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

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

In this action brought by parents of a severely disabled student against the school district alleging federal and statement claims the First Circuit vacated the district court's entry of judgment for the school district on Plaintiffs' federal claims on the basis that they were subject to the exhaustion requirement set forth in the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400-1491o, holding that no further administrative pursuit was required for the claims.Plaintiffs' federal claims claims included a Rehabilitation Act claim and a substantive due process claim under 42 U.S.C. 1983. The district court granted the school district's motion for judgment on the pleadings as to Plaintiffs' federal claims and remanded the state law claims to state court, concluding that the federal claims were subject to the IDEA's exhaustion requirement. The First Circuit vacated that decision, holding (1) the gravamen of Plaintiffs' Rehabilitation Act claim did not involve the denial of a free appropriate public education, and therefore, that claim was not subject to the exhaustion requirement of the IDEA; and (2) Plaintiffs' section 1983 claim was either exhausted or continued engagement with the IDEA's administrative scheme would have been futile. View "Doucette v. Georgetown Public Schools" on Justia Law

The First Circuit affirmed the judgment of the district court denying class certification in this suit alleging violations of Title II of the Americans with Disabilities Act (ADA), 42 U.S.C. 12131-12134, and the court's grant of judgment on the pleadings as to Parent/Professional Advocacy League (PPAL) and Disability Law Center (DLC), holding that PPAL and DLC lacked standing to pursue the claims in the complaint.S.S., a student at the Springfield Public Day School (SPDS), brought this suit on his own behalf and on behalf of a class of all student with a mental health disability who were or had been enrolled at SPDS, alleging that the City of Springfield, Massachusetts, and Springfield Public Schools violated Title II by segregating students with mental health disabilities in SPDS, a separate and inferior school. Associations PPAL and DLC joined S.S. as plaintiffs. The district court denied class certification. The court then ruled that the associations had standing but dismissed their claims for failure to exhaust. The First Circuit held (1) class certification was correctly denied; and (2) the associations lacked standing to bring this suit. View "Parent/Professional Advocacy League v. City of Springfield" on Justia Law

The First Circuit affirmed the district court's dismissal of Plaintiff's complaint in part and otherwise vacated the judgment, holding that the University of Massachusetts at Amherst violated Plaintiff's federal constitutional right to due process in suspending him for five months without prior notice or a fair hearing but did not violate his rights in expelling him after providing a fair expulsion hearing.After the university suspended and then expelled Plaintiff, Plaintiff brought this action seeking compensatory damages, declaratory relief, and an injunction preventing the university from enforcing the expulsion. The district court entered summary judgment in favor of Defendants. The First Circuit (1) affirmed the district court's dismissal of Plaintiff's 42 U.S.C. 1983 claims challenging the adequacy of his expulsion hearing, Plaintiff's section 1983 claims for money damages against the university officials acting in their official capacities, and Plaintiff's Title IX claim; but (2) vacated for the entry of nominal monetary damages the dismissal of Plaintiff's section 1983 claims challenging the constitutionality of the manner in which the university suspended Plaintiff without prior notice or an adequate hearing. The Court then remanded the case for further proceedings. View "Haidak v. University of Massachusetts-Amherst" on Justia Law

The First Circuit affirmed the judgment of the district court in favor of the Fay School, Inc. and Fay's Head of School as to Appellants' complaint alleging unlawful retaliation for demands for an accommodation for a certain condition of G., a twelve-year-old minor, holding that the district court correctly denied Appellants' claims.G., a former student of the Fay School, and her parents (collectively, Appellants) brought this suit against Fay after the school refused to remove wireless internet from its classrooms to accommodate G.'s alleged electromagnetic hypersensitivity (EHS), a sensitivity to electromagnetic fields. Appellants alleged, among other claims, unlawful retaliation for an accommodation for G.'s condition, in violation of Title V of the Americans with Disabilities Act, 49 U.S.C. 12203(a), breach of contract, and misrepresentation. The First Circuit affirmed, holding (1) damages are not an available remedy for a Title V retaliation claim premised upon an exercise of rights under Title III of the ADA; and (2) Appellants failed to raise triable issues of fact as to their contract and misrepresentation claims. View "G. v. Fay School" on Justia Law

The First Circuit affirmed the judgment of the district court upholding a decision of the Massachusetts Bureau of Special Education Appeals (BSEA) ruling that the Natick Public School District had complied with the "free appropriate public education" (FAPE), "least restrictive environment" (LRE), and transition requirements in proposed individualized education programs (IEP) for C.D., holding that the district court did not err.Under the Individuals with Disabilities Education Act (IDEA) and Massachusetts law, the IEPs of certain disabled students must contain, in addition with FAPE and LRE requirements, postsecondary transition goals and services based on age-appropriate assessments. Appellants were C.D., who qualified as a child with a disability under the IDEA, and her parents. Appellants filed a complaint with the BSEA seeking reimbursement for C.D.'s tuition at a specialized private school. The BSEA denied Appellants' request. The district court affirmed. The First Circuit affirmed, holding that the district court (1) applied the correct legal standards; (2) properly ruled that the IEPs did not violate the LRE mandate; and (3) did not err in affirming the BSEA's ruling that the IEPs complied with the statute's transition provision. View "C.D. v. Natick Public School District" on Justia Law

In these appeals arising from a complaint filed by Ms. S. with the Maine Department of Education alleging violations of the Individuals with Disabilities Education Act, 20 U.S.C. 1400 et seq., the First Circuit remanded with instructions to dismiss Ms. S.’s action with prejudice, holding that Ms. S.’s claims about her son’s education in school years 2009-2010 and 2010-2011 were time barred.The state due process hearing officer dismissed as untimely Ms. S.’s claims about 2009-2010 and 2010-2011 and found no violations as to school years 2011-2012 and 2012-2013. In the First Circuit’s second decision it held (1) the district court erred in ruling that an earlier decision by the First Circuit foreclosed the interpretation of Maine’s Unified Special Education Regulation (MUSER) that Maine has established a two-year statute of limitations for due process complaints and has done so to align its statute of limitations with the IDEA’s; and (2) Ms. S.’s proposed construction of MUSER, her waiver argument, and her argument that the Regional School Unit 72 misled her were all without merit. View "Ms. S. v. Regional School Unit 72" on Justia Law