Justia Iowa Supreme Court Opinion Summaries

Articles Posted in Education Law
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The Supreme Court affirmed the decision of the district court affirming the declaratory order of the Iowa Department of Education interpreting a number of statutes and answering five questions posed by the Keystone Area Education Agency, holding that there was no error or abuse its discretion.The questions at issue concerned whether public agencies are required to release or excuse students to receive behavioral analysis therapy (ABA therapy) and, if so, under what circumstances. The Department's declaratory order determined, among other things, that the decision whether to excuse an absence for ABA therapy is generally up to the school district and that a public agency that does excuse attendance for therapy may violate federal law under some circumstances. The district court affirmed. The Supreme Court affirmed, holding (1) the Department had the authority to issue the declaratory order; and (2) the Department's declaratory order was supported by substantial evidence. View "Hills & Dales Child Development Center v. Iowa Department of Education" on Justia Law

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The Supreme Court affirmed the judgment of the district court declining to modify a restriction on alienability of paintings painted by artist Grant Wood and donated in 1976 to Coe College in Cedar Rapids, holding that the 1976 gift was restricted.A foundation donated the paintings to the college, and the gift letter stated that "this would be their permanent home, hanging on the walls of Stewart Memorial Library." While the college traditionally treated the paintings on its books as an unrestricted gift that could be sold or otherwise alienated, in 2016, an auditor determined the paintings should be treated as a restricted gift. The college subsequently filed a petition seeking a judicial interpretation of the gift's terms. The district court ruled that there existed a restriction on the alienability of the paintings and declined to modify the restriction. The Supreme Court affirmed, holding (1) the language in the gift letter did restrict the gift; (2) the Uniform Prudent Management of Institutional Funds Act does not apply; and (3) it was premature to consider the application of the common law doctrine of cy pres because there was no showing the gift restrictions cannot be carried out at present. View "In re Application of Coe College for Interpretation of Purported Gift Restrictions v. Coe College" on Justia Law

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The Supreme Court affirmed in part and reversed in part the order of the district court entering an injunction directing Defendants to place on the ballot a measure asking voters whether they approved the demolition of Hoover Elementary School and the use of the proceeds for school district purposes, holding that the district court erred in granting Plaintiffs injunctive relief.The Iowa City Community School District refused to authorize the placement of the ballot issue at an election after a petition bearing more than 2000 signatures had been timely filed with the Board. When the Board refused to direct the county auditor to place the matter on the ballot for the upcoming election, Plaintiffs sought injunctive relief and damages against the school district court individual board members. The district court entered an injunction and directed the district court to place the matter on the next general election ballot. The district court then granted Defendants summary judgment on Plaintiffs' claims for damages. The Supreme Court reversed in part, holding that Defendants were entitled to summary judgment on all claims because the school district was under no legal obligation to require the county auditor to place the matter on the ballot. View "Young v. Iowa City Community School District" on Justia Law

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The Supreme Court affirmed the evidentiary ruling of the district court and grant of summary judgment in favor of Medical School on Student's complaint that Medical School failed to accommodate her mental disability under the Iowa Civil Rights Act, Iowa Code chapter 216, holding that the district court properly declined to impute a staff psychotherapist's knowledge of Student's depression to Medical School's academic decision-makers and that the failure-to-accommodate claim failed as a matter of law.Student was treated for depression by the psychotherapist during the school year but did not consent to allow the psychotherpiast to discuss her depression with the faculty. Medical School eventually expelled Student based on her failing grades and lack of academic promise. In this complaint, Student filed an evidentiary motion to impute her psychotherapist's knowledge of her depression to the school's academic decision-makers. The district court denied the motion after applying statutory confidentiality requirements for mental health information. The court then granted Medical School summary judgment on Student's failure-to-accommodate claim. The Supreme Court affirmed, holding (1) the district court correctly ruled that confidential information the psychotherapist learned while treating Student was not imputed to Medical School; and (2) Medical School adequately engaged in the interactive process. View "Slaughter v. Des Moines University College of Osteopathic Medicine" on Justia Law

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This case involved three small school districts, Northeast Community School District, East Central Community School District, and Preston Community School District. In 2010, the school boards of Northeast and East Central entered into a whole grade sharing agreement. Thereafter, citizens from Preston and East Central voted to reorganize their districts and merge the districts together into a new school district called Easton Valley Community School District (Easton). The Easton school board subsequently sent a notification of cancellation of the agreement to the superintendent of Northeast, claiming that when East Central ceased to exist the agreement was null. Northeast filed a petition for declaratory action and mandamus and then amended its petition alleging repudiation of the agreement. The district court granted summary judgment for Easton, concluding (1) the agreement and the reorganization were valid but that the two were in direct conflict, and (2) the East Central school board did not have the ability to bind Easton as its successor corporation. The Supreme Court reversed, holding that the agreement could bind the reorganized school district. View "Northeast Cmty. Sch. Dist. v. Easton Valley Cmty. Sch. Dist." on Justia Law

