Justia Civil Rights Opinion Summaries

Jane Doe attended high school in City View Independent School District from 2016 to 2020, where she was allegedly sexually abused by her teacher, Robert Morris. The abuse reportedly began when Doe was a fifteen-year-old freshman and continued until she graduated. Doe claims that she reported the abuse to school officials in 2018, but they threatened her with retaliation and did not report the abuse to law enforcement. In 2022, after public outcry over Morris being named coach of the year, Doe publicly stated her experiences, leading to further threats from school officials.Doe filed a lawsuit against City View ISD and several school officials in the United States District Court for the Northern District of Texas on April 4, 2023. The district court dismissed her second amended complaint with prejudice, concluding that her claims were barred by the statute of limitations. Doe appealed the dismissal of her Title IX claims, arguing that her claims were timely due to the continuing violation doctrine or equitable tolling.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court's dismissal. The court held that Doe's Title IX claims were barred by the statute of limitations, as they accrued no later than May 2020 when she graduated. The court also found that Doe's arguments for equitable tolling and the continuing violation doctrine were unavailing. Additionally, the court determined that Doe could not convert her First Amendment retaliation claim, based on a 2022 letter from a school official, into a Title IX retaliation claim. The court concluded that the district court did not abuse its discretion in denying Doe leave to amend her complaint. View "Doe v. City View Independent School District" on Justia Law

M.K., a minor, enrolled in the Pearl River County School District after being homeschooled. During his sixth-grade year, he was bullied by boys in four of his classes, who called him names like "gay." In October, M.K. exposed his genitals to one of the boys in a restroom, claiming it was either accidental or an attempt to prove he was not "gay." The District suspended M.K. and required him to attend an alternative school for six weeks, which he refused, considering it akin to a prison. M.K., through his father, sued the District and others, alleging deliberate-indifference sex-discrimination under Title IX.The United States District Court for the Southern District of Mississippi granted summary judgment in favor of the District, concluding that Title IX does not cover sexual-orientation discrimination and that the alleged behavior was not severe enough to be actionable. M.K. appealed this decision.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo. The court affirmed the district court's decision, holding that the student behavior M.K. experienced, while mean-spirited, did not meet the Supreme Court's stringent standard for "severe, pervasive, and objectively offensive" conduct required for a Title IX claim. The court emphasized that the behavior M.K. described, such as name-calling and teasing, is common in schools and does not rise to the level of actionable harassment under Title IX. The court concluded that M.K.'s experiences, though unfortunate, were not sufficient to sustain his Title IX claim against the District. View "M.K. v. Pearl River County School District" on Justia Law

In this case, Olivia Boone, on behalf of her autistic son K.A., challenged the Rankin County Public School District's decision to move K.A. to a new program at a different school without her consent. Boone filed a complaint with the Mississippi Department of Education, alleging that the school district violated the Individuals with Disabilities Education Act (IDEA) by unilaterally making the placement decision. A hearing officer found that the school district violated the IDEA and ordered relief but denied Boone's request for compensatory educational services. Boone then filed a suit seeking compensatory educational services and attorneys' fees.The United States District Court for the Southern District of Mississippi affirmed the hearing officer's decision, holding that Boone was entitled to attorneys' fees but not compensatory educational services. Boone appealed the denial of compensatory educational services, and the school district cross-appealed the finding that it violated the IDEA and the award of attorneys' fees.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court's judgment. The court held that the school district denied K.A. a free appropriate public education by failing to individualize his education plan to address his elopement tendencies and by predetermining his placement without Boone's input. However, the court found that Boone did not prove that Brandon Middle School was not K.A.'s least restrictive environment. The court also held that Boone was not entitled to compensatory educational services, as the district court did not abuse its discretion in limiting relief to address Boone's primary concerns. Finally, the court affirmed that Boone was a prevailing party entitled to attorneys' fees, as the relief awarded altered the legal relationship between K.A. and the school district and fostered the purposes of the IDEA. View "Boone v. Rankin County" on Justia Law

