.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court's decision. The court found that Blick failed to show a reversible error. She argued that the school district violated the First Amendment by imposing a prior restraint that barred her from speaking during her leave and by taking harmful actions against her in retaliation for her speech. However, the court found that Blick's lawyers did not provide sufficient information about what she wanted to say or what she did say. The court also found that Blick's opening brief did not preserve her challenges to much of the district court's motion-to-dismiss decision. As a result, the court affirmed the district court's decision. View "Blick v. Ann Arbor Public School District" on Justia Law

The case involves a group of plaintiffs who filed a civil rights action under 42 U.S.C. § 1983 against Independent School District 194 and its superintendent. The plaintiffs alleged that the defendants violated their First Amendment rights by discriminating against their political viewpoints. The controversy arose when the school district allowed the display of Black Lives Matter (BLM) posters in classrooms but rejected requests to display "All Lives Matter" and "Blue Lives Matter" posters and shirts. The district court dismissed the plaintiffs' First Amendment claims and denied the unnamed plaintiffs' motion to proceed under pseudonyms.The district court ruled that the unnamed plaintiffs had not sufficiently established a threat of a hostile public reaction to their lawsuit that would warrant anonymity. It also concluded that the BLM posters constituted government speech that is not subject to scrutiny under the First Amendment’s Free Speech Clause. The plaintiffs appealed both orders.The United States Court of Appeals for the Eighth Circuit affirmed in part, reversed in part, and remanded the case for further proceedings. The court affirmed the district court's denial of the motion to proceed under pseudonyms, finding that the unnamed plaintiffs did not provide sufficient evidence of a compelling fear of retaliation. However, the court reversed the district court's dismissal of the complaint, concluding that the plaintiffs had pleaded sufficient facts to allow a court to draw the plausible inference that the BLM posters are expressions of private persons, not government speech. The court also found that the district had engaged in viewpoint discrimination by allowing the display of BLM posters but rejecting "All Lives Matter" and "Blue Lives Matter" posters and shirts. View "Cajune v. Independent School District 194" on Justia Law

The case involves Benjamin Stanley, who was employed by Western Michigan University (WMU) for about a month before his employment was terminated. Stanley, who has severe ADHD, claimed that WMU and certain supervisors discriminated and retaliated against him in violation of the Americans with Disabilities Act (ADA). He also brought a claim under Michigan’s Persons with Disabilities Civil Rights Act (PWDCRA), as well as a claim for intentional infliction of emotional distress. The district court dismissed Stanley’s federal claims for lack of subject-matter jurisdiction based on Eleventh Amendment immunity and dismissed his state-law claims for failure to comply with the Michigan Court of Claims Act’s notification statute.The district court's dismissal of Stanley's claims was appealed to the United States Court of Appeals for the Sixth Circuit. The appellate court affirmed the district court’s dismissal of Stanley’s federal claims and the denial of Stanley’s motion for leave to amend his complaint. However, the court vacated the judgment in part and remanded to the district court to dismiss Stanley’s federal and state-law claims without prejudice. The court found that the district court lacked subject-matter jurisdiction to adjudicate Stanley’s ADA claims because the defendants were entitled to Eleventh Amendment immunity, and Stanley lacked standing to request injunctive relief from the individual defendants. The court also found that the district court lacked jurisdiction to decide Stanley’s state-law claims because it lacked subject matter jurisdiction over any federal issues. View "Stanley v. Western Michigan University" on Justia Law