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Aaron Cannon, a student at Palmer College of Chiropractic, was blind and requested that Palmer make accommodations for his visual disability. Palmer denied the request, explaining that it could not provide the proposed accommodations and curricular modifications because they would fundamentally alter its educational program. Cannon eventually withdrew from the program. Cannon filed a complaint with the Davenport Civil Rights Commission, arguing that Palmer had discriminated against him on the basis of his disability. The Commission granted relief, finding that Palmer had failed to comply with the applicable federal and state disability laws. The district court reversed. The Supreme Court reversed, holding that the Commission did not erroneously interpret or irrationally apply the applicable law in concluding that Palmer failed to establish that Cannon’s suggested accommodations would fundamentally alter its curriculum. View "Palmer College of Chiropractic v. Davenport Civil Rights Comm’n" on Justia Law

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Petitioner was a middle school teacher involved in a physical altercation with a student. The Iowa Board of Educational Examiners issued a statement of charges against Petitioner alleging student abuse. The Board subsequently imposed a ninety-day suspension of Petitioner's teaching license and permanent revocation of his physical education and coaching endorsements. Petitioner filed a petition for judicial review in district court within thirty days of the Board's denial of his application for rehearing but before the Board's final decision on the State's application for rehearing. The district court ultimately affirmed the Board's decision on the merits. The court of appeals reversed, holding that Petitioner's "premature" petition never invoked the district court's jurisdiction. The Supreme Court vacated the decision of the court of appeals and affirmed the judgment of the district court, holding (1) the proper time to file a petition for judicial review is within thirty days after the agency's final decision on the last application granted for rehearing; and (2) Petitioner initially appealed prematurely before the Board's final decision on the State's rehearing application, but he later perfected his appeal to the district court. View "Christiansen v. Iowa Bd. of Educ. Examiners" on Justia Law

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The American Civil Liberties Union of Iowa Foundation submitted an open records request to the Atlantic Community School District records custodian requesting information pursuant to Iowa's Open Records Act concerning the discipline of two school district employees after the school district disciplined them for performing a strip search of five students. The district court entered summary judgment in favor of the school district. The Supreme Court affirmed, holding that the district court did not err in finding that the disciplinary information sought was exempt from disclosure under Iowa Code 22.7(11), which exempts from disclosure "personal information in confidential personnel records of public bodies including...cities, boards of supervisors, and school districts." View "ACLU of Iowa vs. Atlantic Cmty. Sch. Dist." on Justia Law

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In 2007, two University of Iowa football players were accused of sexually assaulting another student in a campus dorm room. The incident led to criminal charges, internal actions by the University, an external criticism of the University. The incident also led to the present lawsuit, which concerned Open Records Act requests that the Iowa City Press-Citizen served on the University. Dissatisfied with the University's initial response to those requests, the Press-Citizen filed suit. The lawsuit resulted in more documents being produced and others being submitted for in camera review by the district court. The court then ordered additional documents produced, in some instances with redactions. The University appealed that order in part. The Supreme Court reversed the district court's judgment in part, holding that the Federal Educational Rights and Privacy Act prohibited the disclosure of the remaining documents, including even redacted versions of "education records" where the identity of the student was known to the recipient. View "Press-Citizen Co. v. Univ. of Iowa" on Justia Law

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In this case the Supreme Court considered whether an area education agency (AEA) acted lawfully when it approved for submission to the voters a petition that proposed a consolidation of two community school districts, Preston and East Central. East Central sought to block the measure from being placed before the voters, asserting (1) the AEA approval of the petition for submission to the voters was legally flawed because the AEA failed to comply with a statutory requirement that it develop a plan for the AEA district, and (2) the AEA failed to make a required statutory finding that the consolidation proposed in the petition was in conformity with the plan. The district court rejected the claims. The Supreme Court affirmed, concluding that the AEA acted lawfully in approving submission of the petition to the voters, as (1) the AEA was not required to develop a specific plan of merger between the two school districts prior to approval of submission of a citizen petition to the voters of the districts; and (2) by approving the submission of the issue to the voters, the AEA made an implied finding that all the statutory requisites were met. View "E. Central Cmty. Sch. Dist. v. Miss. Bend Area Educ. Agency" on Justia Law