Justia Civil Rights Opinion Summaries

The School District includes four high schools. Groves, who is white, started at the District in 1991 as a teacher. In 2007 he became the Adams High School athletic director. In 2017 Groves applied to serve as Corporation Director of Athletics, a new, District-wide position. Superintendent Spells interviewed four applicants and recommended Gavin, who is Black, explaining that Gavin inspired confidence in his ability to repair the District’s relationship with the Indiana High School Athletic Association; Groves interviewed poorly and seemed to boast of firing 24 coaches during his tenure. Noncompliance with Association regulations occurred under Groves’s watch at Adams.Groves sued under Title VII, noting that Spells is also Black. The District later eliminated the Corporation Director of Athletics position and created a hybrid Dean of Students/Athletics position at each of the four high schools. Groves, Gavin, and seven other candidates applied for the four new positions. The Riley High School position went to Gavin. Groves added a claim of retaliation based on the elimination of his position. The Seventh Circuit affirmed the summary rejection of his claims. Groves was not substantially more qualified than Gavin. Both met the criteria that the District required for the position. The court rejected a claim of pretext. Although Gavin’s criminal background came to light after the challenged hiring decisions, the District interpreted its background check policy as applying only to external hires, not existing employees moving to new positions. View "Groves v. South Bend Community School Corp." on Justia Law

Will started attending Farragut High School in 2015. Will’s style and his friendships created “a perception that he was alternatively sexually oriented” and affiliated “with the LGBT movement.” According to his parents, administrators targeted Will for discipline because of his appearance, perceived sexual orientation, and speech. There were several disciplinary actions that contributed to Will’s increasing anxiety and depression. Although a teacher graded an assignment in which Will expressed suicidal thoughts, nobody at the school informed his parents. During his sophomore year, Will died from a self-inflicted gunshot wound.Will's parents brought a state court suit, alleging deprivation of “administrative due process” during Will’s suspension proceedings, violations of the District’s anti-harassment and suicide-prevention policies, and negligent infliction of emotional distress. The District removed the suit to federal court, arguing that the “due process” allegations raised federal claims. The district court remanded the suit in 2018, based on the parents’ assertions that they raised only state law claims. Their attorney let the suit languish for years. A new attorney believed that the state law claims would fail and filed an amended complaint adding claims under 42 U.S.C. 1983 and claims under Title IX, 20 U.S.C. 1681. The District removed the suit to federal court again. The Sixth Circuit affirmed the dismissal of the federal claims as time-barred. The parents forfeited several of their arguments by failing to raise them earlier. View "Bannister v. Knox County Board of Education" on Justia Law

At the Ohio State University, Dr. Strauss allegedly abused hundreds of young men under the guise of performing medical examinations, between 1978-1998. The University placed Strauss on leave in 1996, while it investigated his conduct, and ultimately declined to renew his appointments with Student Health Services and terminated his employment with the Athletics Department. It did not publicly provide reasons for these decisions. The University conducted a hearing but did not notify students or give them an opportunity to participate. Strauss remained a tenured faculty member. He retired in 1998, with emeritus status. He opened a private clinic near the University to treat “common genital/urinary problems,” advertised in the student newspaper, and continued treating students. An independent investigation commissioned by the University in 2018 and undertaken by a law firm substantiated allegations of abuse.Strauss’s victims brought Title IX suits, alleging that the University was deliberately indifferent to their heightened risk of abuse. The district court found that the plaintiffs’ claims were barred by the two-year statute of limitations. The Sixth Circuit reversed. Many plaintiffs adequately alleged that they did not know they were abused until 2018; the time of the abuse, they were young and did not know what was medically appropriate. Strauss gave pretextual, false medical explanations for the abuse. The plaintiffs did not have reason to know that others had previously complained about Strauss’s conduct. View "Moxley v. The Ohio State University" on Justia Law

The Fellowship of Christian Athletes (“FCA”) requires students serving in leadership roles to abide by a Statement of Faith, which includes the belief that sexual relations should be limited within the context of a marriage between a man and a woman. The San Jose Unified School District (the “School District”) revoked FCA’s status as an official student club at its high schools, claiming that FCA’s religious pledge requirement violated the School District’s non-discrimination policy.   The Ninth Circuit reversed the district court’s denial of a motion for a preliminary injunction sought by a derecognized student club, the Fellowship of Christian Athletes, and directed the district court to enter an order reinstating the Fellowship as a student club within the San Jose Unified School District.   The panel first held that FCA National had direct organizational standing and Pioneer High School FCA had representational organizational standing to seek prospective injunctive relief. The School District’s denial of Associated Student Body (“ASB”) recognition hampered FCA National’s ability to further student engagement with the Christian faith and required it to expend significant time and resources to assist its student members.   Addressing the merits, the panel first held that Plaintiffs’ motion for a preliminary injunction sought to maintain the status quo that existed before the School District’s novel scrutiny of FCA—a prohibitory injunction—so the district court erred in applying the heightened standard for mandatory injunctions. The panel held that Plaintiffs would likely prevail on the merits of its selective enforcement claim under the Free Exercise Clause. View "FELLOWSHIP OF CHRISTIAN ATHLET V. SAN JOSE UNIFIED SCHOOL DISTRI" on Justia Law

