Justia U.S. 1st Circuit Court of Appeals Opinion Summaries

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

A minor, L.M., represented by his father and stepmother, sued the Town of Middleborough, Massachusetts, the Middleborough School Committee, and various school officials, alleging that his First Amendment rights were violated when he was prohibited from wearing a t-shirt that read "There Are Only Two Genders" at his public middle school. The United States District Court for the District of Massachusetts denied L.M.'s motion for a preliminary injunction and granted final judgment in favor of the defendants.On appeal, the United States Court of Appeals for the First Circuit affirmed the District Court's rulings. The Court of Appeals held that the school officials reasonably interpreted the message on L.M.'s t-shirt as demeaning to the gender identities of other students. The court also found that the school officials reasonably forecasted that the t-shirt's message would negatively affect the psychology of students with the demeaned gender identities and disrupt the learning environment. The court concluded that the school's actions were permissible under the "material disruption" limitation of the Supreme Court's decision in Tinker v. Des Moines Independent Community School District, which allows schools to regulate student speech that materially disrupts classwork or involves substantial disorder.The Court of Appeals also rejected L.M.'s facial challenges to the school's dress code, finding that he lacked standing to challenge one provision and that the other provision was not unconstitutionally vague or overbroad. View "L. M. v. Town of Middleborough, Massachusetts" on Justia Law

This appeal, heard by the United States Court of Appeals for the First Circuit, centered on the constitutionality of Massachusetts' Law 80, which retroactively provided immunity to higher education institutions for monetary damages due to actions taken in response to the COVID-19 pandemic. The plaintiffs, students at Boston University (BU), had sued the university for breach of contract and unjust enrichment following BU's transition to remote learning during the Spring 2020 semester. They contended that they had paid for in-person instruction and services, which BU failed to provide.The lower court ruled in favor of BU, holding that the university was entitled to the defense of impossibility as it had to comply with COVID-19 emergency orders. On appeal, the court was required to consider whether the retroactive application of Law 80 to the case violated the Due Process Clause of the United States Constitution.The appellate court found that Law 80 served reasonable public interests related to public health, safety, future compliance, and economic consequences beyond the control of the universities. The court also determined that the plaintiffs' alleged implied contract rights did not constitute vested rights. Furthermore, the court noted that the scope of Law 80 was appropriately limited and did not excessively burden the plaintiffs.Consequently, the court held that Law 80 does not violate due process and affirmed the lower court's judgment, ruling in favor of BU. The court did not need to consider the merits of the lower court's decision to exclude the plaintiffs' expert witness's testimony. View "Dutra v. Trustees of Boston University" on Justia Law

In a case involving an attorney father, Scott D. Pitta, and the Bridgewater-Raynham Regional School District, the United States Court of Appeals for the First Circuit affirmed the district court's dismissal of Pitta's claim that he had a First Amendment right to video record a private meeting discussing his child's Individualized Educational Program (IEP). The court found that an IEP Team Meeting does not occur in a public space, is closed to the public, and involves discussion of highly sensitive information about a student. Furthermore, the court stated that public school teachers and administrators carrying out their IEP obligations are not akin to the "public officials" in previous cases that established a First Amendment right to record. The court also noted that Pitta's claimed right to record was not linked to the public's right to receive information. Finally, the court reasoned that even if there were a First Amendment right to record such meetings, the school district's prohibition of video recording served a significant governmental interest and was narrowly tailored to promoting candid conversations and protecting sensitive information during IEP discussions. View "Pitta v. Medeiros" 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

The First Circuit affirmed the decision of the district court granting summary judgment in favor of Appellees - School Administrative Unit 8 and the Concord School District - under Title IX of the Education Amendments of 1972, 20 U.S.C. 1681(a) in this action alleging that Appellees exhibited deliberate indifference in their response to Appellant's allegations of sexual harassment, holding that there was no error.In granting summary judgment for Appellees, the district court found that Appellant could not show that Appellees were deliberately indifferent in their handling of Appellant's complaint. At issue was whether the District's response to Appellant's allegations of sexual harassment constituted deliberate indifference. The First Circuit affirmed the summary judgment for Appellees, holding that genuine issues of material fact did not exist as to deliberate indifference so as to preclude summary judgment. View "M.L. v. Concord School District" on Justia Law

