Justia Civil Procedure Opinion Summaries

Middle school and high school cheerleaders, through their parents, sued Kountze Independent School District after the District prohibited them from displaying banners at school-sponsored events containing religious messages or signs. The District filed a plea to the jurisdiction, asserting mootness in light of its subsequent adoption of a resolution providing that the District was not required to prohibit religious messages on school banners. The trial court denied the District’s plea. The court of appeals reversed, concluding that Plaintiffs’ claims for declaratory and injunctive relief were moot because the District voluntarily discontinued its prohibition on the display of banners containing religious messages or signs. The Supreme Court reversed, holding that because the resolution only states that the District is not required to prohibit the cheerleaders from displaying religious messages on school banners and reserves to the District discretion in regulating those banners, this case was not moot, as the challenged conduct might reasonably be expected to recur. Remanded. View "Matthews v. Kountze Indep. Sch. Dist." on Justia Law

The DOJ filed a motion for further relief in this 40-year-old case in order to gain oversight and some level of control over Louisiana’s school voucher program. The district court granted the DOJ’s motion for further relief and thus mandated annual reporting requirements for Louisiana’s school voucher program. Appellants moved to vacate the district court's order under Federal Rules of Civil Procedure 59(e), 60(b)(4), and 60(b)(5). The district court denied the motion. The court held that the order concerning the voucher program is beyond the scope of the district court’s continuing jurisdiction in this case and is therefore void for lack of subject matter jurisdiction. The district court should have granted the Rule 60(b)(4) motion. The order is reversed and the injunction is therefore dissolved. View "Brumfield v. Louisiana State Bd. of Edu." on Justia Law

Hattiesburg High School (“HHS”) filed a complaint for injunctive relief against the Mississippi High School Activities Association (“MHSAA”), alleging that its decision to declare one of HHS’s students ineligible to participate in athletics was arbitrary and capricious. The Forrest County Chancery Court agreed, and it vacated the penalties that MHSAA had imposed against HHS. MHSAA appealed. Because the Supreme Court found that HHS failed to state a legally cognizable claim or cause of action, we vacate the decisions of the Forrest County Chancery Court. View "Mississippi High School Activities Association, Inc., v. Hattiesburg High School" on Justia Law

In the underlying “school finance” case, Shawnee Mission School District No. 512 (U.S.D. 512) filed a motion to intervene. Plaintiffs opposed U.S.D. 512’s entry into that litigation, and the State did not object. The district court panel denied the motion to intervene, concluding that the State adequately represented U.S.D. 512’s interests and that the motion to intervene was untimely. The Supreme Court affirmed, holding that the panel did not abuse its discretion in denying U.S.D. 512’s motion to intervene as a matter of right, as (1) U.S.D. 512’s interests were not adequately represented by the parties in this case; but (2) U.S.D. 512’s motion to intervene was untimely. View "Gannon v. State" on Justia Law

Christine B., the mother of student "A.F.," filed suit claiming that the Espanola Public Schools failed to address appropriately her daughter's disabilities in the educational program it formulated for her. Before any hearing could be held, Christine sought to mediate her dispute. In the end, the parties signed a settlement agreement. As a result of the settlement, Christine B. asked the administrative agency to dismiss her Individuals with Disability Education Act (IDEA) claims with prejudice. Despite the satisfactory result she received through mediation, Christine B. filed suit again, though not pursuant to IDEA, but under the Americans with Disabilities Act, the Rehabilitation Act, and 42 U.S.C. 1983. The allegations in her federal court complaint and those in her original IDEA administrative complaint were nearly identical: both alleged that A.F. suffered from the same disabilities and both contended that the school district failed to take her disabilities into account in her educational program. Agreeing with the school district that Christine B. failed to exhaust available administrative remedies, the district court dismissed her lawsuit. Christine B. appealed. Finding no reversible error, the Tenth Circuit affirmed the dismissal. View "A.F. v. Espanola Public Schools" on Justia Law

Plaintiff, once a standout high school basketball player, sued 942 U.S.C. 1983) Valley View Community School District, and the Illinois High School Association, raising claims of First Amendment retaliation, equal protection, substantive due process, unconstitutional policy, section 1983 conspiracy to violate constitutional rights, and indemnification under the Illinois Tort Immunity Act. He alleged that the District and IHSA singled him out for residency investigations, which rendered him ineligible to participate in basketball for 10 days, because his mother complained to the District. The district judge determined that plaintiff failed to comply with local Rule 56.1 and deemed admitted all of the defendants’ properly supported facts and disregarded plaintiff’s additional facts that lacked evidentiary support. Rule 56.1(a)(3) requires a party moving for summary judgment to include with that motion “a statement of material facts as to which the moving party contends there is no genuine issue and that entitle the moving party to a judgment as a matter of law,” organized by numbered paragraphs and referring to supporting materials that substantiate the asserted facts. The district judge entered summary judgment for the defendants. The Seventh Circuit affirmed. The defendants complied; plaintiff, in opposing summary judgment, was required to, but did not comply. View "Friend v. Valley View Cmty Unit Sch. Dist." on Justia Law

