Justia Civil Rights Opinion Summaries

Parents requested that the Anchorage School District evaluate their child for eligibility for special education services. While awaiting the results of the eligibility assessment, the parents arranged for private tutoring. The school district did not assess the childâs eligibility within the statutorily-required time, and the parents requested a due process hearing. They also arranged for their child to be privately evaluated to determine whether he was eligible for special education services. The school district subsequently completed its evaluation and determined the child to be ineligible for services. At the due process hearing, the parents alleged that the school district committed procedural violations under the federal Individuals with Disabilities Education Act (IDEA), including impermissibly delaying the evaluation. They sought reimbursement for the cost of their childâs private evaluation and tutoring. An independent hearing officer presided over the due process hearing and ultimately agreed with the district that the child was ineligible for services. The hearing officer ordered the school district to pay the cost of the private eligibility assessment and to partially pay the cost of the tutoring. The superior court upheld the award of the private eligibility assessment, but reversed the award of the private tutoring cost. On appeal to the Supreme Court, the school district argued that the parents should not be reimbursed for the evaluation or the tutoring; the parents argued they are entitled to full reimbursement for both expenses. The central question the Court addressed was: where a child is ultimately determined to be ineligible for special education services, does the IDEA provide relief for procedural violations that occur during the process of evaluating the childâs eligibility for services? The Court affirmed the superior courtâs decision, upholding the independent hearing officerâs award of the private assessment cost, but reversing the hearing officerâs award of the private tutoring expenses.

This case arose out of a dispute between plaintiff and her ex-husband over the education and custody of their three minor children. Plaintiff sued City Defendants, alleging that they unlawfully impeded her access to the children. Plaintiff sued the School District Defendants, asserting that they unlawfully denied her access to the children and their education records. The district court dismissed plaintiff's claims against the City Defendants for failure to state a claim and granted summary judgment for the School District Defendants. The court held that the fact that plaintiff lived in a different state did not suffice to convert the loss of a single three-hour visit into a deprivation of a fundamental right for purposes of substantive due process and, even if plaintiff could show a deprivation, the City Defendants' alleged conduct would not shock the conscience. The court also held that plaintiff failed to state a procedural due process claim against the City Defendants, given the relatively minimal deprivation alleged in this case, where the post-deprivation procedures were adequate to protect her rights to be heard at a meaningful time and in a meaningful manner. The court further held that plaintiff had no fundamental liberty interest in contacting her children at their schools and the court agreed with the district court that an attendance clerk's one-time refusal to tell plaintiff why one of the children had been absent from school, a coach's referral of plaintiff to her ex-husband for information about the children's swimming activities, and the school's refusal to send plaintiff all of the school's projects she requested did not amount to a deprivation of a fundamental liberty interest. Given the limited nature of any infringement of plaintiff's protected liberty interest, the procedures at issue were sufficient to protect plaintiff's right to procedural due process. The court finally held that plaintiff's right, as a non-custodial parent, under state law and her role in the children's lives vary significantly from the rights and role afforded to the ex-husband or to a typical married parent. Therefore, the court affirmed the grant of summary judgment to defendants with respect to her equal protection claims. Accordingly, the judgment of the district court was affirmed.

Plaintiff, a high school math teacher, filed suit in federal court alleging that the school district violated his constitutional rights by making him remove banners he displayed in his classroom which referenced "God" and the "Creator." At issue was whether a public school district infringed the First Amendment liberties of plaintiff when it ordered him not to use his public position as a pulpit from which to preach his own views on the role of God in our Nation's history to the captive students in his mathematics classroom. The court agreed with the district court that no genuine issue of material fact remained in the present case. The court held, however, that the district court made a critical error when it determined that the school district had created a limited public forum for teacher speech and evaluated the school district's actions under a traditional forum-based analysis rather than the controlling Pickering-based inquiry. Applying the correct legal principles to the undisputed facts, the court held that the school district was entitled to judgment as a matter of law on each of the claims raised by plaintiff. Therefore, the court reversed and remanded with instructions.

This case stemmed from a dispute regarding the individualized education program (IEP) of C.C., a child with a disability. At issue was whether a school district, after being declared in compliance with the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400-1490, in respect to a disabled child's entitlements, by an administrative hearing officer, could bring a civil action in court for attorneys' fees as a prevailing party against the child's parents on the grounds that their IDEA administrative complaint was brought for an "improper purpose, such as to harass, to cause unnecessary delay, or to needlessly increase the cost of litigation," although the parents had voluntarily dismissed their administrative complaint without prejudice. The court held that, under the plain meaning of the IDEA and its implementing regulations, the administrative proceeding through which the school district sought a declaratory ruling was a proceeding under section 1415. The court also held that the declaratory ruling favorably altered the school district's legal relationship with the parents. Therefore, the court reversed the district court's legal relationship dismissing the school district's civil action and remanded the case for determination of whether the parents' administrative complaint "was delay or to needlessly increase the cost of litigation," and if so, whether the district court should, within its discretion, award attorneys' fees to the school district.

