Justia Civil Rights Opinion Summaries

In the case involving a high school student, Jacob Bradley, and his parents, the United States Court of Appeals for the Sixth Circuit concluded that the Individuals with Disabilities Education Act (IDEA) does not require states to provide special education services to students participating in dual-credit or dual-enrollment programs offered at postsecondary institutions.Jacob Bradley, a gifted student with several physical and cognitive conditions, was enrolled in the Craft Academy for Excellence in Science and Mathematics, a state-run dual-credit program located at Morehead State University. His parents sought reimbursement for special education support accommodations provided at Craft under IDEA. However, the district court ruled that IDEA, which offers federal funds to states to provide free appropriate public education to students with disabilities, does not apply to Craft because its dual-credit classes provide postsecondary rather than secondary school education.The Court of Appeals affirmed this decision, holding that the IDEA’s obligation to provide a "free appropriate public education" applies to "secondary," not postsecondary, education. The court also noted that, under Kentucky law, Craft is considered a postsecondary school because it delivers a college-level course of study on a college campus.The court also concluded that the state and federal agencies' interpretation of the IDEA and the state law, which excluded dual-credit courses at postsecondary institutions from IDEA’s mandate, was correct. The court emphasized that the IDEA is a spending clause legislation that operates as a contract between the federal government and states, and states need to comply only with clearly written terms in the Act, not uncertain or ambiguous ones.Additionally, the court affirmed the dismissal of the Bradleys' claims under the Americans with Disabilities Act and Section 504 of the Rehabilitation Act, as they failed to demonstrate how the Commonwealth separately violated the provisions of these distinct Acts.In conclusion, the court held that the IDEA does not obligate Kentucky school districts to provide special education services to a student participating in dual-credit classes offered at a postsecondary institution. The court also affirmed the dismissal of the Bradleys' claims under the Americans with Disabilities Act and Section 504 of the Rehabilitation Act. View "Bradley v. Jefferson Cnty. Public Schs." on Justia Law

This case concerns John HR Doe and other Doe plaintiffs, who alleged that William Babcock, a counselor at an elementary school in the Marysville Joint Unified School District, committed sexual misconduct causing them injury and damages. The Doe plaintiffs filed three separate lawsuits against the School District. The first two, filed in state court, were voluntarily dismissed. The third, filed in federal court, also alleged violations of federal law. The School District moved to dismiss the federal court action, claiming immunity under the Eleventh Amendment for most of the claims. The Doe Plaintiffs then voluntarily dismissed their federal court action and filed a third state court action.The School District demurred to the third state court complaint, arguing res judicata based on the plaintiffs' voluntary dismissal of the second action in federal court. The trial court sustained the demurrer and dismissed the complaint, ruling that the dismissal of the federal court action constituted res judicata. On appeal, the Doe plaintiffs contended that the federal court lacked subject matter jurisdiction to adjudicate the claims on the merits because the School District argued Eleventh Amendment immunity. They also argued that California state law controls, under which a second voluntary dismissal does not constitute res judicata.The Court of Appeal of the State of California, Third Appellate District, affirmed the trial court's decision. The appellate court found that the federal court did have subject matter jurisdiction over the plaintiffs' claims because it had jurisdiction over the federal law claims, with supplemental jurisdiction over the state-law claims. Moreover, the court held that res judicata applied because federal law determines the claim-preclusive effect of a federal court judgment in a federal question case, and under federal law, a second voluntary dismissal operates as an adjudication on the merits. The court rejected the plaintiffs' argument that California law should control, stating that states must accord federal court judgments the effect that federal law prescribes. As such, the Doe plaintiffs' third state court action was barred by res judicata due to their second voluntary dismissal in federal court. View "Doe v. Marysville Joint Unified Sch. Dist." on Justia Law

In the Matter of Antavis Chavis, the Supreme Court of Maryland ruled that a bar applicant diagnosed with Attention Deficit Hyperactivity Disorder (ADHD) had met his burden to prove that he had a "disability" under the Americans with Disabilities Act of 1990 (ADA) and that the testing accommodation he requested—50% additional time to take the Uniform Bar Examination (UBE)—was warranted. The court adopted a two-step test to determine whether a bar examination test accommodation request should be granted. First, the court must determine if the applicant meets the ADA definition of "disability." Second, the court must determine if the test accommodation requested by the applicant is "reasonable, consistent with the nature and purpose of the examination and necessitated by the applicant’s disability." The court observed that under the ADA and related federal regulations, the definition of disability should be broadly construed and that evidence of past test accommodations must be given considerable weight. The court sustained the applicant’s exceptions to the denial of his test accommodation request by the State Board of Law Examiners (SBLE), reversed the denial, and remanded the matter to the SBLE with instruction to grant the applicant’s test accommodation request. View "In the Matter of Antavis Chavis" on Justia Law

