Justia Civil Rights Opinion Summaries

K.N., an eight-year-old boy with multiple disabilities, lives in a non-wheelchair-accessible apartment in the District of Columbia. His mother, Margda Pierre-Noel, requested that the District and his school, Bridges Public Charter School, provide assistance to move K.N. from their apartment door to the school bus. The District denied the request, citing its policy that staff only retrieve students from the outermost door of their dwelling and do not physically lift or carry students.The Office of the State Superintendent of Education (OSSE) hearing officer ruled that it was beyond his authority to order the requested assistance but required OSSE to offer transportation services to and from the outer door of K.N.'s apartment building. Pierre-Noel then filed a lawsuit in the United States District Court for the District of Columbia, which granted summary judgment in favor of the District, ruling that the service requested was not a transportation service under the Individuals with Disabilities Education Act (IDEA).The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court held that the IDEA requires the District to provide door-to-door transportation services for K.N., as such services are necessary for him to benefit from his special education. The court found that the term "transportation" under the IDEA includes moving a child from their apartment door to the vehicle that will take them to school. The court vacated the district court's grant of summary judgment and remanded the case for further proceedings consistent with its opinion. The appeal was dismissed as moot with respect to Bridges Public Charter School, as K.N. was no longer enrolled there. View "Pierre-Noel v. Bridges Public Charter School" on Justia Law

The plaintiff, Jane Doe, challenged the Manchester School District's policy regarding transgender and gender non-conforming students. The policy allowed students to keep their transgender status private and required school personnel to use a student's preferred name and pronouns, without disclosing this information to parents unless legally required or authorized by the student. Jane Doe, the parent of a minor child (M.C.) in the district, discovered that M.C. had asked to be called by a different name and pronouns. She requested the school to use M.C.'s birth name and pronouns, but the school adhered to the district policy.The Superior Court dismissed Jane Doe's claims, finding that the policy did not infringe upon a fundamental right and thus did not warrant strict scrutiny. The court applied the rational basis test and concluded that the policy was constitutional. The court also found that the policy was not ultra vires and did not violate federal laws such as the Family Educational Rights and Privacy Act (FERPA) or the Protection of Pupil Rights Act (PPRA).The Supreme Court of New Hampshire reviewed the case and affirmed the lower court's decision. The court held that the policy did not directly interfere with the fundamental right to parent, as it did not prevent parents from obtaining information from other sources or restrict their ability to parent their child. The court agreed that the policy did not infringe on a fundamental right and thus was subject to rational basis review, which it survived. The court did not find it necessary to address the plaintiff's facial and as-applied challenges separately, as the policy was found to be constitutional under the rational basis test. View "Doe v. Manchester School District" on Justia Law

Four female hockey players filed a lawsuit against the University of North Dakota, alleging that the university violated Title IX by eliminating the women’s ice hockey program after the 2016-17 season. None of the plaintiffs were enrolled at the university at the time of the program's termination. They sought to represent a class of current, prospective, and future female students and requested a declaratory judgment and an injunction to reinstate the women’s hockey program.The United States District Court for the District of North Dakota dismissed the case for lack of jurisdiction, finding that the plaintiffs did not demonstrate a "concrete" injury as required for standing under Article III.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court found that two plaintiffs, Calli Forsberg and Maya Tellmann, had standing. Forsberg was recruited to play for the university’s hockey team but chose another school after the program was cut. Tellmann, a two-time state hockey champion, was accepted as a student but had no opportunity to play due to the program's elimination. Both plaintiffs demonstrated a concrete injury by being denied the opportunity to compete for the team of their choice, and they expressed a definite intent to attend the university if the program were reinstated.The court found that the other two plaintiffs, Emily Becker and Morgan Stenseth, did not allege sufficient facts to establish standing. Becker did not provide details about her qualifications or acceptance to the university, and Stenseth did not express an intent to attend the university in the future.The Eighth Circuit reversed and remanded the case in part, allowing Forsberg and Tellmann’s claims to proceed, but affirmed the dismissal of Becker and Stenseth’s claims. View "Becker v. North Dakota University System" on Justia Law

Joel Cielak and Barron Hodges were sexually abused by David Johnson, a teacher at Nicolet High School (NHS), in the late 1970s and early 1980s. Hodges reported the abuse in 1983, leading the school board to confront Johnson but keep him employed under supervision. Johnson ceased abusing Hodges but continued to abuse Cielak, who had graduated in 1982. Both plaintiffs sued NHS, the school district, and board members under 42 U.S.C. §§ 1983 and 1985, alleging violations of their Fourteenth Amendment rights and a conspiracy to violate their equal protection rights. The district court dismissed the claims with prejudice and denied leave to amend the complaint.The United States District Court for the Eastern District of Wisconsin granted the defendants' motion to dismiss, concluding that the plaintiffs failed to state claims based on Johnson's abuse predating Hodges's 1983 allegation. The court also found that Hodges's claims were time-barred and that Cielak's allegations of post-allegation harms did not amount to violations of his substantive due process or equal protection rights. The court denied the plaintiffs leave to amend their complaint, deeming it futile.The United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The appellate court held that Hodges's claims were time-barred as he knew of his injuries and their cause in the fall of 1983. In contrast, the court found that it was unclear when Cielak knew or had reason to know that his post-allegation injuries were connected to actions by the defendants, making it improper to dismiss his claims on statute of limitations grounds at this stage. However, the court concluded that Cielak failed to plausibly plead a violation of his substantive due process or equal protection rights because Johnson's post-allegation abuse was not under color of state law. The court also upheld the denial of leave to amend, noting that the plaintiffs failed to explain how they would cure the complaint's defects. View "Cielak v. Nicolet Union High School District" on Justia Law