Plaintiffs, parents of deaf and hearing impaired children, brought suit against defendants, claiming that the closure of the South Dakota School for the Deaf and the discontinuation of its programs at the school's campus violated state and federal law. The complaint sought, among other things, class certification and an order enjoining the closure of the school and outsourcing of its programs to other school districts. Plaintiffs subsequently appealed from the district court's order granting summary judgment in favor of defendants. The court held that the district court did not err in converting defendants' motion to dismiss to a motion for summary judgment. The court also held that plaintiffs have failed to allege facts to support their claim that the school's discontinuation of education programs at the Sioux Falls campus violated the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq., and therefore, the district court properly granted summary judgment in favor of defendants on that cause of action. The court further held that plaintiffs have failed to point out any facts supporting their claim that their constitutional rights were violated and therefore, their 42 U.S.C. 1983 cause of action against defendants in their individual capacities failed. The court finally held that plaintiffs did not have standing to sue on behalf of students in the auditory-oral program because they could not show an injury in fact. Therefore, the court concluded that it was within the South Dakota Board of Regents' power to discontinue offering education programs at the school's campus, in favor of contracting with other school districts to offer those programs and maintaining funds in its budgets for students to attend residential programs.

Two administrative hearing panels (Panels) concluded that the school district failed to provide plaintiffs' twin sons with a free appropriate public education (FAPE) in 2005, pursuant to the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq., but did provide one in 2006. The district court upheld these decisions and later awarded attorney's fees to plaintiffs. Plaintiffs and the school district cross appealed. The court held that the school district offered the twins a FAPE in 2005 and therefore, reversed the award of a reduced attorney's fee. The court affirmed, however, the district court's ruling that plaintiffs waived or abandoned their appeal of the Panels' 2006 FAPE decision.

Plaintiffs brought this action for damages under 42 U.S.C. 1983 on behalf of their minor daughter, who allegedly was deprived of her constitutional rights when she was expelled from public school and refused alternative education benefits during the 2005-2006 academic school year by defendants. The district court granted summary judgment in favor of defendants dismissing all of plaintiffs' claims. The court affirmed the district court's summary judgment in principal part, but reversed summary judgment with respect to plaintiffs' claims that their daughter was deprived of her constitutional right to procedural due process when defendants denied her right under state law to continued public educational benefits through an alternative education program without some kind of notice and some kind of hearing. Accordingly, the court remanded the case to the district court for further proceedings.

Plaintiff, a minor with dyslexia, by and through her mother and Guardian Ad Litem, appealed from the district court's order affirming the Administrative Hearing Officer's conclusion that the Hawaii Department of Education (DOE) properly found plaintiff ineligible for services under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq. The court held that the DOE procedurally violated the IDEA by applying regulations that required exclusive reliance on the "severe discrepancy model" at plaintiff's final eligibility meeting. This violation deprived plaintiff of a significant educational opportunity because it resulted in an erroneous eligibility determination. Accordingly, the court reversed the district court's order affirming the Hearing Officer's decision and remanded for further proceedings.

Plaintiffs Ginger James and Deborah Tennison brought suit under 42 U.S.C.1983 alleging Defendant Prue Public Schoolsâ (the District) termination of their employment violated their First and Fourteenth Amendment rights. They appealed a summary judgment that rejected their claims, in which the district court determined (1) their pre-termination hearing satisfied their due-process rights, and (2) they failed to show their speech was a motivating factor for the termination. The School Board became concerned about the Districtâs finances. It initiated a financial investigation by retaining a financial consultant and terminated the treasurerâs employment. Without recommending any particular positions to be cut, Jones further opined there would have to be some reduction in personnel and it appeared the District had too many administrators. Eliminating the positions of an elementary and a high-school principal, it decided, would have the least impact on the students and was in the Districtâs best interest. Accordingly, the Board voted to eliminate the positions due to lack of funds and to dismiss Plaintiffs. Upon review, the Supreme Court found that the issues Plaintiffs raised in their appeal did not create a genuine issue of material fact regarding a denial of due process. Furthermore, they did not establish the occurrence and/or the content of the speech sufficiently for the district court to hold in their favor. Accordingly, the Court affirmed the district courtâs decision.

Ten special education students and their parents and guardians (Appellants) sued Clover Park School District for intentional torts, outrage, negligence and unlawful discrimination under state law. Clover Park moved for summary judgment to dismiss, arguing that Appellants had not exhausted the administrative remedies available under the state Individuals with Disabilities Education Act (IDEA). The trial court granted Clover Parkâs motion. Upon review, the Supreme Court reversed the trial court and remanded the case, holding that IDEAâs administrative exhaustion requirement does not apply to state-law claims nor does Washington State law require exhaustion before filing such claims.