This case involves the Boston Parent Coalition for Academic Excellence Corp., which challenged the temporary admissions plan for three selective public schools in Boston. The admissions plan was based on students' grade point averages (GPAs), zip codes, and family income, rather than on standardized test scores. The Coalition claimed that the plan had a disparate impact on White and Asian students and violated the Equal Protection Clause of the Fourteenth Amendment and Massachusetts law.The United States Court of Appeals for the First Circuit found that the Coalition's claim lacked merit. It held that the Coalition failed to show any relevant disparate impact on White and Asian students, who were over-represented among successful applicants compared to their percentages of the city's school-age population. The court also found that the Coalition failed to demonstrate that the plan was motivated by invidious discriminatory intent. It pointed out that the Plan's selection criteria, which included residence, family income, and GPA, could hardly be deemed unreasonable.The court noted that any distinction between adopting a criterion (like family income) notwithstanding its tendency to increase diversity, and adopting the criterion because it likely increases diversity, would, in practice, be largely in the eye of the labeler. It emphasized that the entire point of the Equal Protection Clause is that treating someone differently because of their skin color is not like treating them differently because they are from a city or from a suburb.The court also rejected the Coalition's appeal of the district court's denial of its motion under Federal Rule of Civil Procedure 60(b), which sought relief from the judgment based on newly discovered evidence that some members of the School Committee harbored racial animus. The court found that the district court did not abuse its discretion in denying the motion, as the Coalition had failed to show that the newly discovered evidence was of such a nature that it would probably change the result were a new trial to be granted.The court therefore affirmed the judgment of the district court. View "Boston Parent Coalition for Acad. Excellence Corp. v. The School Committee of the City of Boston" on Justia Law

In 2015, a group of parents brought a class action lawsuit on behalf of their children, who were enrolled in Minneapolis and Saint Paul public schools. The parents claimed that the state of Minnesota violated their children's right to an adequate education under the Education Clause of the Minnesota Constitution due to the racial and socioeconomic segregation present in the schools. The case went through several years of litigation, and the district court certified a question for immediate appeal: whether racial imbalances in Minneapolis and Saint Paul public schools are sufficient, standing alone, to establish a violation of the Education Clause. The Minnesota Supreme Court reformulated the certified question and held that racial imbalances in Minneapolis and Saint Paul public schools, standing alone, are not sufficient to establish a violation of the Education Clause. The court ruled that while the parents do not have to establish that state action caused the racial imbalances, they must show that the racial imbalances are a substantial factor in causing their children to receive an inadequate education. The case was remanded back to the district court for further proceedings. View "Cruz-Guzman, as guardian and next friend of his minor children vs. State of Minnesota" on Justia Law

In this case, an unincorporated association, Saline Parents, and six individuals sued the Attorney General of the United States, Merrick Garland, alleging that the Department of Justice (DOJ) was unlawfully attempting to silence them and others who opposed progressive curricula and policies in public schools. This lawsuit was in response to a memorandum issued by the Attorney General, expressing concern over the increase in reported incidents of harassment, intimidation, and threats of violence against school administrators, board members, teachers, and staff. The memorandum instructed the DOJ staff to investigate the issue and discuss strategies to address it. The plaintiffs argued that their protest activities, which included constitutionally protected conduct and did not involve threats of criminal violence, had been unfairly targeted by the DOJ.The United States Court of Appeals for the District of Columbia Circuit upheld the dismissal of the case by the District Court on the grounds that the plaintiffs lacked standing to pursue this action. The court agreed with the government's argument that the plaintiffs' lawsuit was not ripe for adjudication, indicating that the plaintiffs' claims were based on hypothetical future events that may not occur. The court also found that the plaintiffs had failed to demonstrate that the government had in any way threatened imminent enforcement action against them or had labeled them in a way that impugned their reputations. The court concluded that the plaintiffs' claim was based on contingencies and speculation, making the dispute premature for judicial resolution. View "Saline Parents v. Garland" on Justia Law

The United States Court of Appeals for the Second Circuit ruled that a group of non-transgender female athletes have legal standing to challenge a policy that allows transgender girls to compete in girls' high school sports. The athletes had sued the Connecticut Association of Schools and several school districts, claiming that the policy violated Title IX by depriving them of equal athletic opportunity. The court held that the athletes had established Article III standing because they had plausibly stated a concrete, particularized, and actual injury in fact - the alleged denial of equal athletic opportunity and concomitant loss of publicly recognized titles and placements during track and field competitions in which they competed against and finished behind transgender athletes. The court also held that the injury was plausibly redressable by monetary damages and an injunction ordering defendants to alter certain athletic records. The court did not rule on the merits of the athletes' Title IX claim, instead remanding the case to the district court for consideration of whether the athletes have plausibly stated a claim under Title IX. View "Soule ex rel. Stanescu v. Connecticut Association of Schools, Inc." on Justia Law

