Justia Civil Rights Opinion Summaries

In this case, a minor student known as A.J.T., who suffers from epilepsy, sued her school district, Osseo Area Schools, alleging disability discrimination for not providing her evening instruction sessions. A.J.T.'s epilepsy is severe in the mornings, preventing her from attending school until noon. The child's parents requested evening instruction so that she could have a school day closer in length to her peers. However, the school district denied these requests.A.J.T., through her parents, filed a lawsuit alleging violations of Section 504 of the Rehabilitation Act and the Americans with Disabilities Act (ADA). The district court granted Osseo Area Schools' motion for summary judgment, finding that the school district could not be held liable as it did not act with bad faith or gross misjudgment.The United States Court of Appeals for the Eighth Circuit affirmed the district court's decision. The court stated that while A.J.T. might have established a genuine dispute about whether the district was negligent or even deliberately indifferent, she failed to prove that school officials acted with "either bad faith or gross misjudgment." The court found that the school district did not ignore A.J.T.'s needs or delay its efforts to address them. It further held that in cases involving educational services for disabled children, mere noncompliance with applicable federal statutes or failure to provide a reasonable accommodation is not enough to trigger liability. The plaintiff must prove that the school officials acted with bad faith or gross misjudgment. In this case, A.J.T. failed to identify conduct that cleared that high bar, and as such, the court held that summary judgment was proper. View "A.J.T. v. Osseo Area Schools, Independent School District No. 279" on Justia Law

In this case, the United States Court of Appeals for the Eighth Circuit considered the appeal of Osseo Area Schools (the District) against the ruling of the district court, which held that the District had denied A.J.T., a student with a disability, a Free Appropriate Public Education (FAPE) as mandated by the Individuals with Disabilities Education Act (IDEA). A.J.T. suffers from a rare form of epilepsy, causing seizures that prevent her from attending school before noon. Consequently, her parents had requested the District to provide evening instruction, which was refused.The district court found that the District's refusal to provide A.J.T. with evening instruction resulted in her making de minimis progress overall and even regressing in some areas, such as toileting. The court also determined that A.J.T. would have made more progress had she received evening instruction. On these grounds, the court concluded that the District had failed to provide A.J.T. with a FAPE.On appeal, the Eighth Circuit affirmed the district court's judgment. The court rejected the District's argument that the IDEA's scope was limited to regular school hours, noting nothing in the IDEA suggested such a limitation. Furthermore, the court agreed with the district court's assessment of A.J.T.'s limited progress and regression in toileting. After considering the evidence, the court concluded that the District's refusal to provide evening instruction, based solely on administrative concerns, resulted in A.J.T.'s minimal progress and denied her a FAPE. View "Osseo Area Schools, Independent School District No. 279 v. A.J.T." on Justia Law

In the United States Court of Appeals for the Seventh Circuit, Parents Protecting Our Children, an association of parents, sought an injunction against the Eau Claire Area School District in Wisconsin to stop the enforcement of the District’s Administrative Guidance for Gender Identity Support. The parents argued that the policy violated the Due Process and Free Exercise Clauses of the U.S. Constitution by interfering with their right to make decisions on behalf of their children. The District Court dismissed the case due to lack of subject matter jurisdiction, stating that the parents failed to identify any instance where the policy was applied in a way that infringed on parental rights.The Court of Appeals affirmed the lower court's ruling. The court held that the parents' concerns about potential applications of the policy did not establish standing to sue unless the policy resulted in an injury or created an imminent risk of injury. The court stated that the parents had brought a pre-enforcement facial challenge against the policy without any evidence of the School District applying the policy in a manner detrimental to parental rights.The court also noted that the Administrative Guidance did not mandate exclusion of parents from discussions or decisions regarding a student’s gender expression at school. The court found that the alleged harm was dependent on a speculative "chain of possibilities," which was insufficient to establish Article III standing. Therefore, the court upheld the dismissal of the lawsuit for lack of subject matter jurisdiction. View "Parents Protecting Our Children, UA v. Eau Claire Area School District" on Justia Law