Felissa Jones, the mother of an elementary school student, reported to the Mississippi Department of Child Protection Services (MDCPS) that her son had suffered abuse and neglect by staff at his school. MDCPS responded that it does not investigate reports of abuse at school. Jones then sued MDCPS, seeking declaratory and injunctive relief related to MDCPS’s policy that the agency does not investigate allegations of abuse in out-of-home settings such as schools.The Hinds County Chancery Court denied Jones's motion for a judgment in her favor on the pleadings and granted MDCPS's motion for a judgment on the pleadings, dismissing Jones's complaint. The court ruled that Jones's request for declaratory relief related to MDCPS’s former intake policy was moot because the policy was no longer in effect. It also ruled that the current intake policy does not violate the relevant statutes, but instead conforms to the statutory mandate to refer allegations of child abuse in out-of-home settings to local law enforcement.In the Supreme Court of Mississippi, Jones appealed the lower court's decisions. The court affirmed the lower court's rulings, stating that MDCPS does not have a duty to investigate reports of abuse in out-of-home settings, such as schools, because children who are mistreated by school staff do not fall under the youth court’s limited jurisdiction. The court also found that Jones's claim for declaratory relief from the amended policy had no merit because the policy tracks the relevant statutes. View "Jones v. Department of Child Protection Services" on Justia Law

The case revolves around Timothy Poole, a law graduate who failed the Kentucky Bar Examination five times. Poole claimed that the Kentucky Office of Bar Admissions (KYOBA) and its Executive Director, Valetta Browne, denied him necessary accommodations, leading to his repeated failures. He sought either retroactive admission to the Kentucky Bar Association or permission to retake the exam with all his accommodations.Previously, Poole had initiated a lawsuit in Fayette Circuit Court, alleging negligence on Browne's part regarding the October 2020 exam, which caused him emotional distress, loss of employment opportunities, and other damages. However, the complaint was dismissed, with the court ruling that individuals serving in a judicial capacity are immune from civil liability for their conduct and communications during their duties.The Supreme Court of Kentucky, after reviewing Poole's petition, his interactions with the KYOBA, and the accommodations offered, found that Poole was given appropriate accommodation and ample opportunities to pass the bar exam. The court noted that Poole voluntarily chose to sit for the exam twice without any accommodations, despite having inquired about them and allegedly possessing the required materials for his application. The court also pointed out that Poole never voiced any objection to the additional testing time allowance afforded to him and did not appeal that determination.The court also clarified that the rule limiting attempts to pass the bar exam to five, including attempts on the Uniform Bar Examination (UBE) taken in Kentucky or any other jurisdiction from February 2021 onwards, applies to all attempts, not just those after February 2021.The court concluded that Poole's application process and the exams were conducted in a fair and equitable manner, and any failure to approve and implement additional accommodations was due to Poole's failure to apply for them or seek appellate review of the accommodation granted. The court affirmed the KYOBA's determination that Poole had exhausted his attempts to pass the Kentucky Bar Exam and denied his requests for relief. View "Poole v. Browne" on Justia Law

In this case, Laurie Barton, a third-year law student at the University of Idaho, was accused of violating the university's honor code by committing academic misconduct during a final examination. Despite denying the allegations, she was sanctioned with degree denial after a series of Honor Court proceedings. Barton exhausted her administrative review options, including an appeal to the Idaho State Board of Education, and then petitioned for judicial review. The district court denied her petition. Instead of appealing this decision, Barton sued the Board of Regents of the University of Idaho and Idaho State Board of Education, alleging nine causes of action, all of which the district court dismissed at summary judgment.The district court's judgment was affirmed by the Supreme Court of the State of Idaho. The Supreme Court found that Barton had failed to raise a genuine issue of material fact that the University violated its duty of good faith and fair dealing or that it made a specific promise that induced her action. The court also found that Barton's motion for a protective order was implicitly denied and moot, as the case was resolved on summary judgment. The court concluded that Barton's appeal was pursued frivolously, unreasonably, and without foundation, and awarded attorney fees and costs to the University. View "Barton v. Board of Regents" on Justia Law

