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

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

The First Circuit affirmed the decision of the district court granting judgment to Defendants and denying a declaration requested by Plaintiffs that the Massachusetts Bureau of Special Education Appeals (BSEA) erred in determining that Swampscott Public Schools had provided their daughter, G.D., with a free appropriate public school education as required under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. §§ 1400 et seq., holding that there was no error.Plaintiffs sought a determination from the BSEA that G.D.'s Individualized Education Program (IEP) was not reasonably calculated to provide her with a free appropriate public education (FAPE) and further sought reimbursement from Swampscott Public Schools associated with Plaintiffs' unilateral placement of G.D. at a nearby private school. After the BSEA denied the claims Plaintiffs filed suit against the school district and the BSEA. The district court determined that G.D.'s IEP was reasonably calculated to provide her with a FAPE and entered judgment for Defendants. The First Circuit affirmed, holding that Plaintiffs were not entitled to relief as to any of their allegations of error. View "G.D. v. Swampscott Public Schools" on Justia Law

The First Circuit affirmed the judgment of the district court rejecting the claims of Plaintiffs John Doe and Ben Bloggs that their high school discipline was unconstitutional, holding that the district court properly entered judgment in favor of Hopkinton Public Schools on all counts.Following an investigation, Hopkinton High School determined that eight students on the school hockey team, including Plaintiffs, had bullied their fellow hockey team member, and suspended each hockey player for a number of days. In this appeal from the dismissal of their complaint, Plaintiffs argued that the discipline violated their First Amendment rights, the "emotional harm" prong of Mass. Gen. Laws ch. 71, 370 is unconstitutional, and that the punishment violated their student speech rights under Mass. Gen. Laws ch. 71, 82. The First Circuit affirmed the dismissal of the complaint, holding (1) the school did not violate Plaintiffs' First Amendment rights; (2) Plaintiffs' challenges to the "emotional harm" prong of the Massachusetts statute and school policy were moot; and (3) the school did not violate Plaintiffs' rights under the Massachusetts student speech statute. View "Doe v. Hopkinton Public Schools" on Justia Law

The First Circuit affirmed the judgment of the district court approving an amended settlement agreement in this landmark Title IX case brought by a group of women student-athletes against Brown University claiming gender discrimination with respect to the funding and operation of a variety of varsity athletic programs, holding that there was no error.After a bench trial, the district court found that Brown had violated Title IX. After the First Circuit remanded the case for further proceedings, the parties consummated a settlement, which remained in effect for more than two decades. In 2020, Brown unilaterally decided to eliminate certain varsity sports and to upgrade sailing to varsity status, open to men and women. The parties then revisited the matters embodied in the court-approved settlement and jointly moved for approval of a revised settlement. The district court approved the amended settlement agreement. The First Circuit affirmed, holding that the district court properly concluded that the amended settlement agreement was fair and adequate. View "Cohen v. Walsh" on Justia Law

The First Circuit denied Plaintiff's motion for an injunction preventing the implementation of a plan promulgated by the Boston Public Schools for admitting students to Boston Latin School, Boston Latin Academy, and John D. O'Bryant School of Mathematics and Science for the 2021-2022 school year, holding that Plaintiff did not show it was not entitled to the injunction.Plaintiff, a corporation acting on behalf of fourteen parents and children residing in Boston, asserted that the 2021-2022 admissions plan violated the Equal Protection Clause of the Fourteenth Amendment and Mass. Gen. Laws ch. 76, 5. The district court entered judgment in Defendants' favor. Plaintiff appealed and moved for an order under Fed. R. Civ. P. 62(d) enjoining Defendants from implementing the plan during the pendency of this appeal. The First Circuit denied the motion, holding that Plaintiff failed to show a strong likelihood that it would prevail on the merits. View "Boston Parent Coalition for Academic Excellence Corp. v. School Committee of City of Boston" on Justia Law

The First Circuit held that Students for Fair Admissions, Inc. (SFFA) had associational standing to bring its claims against the President and Fellows of Harvard College and the Board of Overseers (collectively, Harvard) and that Harvard's race-conscious undergraduate admissions program does not violate Title VI of the Civil Rights Act of 1964, 42 U.S.C. 2000d et seq.In its suit, SFFA alleged that Harvard's race-conscious admissions processed violated Title VI by discriminating against Asian American applicants in favor of white applicants. SFFA sought a declaratory judgment, injunctive relief, attorneys' fees and costs. The district court denied Harvard's motion to dismiss for lack of standing and then found that Harvard had met its burden of showing its admissions process did not violate Title VI. The First Circuit affirmed, holding (1) SFFA had associational standing to bring its claims; and (2) under governing Supreme Court law, Harvard's admissions program does not violate Title VI. View "Students for Fair Admissions v. President & Fellows of Harvard College" on Justia Law

The First Circuit affirmed the judgment of the district court granting judgment to the Commissioner of the Maine Department of Education in this federal constitutional challenge to the requirement of Maine's tuition assistance program that a private school must be "a nonsectarian school in accordance with the First Amendment" to qualify as "approved" to receive tuition assistance payments, holding that the program's condition violated neither the Free Exercise Clause nor the Establishment Clause.To ensure that Maine's school administrative units (SAUs) make the benefits of a free public education available Maine provides by statute that SAUs that do not operate a public secondary school of their own may either contract with a secondary school for school privileges or pay the tuition at the public school or an approved private school at which the student from their SAU is accepted. Plaintiffs brought this suit against the Commissioner, arguing that the program's requirement that a private school be a nonsectarian school to receive tuition assistance payments infringed various of their federal constitutional rights. The district court granted judgment to the Commissioner. Having twice before rejected similar federal constitutional challenges to the "nonsectarian" requirement and even accounting for fresh United States Supreme Court precedent the First Circuit affirmed, holding that Plaintiffs' constitutional challenges failed. View "Carson v. Makin" on Justia Law

The First Circuit vacated the district court's dismissal of Plaintiff's claim for a violation of Title IX, 20 U.S.C. 1961 et seq., and affirmed the district court's dismissal of the other claims, holding that Plaintiff's allegations told a plausible story of deliberate indifference by school officials to repeated and severe sexual harassment.Plaintiff alleged that she was the victim of several incidents of sexual assault and harassment while she was a student at the Pawtucket Learning Academy in Rhode Island. Plaintiff sued twenty-one defendants under sixteen different counts. The district court dismissed the entire action. The First Circuit vacated the judgment in part, holding that based on the facts set forth in Plaintiff's complaint it was plausible that a fact-finder could find that the conduct of school officials caused Plaintiff's harassment in some way or made Plaintiff liable or vulnerable to harassment. View "Doe v. Pawtucket School Department" on Justia Law

The First Circuit reversed the judgment of the district court granting a preliminary injunction prohibiting the Trustees of Boston College (BC) from imposing a suspension of one year on John Doe, a student, who was found to have engaged in the sexual assault of a female student, holding that the district court erred in finding a probability of success as to Doe's claim under Massachusetts contract law.The suspension decision in this case was the outcome of a disciplinary complaint filed against Doe, and the suspension decision was the outcome of the procedures set forth in BC's student sexual misconduct policy. In issuing the preliminary injunction the district court found Doe had shown a probability of success on the merits of the state law claim of violation of a contractual obligation of basic fairness. The First Circuit vacated the injunction, holding (1) to the extent the district court was attempting to base its ruling on a prediction of future developments in Massachusetts contract law, the court erred; and (2) where current Massachusetts law does not require the college discipline process Doe argues must be a part of a contractual obligation of basic fairness the court erred in granting the injunction. View "Doe v. Trustees of Boston College" on Justia Law