Jane Doe, a student in a dual enrollment program with the University of Kentucky, reported being raped by John Doe (JD) in her dorm room. The University held four student conduct hearings. The first three hearings resulted in JD's expulsion or suspension, but each decision was overturned by the University’s appeals board due to procedural errors. After the third reversal, Doe filed a Title IX lawsuit against the University. In the fourth hearing, the panel ruled against her, and Doe claimed the University mishandled this hearing in retaliation for her lawsuit.The United States District Court for the Eastern District of Kentucky granted summary judgment in favor of the University, concluding that Doe could not establish a prima facie case of retaliation under Title IX. The court found that Doe was no longer a student at the time of the fourth hearing and thus could not claim adverse school-related actions. It also limited its analysis to the allegations in Doe’s complaint, excluding additional evidence presented in opposition to summary judgment.The United States Court of Appeals for the Sixth Circuit reversed and remanded the case. The court held that Doe could suffer adverse school-related actions even if she was not a current student and that the University’s disciplinary proceedings are educational programs under Title IX. The court found that the University’s delays, procedural errors, and failure to adequately prosecute JD could dissuade a reasonable person from pursuing a Title IX claim. The court also held that Doe presented sufficient evidence to establish a causal connection between her lawsuit and the adverse actions. The case was remanded for further proceedings consistent with this opinion. View "Doe v. University of Kentucky" on Justia Law

A.D., a student with disabilities, attended Sparta High School and was designated as having a disability under the IDEA. In early 2019, Sparta informed A.D. that he was in danger of failing several classes, leading to a period of home instruction. A.D.'s parents withdrew him from school, and he subsequently passed the GED, receiving a State-issued high school diploma in April 2019. Despite re-enrolling at Sparta High School and receiving home instruction again, A.D. faced academic challenges and was withdrawn from school multiple times. In May 2021, Sparta denied A.D.'s re-enrollment request, citing his receipt of the State-issued diploma.M.N., A.D.'s mother, requested a due process hearing with the New Jersey Department of Education (DOE). The Administrative Law Judge (ALJ) ruled that A.D.'s State-issued diploma was a "regular high school diploma" under federal regulations, thus ending his entitlement to a FAPE. The Commissioner of the DOE upheld the ALJ's decision, and the Appellate Division affirmed, agreeing that the State-issued diploma met state standards and ended A.D.'s entitlement to a FAPE.The Supreme Court of New Jersey reviewed the case and held that a New Jersey State-issued diploma based on passing the GED is not a "regular high school diploma" under 34 C.F.R. § 300.102(a)(3)(iv). Therefore, a student who receives such a diploma remains entitled to a free appropriate public education under the IDEA. The Court reversed the Appellate Division's decision, concluding that A.D. remains entitled to receive a FAPE, and Sparta must provide it. View "Board of Education of the Township of Sparta v. M.N." on Justia Law

The case involves several special education students who alleged that their teacher physically and emotionally abused them. The students, who have various disabilities affecting their communication abilities, were assigned to the same classroom at Elm Street Elementary School in Coweta County, Georgia. The teacher, Catherine Sprague, was hired by the principal, Dr. Christi Hildebrand, despite lacking special education certification. Throughout the fall of 2019, the students exhibited signs of distress, and their parents noticed behavioral changes and physical signs of mistreatment. A paraprofessional, Nicole Marshall, reported multiple instances of abuse by Sprague to Hildebrand, who delayed reporting these allegations to law enforcement and the students' parents.The United States District Court for the Northern District of Georgia dismissed the students' complaint. The court ruled that emotional distress damages are not recoverable under Title II of the Americans with Disabilities Act (ADA) following the Supreme Court's decision in Cummings v. Premier Rehab Keller, P.L.L.C. The court also found that the students failed to state a constitutional violation against Hildebrand and the school district, and that Hildebrand was entitled to qualified immunity. The court declined to exercise supplemental jurisdiction over the state law negligence claim.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court affirmed that emotional distress damages are not recoverable under Title II of the ADA, as Title II incorporates the remedies of the Rehabilitation Act, which the Supreme Court in Cummings ruled does not allow for emotional distress damages. However, the appellate court found that the district court erred by not considering whether the students might be entitled to other forms of relief under Title II, such as damages for physical harm or nominal damages. The appellate court also affirmed the dismissal of the section 1983 claims, ruling that the alleged abuse did not meet the "shock-the-conscience" standard required for a substantive due process violation. The case was remanded for further proceedings to consider other potential relief under Title II. View "A.W. v. Coweta County School District" on Justia Law

This case involves a child with significant developmental disabilities, B.D., who attended Georgetown Public Schools. B.D.'s parents, Rachel and Michael Doucette, sued the school district and various personnel, alleging that the school's failure to properly implement B.D.'s individualized education program (IEP) and health and safety plan led to a series of five severe seizures that B.D. experienced at school in 2012. The Doucettes claimed that the school district violated B.D.'s constitutional rights under 42 U.S.C. § 1983 and Massachusetts tort law.The district court granted the school district's motion for summary judgment, finding that a reasonable jury could not conclude that the school district engaged in the conscience-shocking conduct necessary to sustain the constitutional claim, nor that the school district was liable under the state-law claims.The United States Court of Appeals for the First Circuit affirmed the district court's decision. The court found that the school district's conduct, while flawed, did not rise to the level of "conscience-shocking" behavior necessary to establish a violation of B.D.'s substantive due process rights. The court also found that the Doucettes failed to establish that the school district's conduct was the but-for cause of B.D.'s seizures, a necessary element of their state-law claims. View "Doucette v. Jacobs" 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