Justia U.S. 11th Circuit Court of Appeals Opinion Summaries

Plaintiff filed suit against defendants alleging that her teenage daughter - who suffers from severe emotional, mental, and physical disabilities - was sexually assaulted by another student while in defendant's care. The district court concluded that plaintiff's amended complaint failed to state a plausible claim for relief and dismissed with prejudice. On appeal, defendant challenged the district court's denial of her motions for partial reconsideration and for leave to amend. Because plaintiff failed to demonstrate "extraordinary circumstances" warranting the reopening of the final judgment, the district court did not abuse its discretion in denying her motion for partial reconsideration. Further, the district court did not abuse its discretion in denying plaintiff's motion for leave to amend her complaint. The court affirmed the judgment of the district court. View "M. G. v. St. Lucie Cty. Sch. Bd., et al." on Justia Law

This appeal primarily concerns a Fourteenth Amendment challenge to various sections of the Alabama Constitution that are central to the State's system of ad valorem property taxation. Plaintiffs filed suit asserting that these provisions are rooted in the State's historic racially discriminatory policies and cripple the ability of certain rural, nearly all-black public school systems in Alabama to raise revenues. Because the requested remedy would not address the alleged injury, plaintiffs lacked standing to challenge the constitutional millage cap provisions despite the district court's finding that they were enacted with discriminatory intent; plaintiffs' challenges to these provision were therefore dismissed without prejudice; plaintiffs' challenge to the State's property classification system (as set forth in Amendments 325 and 373 to Section 217) were not similarly barred, yet these claims failed because the court could not say that the district court clearly erred in finding that this system was not the product of invidious discriminatory intent; sufficient evidence also rendered permissible the district court's finding that these Amendments were financially, and not discriminatorily, motivated; under clear-error review, the court was not free to second-guess the district court's choice between two permissible views of the evidence; and, therefore, the court affirmed in part, vacated in part, and remanded with instructions to dismiss in part. View "Lynch, et al. v. State of Alabama, et al." on Justia Law

Plaintiffs, on behalf of their daughter, filed suit challenging the district's implementation of a new individualized education program (IEP) for their daughter under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq. Determining that the daughter's case was not moot, the court concluded that the court need not decide whether the various notice requirements were satisfied because whatever notice deficiencies there could have been in this case, they did not warrant relief; there was no error in requiring the parents to present a complaint and demand a due process hearing because they disagreed with the IEP team's decision; the district court correctly stated the Loren F. ex. rel. Fisher v. Atlanta Independent School System standard, fully reviewed the administrative record, and independently analyzed each of the parents' claims; the district court did not abuse its discretion when it issued the parents' proposed order and then decided the case on summary judgment; and the court held that 42 U.S.C. 1983 actions for denial of rights conferred by the IDEA were barred because the IDEA's comprehensive enforcement scheme provided the sole remedy for statutory violations and, therefore, the district court did not err in dismissing the parents' section 1983 claims. Accordingly, the court affirmed the judgment of the district court. View "K.A. v. Fulton County Sch. Dist." on Justia Law

Florida VirtualSchool, a Florida state agency, appealed the district court's dismissal of its trademark infringement suit against K12 for lack of standing. At issue on appeal was whether Florida VirtualSchool was authorized under Florida law to assert such claims, or whether that authority lies exclusively with Florida's Department of State. The court found that the relevant Florida law was ambiguous on the issue and certified the question to the Florida Supreme Court. View "Florida VirtualSchool v. K12, Inc., et al." on Justia Law

The Board challenged the district court's determination affirming the validity of a Department of Education regulation that required state and local agencies to reimburse parents and guardians for an independent educational evaluation (IEE) of their children with disabilities. The court held that the Secretary of Education did not exceed its authority in promulgating 34 C.F.R. 300.502, providing parents the right to a publicly financed IEE and therefore, the district court did not err in requiring the Board to reimburse plaintiffs for the IEE that they obtained for their child. View "Phillip C., et al v. Jefferson County Board of Education" on Justia Law