The case involves Little Scholars of Arkansas, AP Consolidated Theatres II L.P., CSRC Charter LISA, LLC, and KLS Leasing LLC (collectively, appellants) who appealed against Pulaski County, Arkansas, and its officials (collectively, appellees). The appellants operate charter schools and lease properties for their schools. The appellees assessed real-property taxes against the schools, which the appellants contested, arguing that the properties used for school purposes are exempt from taxes under the Arkansas Constitution. The appellants also sought a declaration that Ark. Code Ann. § 6-21-118, which they claimed the appellees relied on for the tax assessment, is void under the constitution.The case was initially brought before the Pulaski County Circuit Court. The appellees moved to dismiss the case, arguing that the county courts have exclusive jurisdiction over county tax matters. The circuit court agreed with the appellees, dismissing the case on the grounds that it lacked subject-matter jurisdiction over the appellants' claims.The case was then brought before the Supreme Court of Arkansas. The appellants argued that the circuit court did have subject-matter jurisdiction over their illegal-exaction claims. They also argued that their request for a declaration that Ark. Code Ann. § 6-21-118 is void does not fall within the county court’s jurisdiction. The Supreme Court disagreed with the appellants, affirming the circuit court's decision. The Supreme Court held that the appellants' claim was not an illegal-exaction claim but an assessment dispute, which falls within the exclusive original jurisdiction of the county court. The Supreme Court also held that the circuit court did not have subject-matter jurisdiction over the appellants' request for declaratory judgment. View "LITTLE SCHOLARS OF ARKANSAS FOUNDATION v. PULASKI COUNTY, ARKANSAS" on Justia Law

The case involves a non-verbal student, Alexandre Le Pape, and his family who repeatedly requested that the Lower Merion School District change his educational program to include a new communication protocol known as "Spelling to Communicate" (S2C). The school district denied these requests, leading to Alexandre's withdrawal from public education. The family filed an administrative special education due process complaint against the school district, alleging that the district failed to protect Alexandre's rights and denied him a Free Accessible Public Education (FAPE) under various laws. An administrative hearing officer ruled against the family on all claims, leading them to file a suit in the United States District Court for the Eastern District of Pennsylvania.The District Court granted the school district's motions for summary judgment on the Americans with Disabilities Act (ADA) claim and judgment on the administrative record for the denial-of-FAPE claims. The Le Papes appealed the court's decision, arguing that the court granted judgment without applying the summary judgment standard to which they were entitled under Federal Rule of Civil Procedure 56.The United States Court of Appeals for the Third Circuit reversed and remanded the case. The court held that the District Court erred in granting summary judgment for the school district on the Le Papes' ADA discrimination claim and judgment on the administrative record for their discrimination claims under both the ADA and Section 504. The court clarified that a denial-of-FAPE claim under the Individuals with Disabilities Education Act (IDEA) can be resolved through an administrative appeal, but ADA and Section 504 discrimination claims seeking compensatory damages, even if on the same facts, should be resolved through summary judgment and, possibly, trial. View "Le Pape v. Lower Merion School District" on Justia Law

The case involves a dispute over the funding of Delaware's public schools. The plaintiffs, non-profit organizations with an interest in Delaware's schools, filed a lawsuit in 2018, alleging that the state's public schools were not providing an adequate education for students from low-income households, students with disabilities, and students whose first language is not English. They argued that one of the problems was a broken system for funding the schools, which relied on property taxes. The plaintiffs contended that the three counties in Delaware were using decades-old property valuations, which violated state law and the state constitution.The case was initially heard in the Court of Chancery of the State of Delaware. During discovery, the plaintiffs served requests for admission to the counties, asking them to admit that their decades-old assessments resulted in a lack of uniformity in property taxes and violated state law. The counties denied these requests. At trial, the court found in favor of the plaintiffs, ruling that the counties' assessments violated state law and the state constitution. The court also found that the plaintiffs had proved the facts that were the subject of the requests for admission that the counties had denied.The plaintiffs then requested an award of expenses under Court of Chancery Rule 37(c), which allows the court to order a party to pay the expenses that another party incurred in proving a fact that should have been admitted. The court granted the plaintiffs' request, awarding them expenses of $337,224, which included attorneys’ fees and out-of-pocket costs. Each county was ordered to pay a prorated share of $112,408. View "In re Delaware Public Schools Litigation" on Justia Law