The Supreme Court of the State of Washington was required to make a decision on a case involving a high school student, M.G., who was expelled on an emergency basis by Yakima School District No. 7 (the District). The District later extended the expulsion to a long-term suspension without providing M.G. with the statutorily required procedural protections. The Court of Appeals found that M.G. was indefinitely suspended in violation of his statutory procedural rights and reversed the dismissal of M.G.’s suit by the superior court.M.G., a high school student, had previously signed a behavior agreement, or “gang contract." He was expelled from school for violating this contract and for his involvement in an altercation with another student. The District converted M.G.’s 10-day emergency expulsion into a long-term suspension. M.G. was later enrolled in an online learning program, which did not meet his academic needs.The Supreme Court of the State of Washington agreed with the Court of Appeals, holding that the District’s decision was disciplinary and that M.G. had a right to due process, which was violated. The court determined that under RCW 28A.600.015(1) and WAC 392-400-430(8), M.G. was entitled to return to his regular educational setting following the conclusion of his suspension. The court also found compensatory education to be a potential equitable remedy for violations of student disciplinary statutes and regulations. The case was remanded to the superior court to determine the appropriate remedy. View "M.G. v. Yakima Sch. Dist. No. 7" on Justia Law

In the case between Alex W., a student with disabilities, and Poudre School District R-1, the United States Court of Appeals for the Tenth Circuit had to decide whether the school district provided Alex with a free appropriate public education (FAPE) under the Individuals with Disabilities Education Act. Alex's parents alleged that the district had denied Alex a FAPE, whereas the district counterclaimed seeking reversal of a reimbursement order for an independent evaluation.After a detailed review of the evidence provided, the court held that the school district had fulfilled its obligations under the IDEA. It ruled that the district had appropriately identified and addressed Alex's behavioral needs, that Alex's Individualized Education Programs were reasonably calculated to allow him to make progress, and that the district had appropriately evaluated Alex in all areas of disability.The court also held that the district was within its rights to reduce Alex's direct therapy hours and that Alex was not denied a FAPE because he was not provided extended school year services. Furthermore, the court ruled that while parents have a right to request an independent educational evaluation (IEE) at public expense if they disagree with a school district's evaluation, they are only entitled to one publicly-funded IEE for each district evaluation. Therefore, the court reversed the district court's order requiring the school district to reimburse Alex's parents for a second IEE. View "W. v. Poudre School District R-1" on Justia Law

The US Court of Appeals for the Third Circuit dealt with two consolidated cases involving two New Jersey parents, who claimed they were retaliated against for protesting school policies related to mandatory masking during the COVID-19 pandemic. One parent, George Falcone, was issued a summons for defiant trespass after refusing to wear a mask at a school board meeting, while another parent, Gwyneth Murray-Nolan, was arrested under similar circumstances. Falcone claimed retaliation for exercising his First Amendment rights, while Murray-Nolan argued the same and also claimed she was deprived of substantive due process. The district court dismissed both cases. On appeal, the court found that Falcone had standing to sue, reversing and remanding the lower court's decision. However, the court affirmed the dismissal of Murray-Nolan's case, concluding that refusing to wear a mask during a pandemic was not protected conduct under the First Amendment. View "Murray-Nolan v. Rubin" on Justia Law

In a case before the United States Court of Appeals for the Eighth Circuit, the plaintiffs, The Arc of Iowa and several parents of children with disabilities, sought to challenge a provision of the Iowa Code that prevents schools from imposing mask mandates unless required by other laws. They had received a preliminary injunction from a lower court that had been vacated by this court due to changing circumstances related to the COVID-19 pandemic. On remand, the district court granted the plaintiffs' motion for summary judgment, declaring that the phrase 'other provisions of law' in the contested Iowa Code section includes Title II of the Americans with Disabilities Act (ADA) and section 504 of the Rehabilitation Act, and that the contested Iowa Code section cannot be cited as the sole basis for denying a student's request for reasonable modification or accommodation under the ADA or the Rehabilitation Act that requires others to wear masks.The defendants, the Governor of Iowa and the Director of the Iowa Department of Education, appealed to the Eighth Circuit, raising issues of exhaustion of remedies under the Individuals with Disabilities Act (IDEA), standing of the plaintiffs, and the propriety and necessity of the relief granted by the district court.The appellate court, after de novo review, found that the plaintiffs failed to meet the requirements for standing, which include having suffered an injury in fact, traceability of the injury to the defendant's conduct, and the likelihood of redress by a favorable judicial decision. The court found that the general risks associated with COVID-19 were not enough to constitute "imminent and substantial" harm for standing. It also concluded that the plaintiffs had not demonstrated that the alleged injuries were fairly traceable to the conduct of the Governor or the Director of the Department of Education. As a result, the court vacated the district court's order and remanded the case with instructions to dismiss due to lack of standing. View "The Arc of Iowa v. Reynolds" on Justia Law