Plaintiff, a teacher at a small Christian school, appealed the district court's grant of summary judgment in favor of the school on her pregnancy discrimination claim, under Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., contending that she had established a prima facie case of unlawful discrimination. After admitting to the school's administrator and assistant administrator that she conceived the child before getting married, the school fired her, purportedly because she had sinned by engaging in premarital sex, and, as the administrator put it, "there are consequences for disobeying the word of God." Because the school did not raise any issue or make any argument in its brief about the ministerial exception, the court would not decide whether that exception might apply. The court found that plaintiff's testimony contradicted the administrator's testimony that he had never heard her say she was sorry for what she had done and that he would not have fired her if she had. For that and other reasons, plaintiff had established a genuine issue of material fact about the reason that the school fired her. Accordingly, the court reversed the grant of summary judgment on the pregnancy discrimination claim and remanded for further proceedings. View "Hamilton v. Southern Christian School, Inc" on Justia Law

Plaintiffs appealed the district court's grant of Troup's motion for summary judgment as to plaintiffs' sexual harassment claim brought pursuant to Title IX, 20 U.S.C. 1681. The facts of this case stemmed from circumstances surrounding the sexual molestation of a 12-year-old boy by his 45-year-old seventh grade homeroom teacher. The court held that the district court combined Title VII, 42 U.S.C. 2000e et seq., workplace discrimination standards with Title IX teacher-on-student harassment standards when it articulated plaintiff's burden. However, the district court's reliance on the wrong standard did not necessarily mandate that the court must now reverse its decision and remand the case. After considering the factual record and drawing all justifiable inferences in favor of plaintiffs, the court found that the information of which the school principal had knowledge was not enough to create a genuine issue of material fact as to whether he had actual notice sufficient to alert him to the possibility of sexual harassment of the 12-year-old by his teacher. Accordingly, although for different reasons than the district court, the court granted summary judgment. View "J.F.K., et al. v. Troup County Sch. Dist., et al." on Justia Law

Plaintiff sued the President of Valdosta State University, claiming that under the Due Process Clause, he was due notice of the charges, and a hearing to answer them, prior to his removal from campus. Plaintiff, a student, was removed on the ground that he presented a "clear and present danger" to the campus. Plaintiff joined the Board of Regents of the University System of Georgia as a defendant, claiming against the Board a state-law breach of contract claim for damages. Plaintiff claimed that the student handbook and contracts for student housing established binding agreements between the Board and the university students and the Board breached these agreements by failing to afford plaintiff the due process prior to his removal from campus. The court held that the district court properly denied the President's motion for summary judgment based on qualified immunity where plaintiff had a constitutional right to process before he was removed from the university and plaintiff's constitutional rights were clearly established. The court held, however, that the district court erred in failing to dismiss plaintiff's breach of contract claim against the Board as barred by the Eleventh Amendment where Georgia had not waived its Eleventh Amendment immunity for breach of contract actions. View "Barnes v. Zaccari, et al." on Justia Law

Appellants are the parents of G.J., a child with autism and brain injuries. At issue was whether the ALJ and the district court properly evaluated appellants' claims that the MCSD did not comply with certain provisions of the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq., with respect to services it was to provide to G.J. The court held that the district court did not err in setting forth reasonable conditions for G.J.'s reevaluation and in determining that appellants were not entitled to either a private or publicly funded independent educational evaluation. The court also held that there was no basis for making a determination that any procedural failures with regard to the August 2008 and 2009 IEP meetings impacted the education received by G.J. to any substantive degree. Accordingly, the judgment was affirmed. View "G. J., et al. v. Muscogee Co. Sch. Dist." on Justia Law

Plaintiff, a teacher, filed this action against defendants, a superintendent and principal, pursuant to 42 U.S.C. 1983 claiming that he was terminated in retaliation for exercising his First Amendment rights. At issue was whether defendants were entitled to qualified immunity and whether plaintiff's First Amendment retaliation claims were barred by res judicata. The court held that plaintiff failed to present any precedent, and the court was aware of none, to suggest that a reasonable principal and superintendent armed with the knowledge they possessed, to include the unsatisfactory performance reviews, would know they could not recommend and/or adopt a recommendation to terminate plaintiff. Accordingly, defendants were entitled to qualified immunity and the court need not address the res judicata issue. View "Sherrod v. Johnson; Sherrod v. Crutchfield" on Justia Law