A transgender girl, D.P., and her mother challenged a new policy by the Mukwonago Area School District that required D.P. to use the boys’ bathroom or a gender-neutral alternative. They argued that the policy violated Title IX of the Education Amendments of 1972 and the Fourteenth Amendment’s Equal Protection Clause. They filed an emergency motion for a temporary restraining order and a preliminary injunction to prevent the policy's enforcement during litigation, citing the precedent set by Whitaker v. Kenosha Unified School District No. 1 Board of Education.The United States District Court for the Eastern District of Wisconsin granted the temporary restraining order and, shortly after, converted it to a preliminary injunction without holding a hearing. The judge found that the case was controlled by the Whitaker precedent and concluded that D.P. was likely to succeed on the merits of her claims. The school district appealed, arguing that the judge erred by not holding an evidentiary hearing and urging the court to overrule Whitaker and a related case, A.C. v. Metropolitan School District of Martinsville.The United States Court of Appeals for the Seventh Circuit affirmed the district court’s decision. The appellate court held that an evidentiary hearing is not always required before issuing a preliminary injunction, especially when the opponent does not request one or identify material factual disputes. The court also declined to revisit or overrule Whitaker and Martinsville, reaffirming that the district judge did not abuse his discretion in granting the preliminary injunction based on binding circuit precedent. The court concluded that the slight differences in D.P.'s case did not warrant a different outcome. View "Doe v Mukwonago Area School District" on Justia Law

A.J.T., a teenage girl with a rare form of epilepsy, moved to Minnesota in 2015. Her new school district, Osseo Area Public Schools, denied her parents' requests to include evening instruction in her Individualized Educational Program (IEP), despite her inability to attend school before noon due to frequent morning seizures. Consequently, A.J.T. received only 4.25 hours of instruction daily, compared to the typical 6.5-hour school day for nondisabled students. After further cuts to her school day were proposed, her parents filed an IDEA complaint, alleging that the refusal to provide afterhours instruction denied A.J.T. a free appropriate public education.An Administrative Law Judge ruled in favor of A.J.T., finding that the school district violated the IDEA and ordered compensatory education and evening instruction. The Federal District Court and the Eighth Circuit Court of Appeals affirmed this decision. However, when A.J.T. and her parents sued under the ADA and the Rehabilitation Act, the District Court granted summary judgment for the school, and the Eighth Circuit affirmed, stating that a plaintiff must prove bad faith or gross misjudgment by school officials to establish a prima facie case of discrimination.The Supreme Court of the United States reviewed the case and held that schoolchildren bringing ADA and Rehabilitation Act claims related to their education are not required to make a heightened showing of bad faith or gross misjudgment. Instead, they are subject to the same standards that apply in other disability discrimination contexts. The Court vacated the Eighth Circuit's judgment and remanded the case for further proceedings consistent with this opinion. View "A. J. T. v. Osseo Area Schools, Independent School Dist. No. 279" on Justia Law

R.M.A., a transgender student who transitioned from female to male, attended public school in the Blue Springs R-IV School District. R.M.A. requested to use male-designated restrooms and locker rooms during the 2013-2014 and 2014-2015 school years, but the School District denied the request. R.M.A. filed a charge of discrimination with the Missouri Commission on Human Rights, alleging public accommodation discrimination based on sex. After receiving a notice of right to sue, R.M.A. filed a petition against the School District, claiming sex discrimination under the Missouri Human Rights Act (MHRA).The Circuit Court of Jackson County dismissed R.M.A.'s petition, stating that the public accommodation protection in section 213.065 does not cover claims based on gender identity. The Missouri Supreme Court reversed this decision in R.M.A. I, finding that R.M.A. had pleaded sufficient facts to establish a claim of sex discrimination and remanded the case for further proceedings. On remand, R.M.A. proceeded to trial, and the jury found the School District liable for sex discrimination, awarding R.M.A. compensatory and punitive damages.The School District filed a motion for judgment notwithstanding the verdict (JNOV) or, alternatively, a motion for a new trial, arguing that R.M.A. failed to make a submissible case for sex discrimination. The circuit court sustained the JNOV motion, finding that the evidence showed R.M.A. was excluded from male facilities due to female genitalia, not male sex. R.M.A. appealed.The Supreme Court of Missouri affirmed the circuit court's judgment, holding that R.M.A. did not present sufficient evidence that the School District's denial was based on R.M.A.'s male sex. The court concluded that the term "sex" in section 213.065 refers to biological sex, and the evidence indicated the School District's decision was based on R.M.A.'s female genitalia. Consequently, the court upheld the JNOV and denied R.M.A.'s motion for attorney fees. View "R.M.A. vs. Blue Springs R-IV School District" on Justia Law