The First Circuit reversed the decision of the district court granting summary judgment for Appellants on their claim brought under Title IX of the Education Amendments of 1972, holding that the district court should not have dismissed the Title IX claim.MG, a minor child, alleged that he was harassed by fellow students while he was attending Brooke Charter School East Boston. Appellants - MG's mother, on behalf of herself, MG, and his four minor siblings - brought suit against the school asserting claims under Title IX, the Equal Protection Clause of the Fourteenth Amendment, and Massachusetts state law. The federal district court granted summary judgment for the school on all claims. The First Circuit reversed the summary judgment on Appellants' Title IX claim and remanded the case, holding that genuine issues of material fact precluded summary judgment on the Title IX claim. View "Grace v. Board of Trustees" on Justia Law

In this action arising out of the curtailment of classes and services at the University of Rhode Island (URI) during the COVID-19 pandemic, the First Circuit affirmed the judgment of the district court dismissing some of Plaintiffs' claims early in the litigation and granting summary judgment in favor of Defendant on the remaining claims, holding that the district court did not err.Plaintiffs, students who remained enrolled at URI during the pandemic, filed separate putative class actions against URI alleging breach of contract and unjust enrichment. Specifically, Plaintiffs argued that URI had breached its contract when it stopped providing in-person, on-campus instruction. The district court dismissed certain claims and then, following the completion of discovery, granted summary judgment on the remaining claims. The First Circuit affirmed, holding that Plaintiffs failed to make out a genuine issue of material fact as to whether URI had either an express or implied contract to provide in-person services and activities. View "Burt v. Bd. of Trustees of University of R.I." on Justia Law

The First Circuit affirmed the order of the district court dismissing Plaintiffs' claims that the closure of in-person education due to the COVID-19 pandemic deprived children of the free appropriate public education to which they were entitled and deprived and parents of their right to participate in their children's education, holding that none of Plaintiffs' claims were cognizable in federal court.Plaintiffs, three children with disabilities and their parents on behalf of a putative class, sued the Governor of Massachusetts, the Commissioner of Schools for Massachusetts, the Massachusetts Department of Elementary and Secondary Education, and several school districts and their superintendents, claiming that the closure of in-person education during the COVID-19 pandemic violated Plaintiffs' rights under the IDEA and that Defendants illegally discriminated against Plaintiffs on the basis of disability in violation the Americans with Disabilities Act and 42 U.S.C. 1983. The district court granted Defendants' motion to dismiss. The First Circuit affirmed, holding that Plaintiffs' claims were properly dismissed in full either because Plaintiffs lacked standing to request the relief they sought, because the claims were moot, and/or because Plaintiffs failed to exhaust administrative remedies. View "Roe v. Healey" on Justia Law

The First Circuit affirmed the rulings of the district court in this civil action brought under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq., holding that none of the parties were entitled to relief on their claims brought on appeal and cross-appeal.Plaintiffs filed an administrative complaint alleging that the Newton Public Schools violated the IDEA by failing to provide their son David with a free appropriate public education, 20 U.S.C. 1412(a)(1). The Massachusetts Bureau of Special Education Appeals rejected the complaint. Thereafter, Plaintiffs brought this complaint. The district court granted judgment for Plaintiffs and ordered Newton to reimburse them for expenses they had incurred in placing their son at a private residential school in Connecticut. Defendants appealed, challenging the court's decision to exclude boarding- and travel-related expenses from the order of reimbursement. The First Circuit affirmed, holding that none of the parties were entitled to relief on their allegations of error. View "Doe v. Newton Public Schools" on Justia Law