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

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

The First Circuit vacated the judgment of the district court denying Plaintiff's motion for leave to proceed under a pseudonym, holding that the district court did not apply the appropriate standard for adjudicating such motions.Plaintiff filed suit against Massachusetts Institute of Technology (MIT) alleging breach of contract, promissory estoppel, and denial of basic fairness related to the investigation of Plaintiff for sexual harassment while he was a student at MIT. In his complaint, Plaintiff challenged the findings of the Committee on Discipline and the ensuing sanction of expulsion. On the same day he filed suit Plaintiff filed an ex parte motion to proceed by pseudonym. The district court denied the motion in a minute order. The First Circuit vacated the order, holding that the district court did not apply the appropriate standard for adjudicating motions for leave to proceed under pseudonyms, requiring remand. View "Doe v. Mass. Institute of Technology" on Justia Law

The First Circuit affirmed the order of the federal district court rejecting a challenge to the ruling by a Maine Department of Education hearing officer that the Falmouth School District violated the Individuals with Disabilities Act (IDEA), holding that the district court's challenged rulings were not in error.The hearing officer in this case concluded that Falmouth was required to reimburse the Does for the cost of their son's tuition at a private school because their son had been denied a free appropriate public education during the time periods in question. Falmouth brought this action under the IDEA, challenging the hearing officer's rulings. The Does answered and brought counterclaims against Falmouth under the Rehabilitation Act and Americans With Disabilities Act. The district court granted judgment to the Does and then dismissed the counterclaims. The First Circuit affirmed, holding that the district court did not err or abuse its discretion in the proceedings below. View "Falmouth School Dep't v. Doe" on Justia Law

The First Circuit dismissed this appeal from the dismissal of a 42 U.S.C. 1983 suit filed by Plaintiffs, two college students, against Defendants, their former universities and university officials, asserting constitutional challenges to the universities' COVID-19 vaccination policies, holding that Plaintiffs' claims are moot.The policies at issue required all students either to be vaccinated or to obtain an exemption to be allowed onto campus. Plaintiffs sought declaratory and injunctive relief seeking exemptions from the policies. The district court denied relief and granted Defendants' motion to dismiss. The First Circuit dismissed Plaintiffs' ensuing appeal, holding that where one student had graduated and the other student was no longer enrolled, Plaintiffs' claims were moot. View "Harris v. University of Massachusetts, Lowell" on Justia Law

The First Circuit affirmed the order of the district court granting summary judgment dismissing Plaintiff's federal claims against Brown University and reversed the grant of summary judgment as to Plaintiff's state law claim for intentional infliction of emotional distress, holding that there were triable issues precluding summary judgment.Jane Doe, a white woman, filed a complaint against Plaintiff, an African-American man who was then a freshman at Brown University, alleging sexual misconduct. After a multi-year process leading to Plaintiff's suspension from school and his suicide attempt. A year before he graduated, Plaintiff brought this action in Rhode Island state court alleging that Brown discriminated against him and intentionally inflicted emotional distress upon him. The district court granted summary judgment for Brown. The First Circuit reversed in part, holding that Plaintiff presented evidence that would allow a jury reasonably to conclude that Brown should be held liable for the tortious conduct of its officials in intentionally causing Plaintiff severe emotional distress under Rhode Island common law. View "Doe v. Brown University" on Justia Law

The First Circuit affirmed in part and reversed in part the judgment of the district court dismissing Plaintiff's complaint against Harvard University for breach of contract and other related claims, holding that the district court erred in dismissing Plaintiff's breach of contract claim.The day before Plaintiff was about to graduate from Harvard three female Harvard students accused him of sexual assault. Following a disciplinary hearing, Harvard withheld Plaintiff's undergraduate degree. Plaintiff sued, and the district court dismissed the complaint for failure to state a claim. The First Circuit reversed in part, holding (1) at the pleadings stage, Plaintiff's allegations, taken as true, stated a plausible breach of contract claim; and (2) the district court properly dismissed the remaining counts of Plaintiff's complaint. View "Sonoiki v. Harvard University" on Justia Law

The First Circuit affirmed the judgment of the court charged with overseeing proceedings under Title III of the Puerto Rico Oversight, Management, and Economic Stability Act confirming a plan of adjustment for the debts of the Commonwealth of Puerto Rico and two of its instrumentalities, holding that there was no error or abuse of discretion.In this case arising out of the effort to restructure the Commonwealth's sovereign debt under Title IIII, various organizations that represented some public school teachers and educators participating in the Commonwealth's pension system objected to the manner in which the plan of adjustment handled their claims to current and future pension payments. The Title III court approved the plan of adjustment over Appellants' objections. The First Circuit affirmed, holding that Appellants' arguments on appeal failed. View "Financial Oversight & Management Board for Puerto Rico v. Federacion de Maestros de Puerto Rico, Inc." on Justia Law

The First Circuit reversed the order of the district court issued under the stay-put provision of the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1415(j), ordering Portland Public Schools to pay for John Doe's placement at a private school during the pendency of these proceedings, holding that the district court erred.During Doe's fourth-grade year, his parents unilaterally placed him at a private school. The Does subsequently filed for a due process hearing alleging that Portland violated the IDEA by previously finding Doe ineligible for special education services. The district court ordered Portland to pay for Doe's tuition for the duration of this litigation at Aucocisco School, where his parents had unilaterally placed him despite the fact that the hearing officer whose decision was being reviewed had determined that the individualized education plan issued by Portland would provide a free appropriate public education. Portland appealed, arguing that the district court impermissibly ordered it to pay for Doe's placement at the private school during the pendency of these proceedings. The First Circuit reversed, holding that the purposes of the IDEA were not served by having Portland continue to pay for Doe's tuition at Aucocisco. View "Doe v. Portland Public Schools" on Justia Law

The First Circuit vacated the order of the district court denying in part Plaintiffs' motion for summary judgment and granting in part Defendants' motion for summary judgment, holding that the case must be dismissed for failure to exhaust administrative remedies.Parents brought this case alleging dissatisfaction with the individualized education plan offered to their son by the Puerto Rico Department of Education. Rather than file an administrative appeal, which was available to them, Parents brought suit in the United States District Court for the District of Puerto Rico. After issuing orders during a period of several years the district court issued an amended opinion and order denying in part Plaintiffs' motion for summary judgment and granting in part Defendants' motion for summary judgment. The First Circuit vacated the district court's judgment and remanded the case with instructions to dismiss, holding that the district court erred in finding that Parents did not need to exhaust their administrative remedies. View "Valentin-Marrero v. Commonwealth of Puerto Rico" on Justia Law