In this case, the Virginia Supreme Court ruled in favor of Peter Vlaming, a high school French teacher who was terminated by the West Point School Board for refusing to use a transgender student's preferred pronouns. Vlaming had chosen to use the student's preferred name but avoided using any third-person pronouns to refer to the student as it conflicted with his religious beliefs. The School Board fired Vlaming for not complying with its policy to use government-mandated pronouns.Vlaming sued the School Board, alleging that his termination violated his constitutional, statutory, and breach-of-contract rights. The Circuit Court dismissed Vlaming's claims, holding that they failed to state legally viable causes of action. The Supreme Court of Virginia, however, reversed the decision and remanded the case for further proceedings. The Court concluded that Vlaming's complaint sufficiently alleged that the School Board substantially burdened his right to free exercise of religion under the Virginia Constitution and that his claims under the Virginia Religious Freedom Restoration Act should not have been dismissed. Moreover, the Court held that Vlaming has alleged a viable compelled speech claim under the free speech provision of the Virginia Constitution. The Court rejected the School Board's argument that it could compel Vlaming's speech as part of his official duties as a teacher. The Court concluded that Vlaming's refusal to use certain pronouns did not interfere with his duties as a French teacher or disrupt the school's operations.The Court's decision reaffirmed the fundamental right to free speech and the free exercise of religion under the Virginia Constitution, emphasizing that these rights extend to public school teachers in their interactions with students. It clarified that although the government has a legitimate interest in ensuring non-discrimination and respect for all students, this interest must be balanced against individual rights to free speech and the free exercise of religion. The Court also clarified that a public school teacher's speech in the classroom is not entirely within the control of the school board and that teachers cannot be compelled to express views that conflict with their sincerely held religious beliefs. View "Vlaming v. West Point School Board" on Justia Law

This case involves Delta Charter Group, Inc. (Delta), a public charter school operating within Concordia Parish in Louisiana. The case has its roots in a 1965 lawsuit against the Concordia Parish School Board for operating segregated schools in violation of the Fourteenth Amendment. The district court approved a desegregation plan, but the Board has yet to achieve unitary status, and Delta, which had intervened in the ongoing desegregation case, was required by a 2013 consent order to comply with the Board's desegregation decree. A second consent order in 2018 outlined a race-based enrollment process for Delta, giving the highest enrollment preference to black students.Four years later, Delta moved to discontinue the race-based enrollment process, arguing that it was unconstitutional. The district court declined to modify the order under Federal Rule of Civil Procedure 60(b)(5), which allows courts to modify or dissolve a consent decree if applying it prospectively is no longer equitable. Delta failed to show a significant change in factual conditions or in law that would justify modification. The United States Court of Appeals for the Fifth Circuit affirmed the judgment of the district court, stating that Delta had forfeited any argument that the district court had abused its discretion by failing to adequately brief the argument on appeal. The court did not offer any opinion on the underlying constitutional merits, as Delta had forfeited any available argument that the district court should have applied Rule 54(b) and that it had abused its discretion in denying relief under Rule 60(b)(5). View "Delta Charter v. Sch Bd Concordia Prsh" on Justia Law

In the State of Montana, a group of parents and the non-profit organization Stand Up Montana sued several school districts in Missoula County over the implementation of mask mandates in schools during the COVID-19 pandemic. The plaintiffs argued that the mask mandates violated their substantive due process rights. The Fourth Judicial District Court granted summary judgment in favor of the school districts, finding the mask mandates did not violate the plaintiffs' substantive due process rights. The Supreme Court of the State of Montana affirmed the lower court's decision. The Supreme Court reiterated that the mask mandates did not implicate any fundamental rights under Article II of the Montana Constitution, and therefore, the rational basis test was the appropriate standard of review. Under the rational basis test, the court found that the mask mandates were rationally related to the legitimate government interest of stemming the spread of COVID-19, as the school districts had considered information and recommendations from reputable public and private health care providers and agencies, including the CDC, which all recommended universal masking. The court also affirmed the lower court's decision to grant a motion in limine to exclude testimony from the plaintiffs' hybrid witnesses, as the proffered testimony was not relevant to whether the mask policies were rationally related to stemming the spread of COVID-19. View "Stand Up Montana v. Msla Co. Schools" on Justia Law