A group of parents sued their local public school district and the State of Michigan, alleging that their children were denied essential special-education services. The parents claimed that the school district failed to provide promised services, such as full-time aides and speech therapy, and that the State failed to supervise the district adequately. The parents sought damages under the Americans with Disabilities Act (ADA) and the Rehabilitation Act, and injunctive relief under the Individuals with Disabilities Education Act (IDEA), ADA, and Rehabilitation Act.The United States District Court for the Eastern District of Michigan denied the State's motion to dismiss, holding that the ADA abrogated the State's sovereign immunity under the Fourteenth Amendment. The State then filed an interlocutory appeal.The United States Court of Appeals for the Sixth Circuit reviewed the case and reversed the district court's decision. The Sixth Circuit held that the parents failed to state a claim against the State under Title II of the ADA. The court explained that Title II allows lawsuits against a public entity for its own actions, not for the actions of another government entity. In this case, the school district, not the State, was responsible for the alleged denial of services. The court also noted that the State had already taken corrective actions against the school district and that the parents' claims of the State's failure to supervise were too conclusory to proceed. Therefore, the State was entitled to sovereign immunity, and the parents' ADA claim against the State was dismissed. View "Y.A. v. Hamtramck Public Schools" on Justia Law

Holly Lawson, a guidance counselor at Franklin County High School, alleged that her Fourth Amendment rights were violated by her coworkers, Kayla Creely and Lori Franke, and by School Superintendent Mark Kopp, along with the Franklin County, Kentucky Board of Education. Lawson claimed that Creely and Franke searched her bag without her consent, discovering a firearm, and that Kopp unlawfully detained and searched her in connection with this incident.The United States District Court for the Eastern District of Kentucky granted summary judgment in favor of the defendants. The court found that Creely and Franke were acting under color of state law but were entitled to qualified immunity. It also determined that Kopp's actions constituted a lawful investigative stop under Terry v. Ohio and that Lawson consented to the search of her bag.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision. The appellate court concluded that Creely and Franke did not act under color of state law because their actions were not authorized by any school policy or state authority. The court also agreed that Kopp's interaction with Lawson was a lawful investigative stop supported by reasonable suspicion and that Lawson voluntarily searched her own bag, negating any Fourth Amendment violation. Consequently, the court found no basis for municipal liability under Monell against the Board. View "Lawson v. Creely" on Justia Law

John Doe, a high school student with several psychological disabilities, repeated his freshman year at an out-of-state boarding school. Upon returning to Rhode Island, he sought a waiver from the Rhode Island Interscholastic League (the League) to extend his eligibility to play sports into his fifth year of high school, citing his disabilities as the reason for his request. The League denied the waiver, stating that his ineligibility was due to his voluntary decision to repeat the ninth grade, not his disabilities.Doe's parents appealed the League's decision to the Waiver Request Hearing Committee and the Principals' Committee, both of which upheld the denial. Subsequently, Doe filed a lawsuit in the District of Rhode Island, claiming that the League's refusal violated Titles II and III of the Americans with Disabilities Act (ADA). The district court granted a permanent injunction, allowing Doe to play sports in his fifth year, reasoning that the League's rule was not an essential aspect of its program and that Doe's disability was the but-for cause of his ineligibility.The United States Court of Appeals for the First Circuit reviewed the case and vacated the district court's injunction. The appellate court concluded that Doe's disability was not the but-for cause of his ineligibility, as his decision to repeat the ninth grade was unrelated to his disability. Additionally, the court held that waiving the eight-semester rule would fundamentally alter the League's interscholastic athletics program, which aims to ensure competitive parity and maximize student participation. Thus, the requested accommodation was deemed unreasonable. View "Doe v. Rhode Island Interscholastic League" on Justia Law

Neysha Cruz, on behalf of her son O.F., filed a lawsuit against the New York City Department of Education (DOE) under the Individuals with Disabilities Education Act (IDEA). Cruz rejected the DOE's education plan for O.F., who has multiple disabilities, and sought reimbursement for his private school tuition. Cruz argued that the DOE's placement of O.F. in a twelve-student classroom violated a New York regulation requiring students with highly intensive management needs to be placed in classes of six or fewer students. The DOE acknowledged the regulation but argued that another regulation allowing a maximum of twelve students for those with severe multiple disabilities also applied, giving them discretion in class size placement.An Impartial Hearing Officer (IHO) initially found that the DOE offered O.F. a Free Appropriate Public Education (FAPE) but that the recommended school could not implement the IEP due to scheduling issues. The IHO ordered partial reimbursement for private tuition. The State Review Officer (SRO) reversed the IHO's finding on the school's ability to implement the IEP and concluded that the DOE provided a FAPE, thus denying reimbursement.The United States District Court for the Southern District of New York upheld the SRO's decision, agreeing that the DOE could choose between the two class size regulations. Cruz appealed to the United States Court of Appeals for the Second Circuit.The Second Circuit found that the case hinged on interpreting New York's education regulations and certified the question to the New York Court of Appeals. The court sought clarification on whether the DOE must satisfy both class size regulations or if it can choose between them when both apply to a student. The Second Circuit retained jurisdiction pending the state court's response. View "Cruz v. Banks" on Justia Law