At issue before the Supreme Court in this case was a Superior Court's grant of summary judgment to defendants, Fairwinds Church and Fairwinds Christian School (collectively, “Fairwinds”), in an action brought by former student Kimberly Hecksher under the Child Victim‟s Act. Hecksher sued Fairwinds under the Act, arguing that Fairwinds, a small, religious school, was grossly negligent for failing to prevent sexual abuse by Ed Sterling (her foster father and her teacher at Fairwinds), that occurred while she was a student. Hecksher alleged that Sterling's wife and fellow-Fairwinds employee, Sandy Sterling, observed Sterling abusing Hecksher on school property, and that Sandy's knowledge of and tortious failure to report the abuse should have been imputed to Fairwinds. Hecksher also argued that Fairwinds was grossly negligent for failing to have a sexual abuse prevention policy in place and for not responding to red flags that Sterling posed a serious risk to Fairwinds students. The Supreme Court disagreed with the Superior Court's grant of summary judgment, finding several instances where reasonable jurors could have found differently than did the Superior Court. The Supreme Court therefore concluded material issues of fact remained, specifically as to whether Sandy's knowledge and conduct could be imputed to Fairwinds, and whether Fairwinds was grossly negligent for failing to have any sexual abuse prevention and detection policies in place and for failing to act on red flags that Sterling posed a serious risk to female students. Accordingly, the grant of summary judgment was reversed and the case remanded for trial. View "Hecksher v. Fairwinds Baptist Church, Inc., et al." on Justia Law

The Belcourt School District operates within the Turtle Mountain Indian Reservation. The North Dakota Constitution requires that the District provide education to children who are Indians or reside on Indian reservations. The Tribe and School District have agreed to share responsibility for educating students, both Indian and non-Indian, residing on the Reservation, and entered into agreements in 2006 and 2009 that provided the District with exclusive authority to administer "day-to-day operations" at Turtle Mountain Community High School, including supervision and employment of staff. Tribe members sued, alleging defamation, excessive use of force, and multiple employment-related claims. The Tribal Court dismissed for lack of jurisdiction over the District and its employees for claims related to the employees' performance of their official duties. The Tribal Court of Appeals reversed, reasoning that the District signed the agreements, subjecting itself to Tribal jurisdiction. The federal trial court concluded that the Tribal Court had jurisdiction, based on the agreements. The Eighth Circuit reversed and held that the Tribal Court did not have jurisdiction, reasoning that the District was clearly acting in its official capacity, in furtherance of its obligations under the state constitution, when it entered into the agreements, View "Belcourt Pub. Sch. Dist. v. Davis" on Justia Law

Fort Yates School District operates within the Standing Rock Indian Reservation. The North Dakota Constitution requires that the District provide education to children who are Indians or reside on reservations. In 2003, the District and the Tribe entered into an Agreement, providing that both the Standing Rock and the Fort Yates School Boards would govern the school system; that all property or equipment purchased under the Agreement would generally be joint property; and that it "neither diminishes nor expands rights or protections afforded … under tribal, state or federal law." After a fight between two students, A. was suspended and C. obtained a restraining order against A. A. allegedly violated the restraining order by verbally harassing C. at school. The school suspended A. for 10 additional days. Murphy sued on behalf of her daughter, C., a Tribe member, in the Tribal Court, which held that it had jurisdiction. The District did not appeal to the Standing Rock Supreme Court, but filed suit in federal court against Murphy and the Tribal Court. The district court dismissed and remanded to the Tribal Court. The Eighth Circuit reversed with respect to Tribal Court jurisdiction, but affirmed dismissal of the Tribal Court on sovereign immunity grounds. View "Fort Yates Pub. Sch. Dist. v. Murphy" on Justia Law

Leetaru, a graduate student at and former employee of the University of Illinois, sought to enjoin the University from taking further action in an investigation of him, as a student, regarding allegations that he violated the University’s “Policy and Procedures on Academic Integrity in Research and Publication.” Leetaru alleged that the defendants failed to comply with the University’s rules and regulations governing student discipline and that their actions exceeded their lawful authority, were arbitrary, resulted in a gross injustice, and deprived him of due process. The circuit court dismissed, finding that exclusive jurisdiction lay in the Court of Claims. The appellate court affirmed. The Illinois Supreme Court reversed, citing the right to seek injunctive relief in circuit court to prevent unauthorized or unconstitutional conduct by the state, its agencies, boards, departments, commissions and agents, or to compel their compliance with legal or constitutional requirements, which includes actions to require compliance with administrative rules and regulations. Leetaru’s claims may proceed in circuit court without offending principles of sovereign immunity. Leetaru does not question the right of defendants to investigate research misconduct, but only claims that in investigating misconduct, defendants are obligated to adhere to policies and procedures promulgated by the University and that they have failed to do so. View "Leetaru v. Bd of Trs. of the Univ. of Ill." on Justia Law