A former medical student at the University of Virginia School of Medicine, Kieran Bhattacharya, sued multiple university officials, alleging they reprimanded, suspended, and expelled him in violation of the First Amendment because of his views expressed during a faculty panel on microaggressions. The officials asserted that they took these actions due to Bhattacharya’s confrontational and threatening behavior.The United States District Court for the Western District of Virginia held that Bhattacharya could not provide evidence that the officials punished him due to his speech, siding with the officials. Bhattacharya appealed to the United States Court of Appeals for the Fourth Circuit.The Fourth Circuit affirmed the district court's decision. The court held that Bhattacharya failed to present evidence sufficient to create a triable issue as to whether his speech caused the actions taken against him. The court found that the university's administrators appropriately exercised their authority to ensure the safety of the school’s faculty and staff. The court also affirmed the district court's denial of Bhattacharya's request to amend his complaint to add a conspiracy claim and the dismissal of his due process claim. View "Bhattacharya v. Murray" on Justia Law

The case involves Pablo Abreu, a student who was expelled from Howard University College of Medicine. Abreu appealed his expulsion, arguing that the university violated his rights under Title III of the Americans with Disabilities Act (ADA) and the Rehabilitation Act of 1972 by refusing to grant him additional opportunities to retake a required examination, in light of his diagnosed test-taking-anxiety disability. The district court dismissed his complaint, applying a one-year statute of limitations and ruling that his claims were time-barred.The United States Court of Appeals for the District of Columbia Circuit disagreed with the lower court's application of a one-year statute of limitations to Abreu’s ADA and Rehabilitation Act claims. The court pointed to its decision in another case, Stafford v. George Washington University, in which it concluded that a three-year statute of limitations should apply to civil rights claims under Title VI of the Civil Rights Act of 1964. Since Abreu's ADA and Rehabilitation Act claims were also civil rights claims alleging discrimination, the court ruled that the three-year statute of limitations should apply. This made Abreu’s claims timely since he filed the suit less than three years after his expulsion.The court then remanded the case back to the district court for further proceedings on the ADA and Rehabilitation Act claims. However, it affirmed the dismissal of Abreu's contractual claims, agreeing with the district court that Abreu failed to state a claim for breach of contract. View "Abreu v. Howard University" on Justia Law

In the case at hand, the United States Court of Appeals for the Third Circuit affirmed the dismissal of claims brought by a group of students and Children’s Health Defense, Inc. against Rutgers University. The plaintiffs challenged the university's COVID-19 vaccination policy, which required in-person students to be vaccinated or else enroll in online programs or seek exemptions for medical or religious reasons. The court found that the university's policy did not violate the plaintiffs' constitutional or statutory rights.The court held that there is no fundamental right to refuse vaccination. It applied the rational basis review and concluded that Rutgers University had a rational basis for its policy given the challenges posed by the COVID-19 pandemic. The court also rejected the plaintiffs' claim that the policy was ultra vires under New Jersey law, determining that Rutgers was authorized to require COVID-19 vaccinations under state law. Furthermore, the court dismissed the plaintiffs' equal protection claim, concluding that Rutgers had a rational basis for its differential treatment of students and staff, as well as vaccinated and unvaccinated students. View "Children's Health Defense Inc. v. Rutgers, the State University of New Jersey" on Justia Law