The Court of Appeals reversed the judgment of the court of special appeals affirming the decision of the circuit court granting summary judgment in favor of Defendants in this case involving violent peer conflicts between adolescents in middle school, holding that the circuit court erred.Plaintiffs filed a five-count complaint against several school defendants and the Board of Education for Dorchester County, alleging violations of their daughter's state constitutional right to due process and other causes of action stemming from their daughter's bullying by other students. The circuit court granted summary judgment for Defendants, and the court of special appeals affirmed. The Court of Appeals reversed, holding (1) the Act does not preempt CJ § 5-518, and Plaintiffs' negligence claims against the individual school employees were not preempted by federal law; (2) the educational malpractice doctrine does not apply to Plaintiffs' negligent supervision claims; and (3) material disputes of fact precluded the entry of summary judgment. View "Gambrill v. Bd. of Education of Dorchester County" on Justia Law

Plaintiff, a person of color and of mixed heritage, reported to school administrators that she was harassed by her peers on the basis of her race and national origin during her sixth-grade year in the Austin Independent School District. Plaintiff alleged that she was told to "go back where [she] came from" and that, in some cases, the harassment involved physical shoving. There were also incidents in which Plaintiff responded physically to verbal threats and name-calling, resulting in the school requesting she be transferred. Through her parents, Plaintiff sued the District for failure to address the harassment under 42 U.S.C. Sec. 1983 and Title VI of the Civil Rights Act of 1964.The trial court dismissed Plaintiff's 1983 claim under Rule 12(b)(6) and ultimately granted summary judgment in favor of the district on Plaintiff's Title VI claim.While the Fifth Circuit took issue with some of the district court's findings, the Fifth Circuit concluded that the district court ultimately reached the correct result. Thus, the court affirmed the dismissal of Plaintiff's 1983 claim and the court's grant of summary judgment on the Title VI claim. View "Menzia v. Austin Indep School Dist" on Justia Law

In a putative class action, Plaintiffs alleged that Defendants violated the Individuals with Disabilities Education Act and the Fourteenth Amendment, and they sought declaratory and injunctive relief. The Ninth Circuit affirmed in part and vacated in part the district court’s dismissal of claims brought by a group of students and parents who alleged that every school district in California failed to adequately accommodate special needs students after California public schools transitioned to remote instruction in March 2020 in response to the COVID-19 pandemic.   The panel held that Plaintiffs lacked standing to sue school districts in which they were not enrolled and the State Special Schools, which they did not attend because they did not allege that those Defendants injured them personally. The panel held that even if the “juridical link” doctrine, provides an exception to the rule that a named plaintiff who has not been harmed by a defendant is generally an inadequate and atypical class representative for purposes of Fed. R. Civ. P. 23, ever applies outside of the Rule 23 context, it would not apply here.   The panel held that the California public schools’ return to in-person instruction mooted Plaintiffs’ claims against the California Department of Education and the State Superintendent of Public Education, as well as their claims against other defendants seeking injunctions requiring a return to in-person instruction or reassessment and services until students return to in-person instruction. The panel vacated the district court’s judgment dismissing on the merits the claims that Plaintiffs lacked standing to bring and remanded with instruction to dismiss those claims for lack of subject-matter jurisdiction. View "DANIELLE MARTINEZ V. GAVIN NEWSOM" on Justia Law

On appeal, the St. Martin Parish School Board (the “School Board”) challenges the district court’s (1) exercise of remedial jurisdiction over the case, (2) denial of its motion for unitary status, and (3) imposition of additional equitable relief. The Fifth Circuit concluded that hat the district court properly retained remedial jurisdiction over the action; the court otherwised affirmed in part and reversed in part.The court explained that the district court did not clearly err in determining that the School Board failed to achieve unitary status in student assignment, faculty assignment, and the quality of education. The denial of unitary status was, therefore, not clearly erroneous. However, the court found that the district court abused its discretion in closing Catahoula Elementary School. The record demonstrates that progress has been made and progress can continue through the implementation of other reasonable, feasible, and workable remedies. Accordingly, the court reversed the closing of Catahoula Elementary School and remanded for consideration of other methods of addressing that concern. View "Borel v. Sch Bd Saint Martin Parish" on Justia Law

The Seventh Circuit affirmed the judgment of the district court denying Plaintiff's request for a preliminary injunction to stop the University of Southern Indiana from imposing a three-semester suspension on the grounds that the university violated Title IX of the Education Amendments of 1972 by discriminating against him on the basis of his sex, holding that Plaintiff was not entitled to a preliminary injunction.The university's Title IX committee in this case found by a preponderance of the evidence that Plaintiff, a student of the university, had sexually assaulted another student and imposed a three-semester suspension. Plaintiff subsequently brought a complaint alleging discrimination. The district court denied Plaintiff's motion for a preliminary injunction. The Seventh Circuit affirmed, holding that the district court did not abuse its discretion in denying relief because Plaintiff did not show a likelihood of success on the merits that would support a preliminary injunction. View "Doe v. University of Southern Indiana" on Justia Law

S.S. was a student in the Cobb County School District. S.S.’s parents challenged the adequacy of the individualized educational plans. S.S.’s parents fought the school district for two years and eventually filed an administrative complaint requesting a due process hearing under the Act with the Georgia Office of State Administrative Hearings. In the administrative complaint, S.S. alleged that the school district failed to provide her with a free and appropriate public education under the Act. The school district moved for summary determination of the administrative complaint. S.S. challenged the administrative law judge’s decision in the Northern District of Georgia.The district court denied the school district’s motion for summary judgment and remanded to the administrative law judge for a due process hearing. The school district appealed the district court’s remand order.   The DC Circuit concluded that remand orders from district courts to administrative agencies for further proceedings under the Act are not final and appealable under section 1291. And because the district court’s remand order was not final and appealable, the court wrote it lacks appellate jurisdiction to review it. Accordingly, the court dismissed the school district’s appeal. View "S.S. v. Cobb County School District" on Justia Law