Articles Posted in Education Law

by
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

by
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

by
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

by
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

by
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

by
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

by
Plaintiffs, students or parents of students who attended Iowa public schools, filed a petition contending that Iowa's educational system was inadequate and urging the courts to impose additional public school standards, stating that such action was both constitutionally and statutorily required. Plaintiffs named as defendants the State, Governor, Department of Education, and Director of the Department. The district court dismissed Plaintiffs' petition, concluding (1) Plaintiffs had stated claims for relief under the equal protection and due process clauses, but their constitutional claims presented a nonjusticiable political question; and (2) their statutory claim under Iowa Code 256.37 failed because that provision did not afford a private right of action. The Supreme Court affirmed, holding (1) Plaintiffs' challenges were properly directed to Plaintiffs' elected representatives, rather than the courts; but (2) Plaintiffs did not state claims for relief under the Iowa Constitution or section 256.37. View "King v. State" on Justia Law

by
Hawkeye Foodservice Distribution filed a petition for declaratory and injunctive relief against the Iowa Educators Corporation (IEC) and ten Area Education Agencies (AEAs) comprising IEC, seeking (1) a declaration that the operation of IEC was in violation of Iowa Code 273 and 28E; (2) equitable relief enjoining the AEAs and IEC from further operation in violation of Iowa law; and (3) injunctive and declaratory relief on the ground that the AEAs and IEC operate in violation of Iowa Code 23A. The district court granted Defendants' motion to dismiss, concluding (1) Hawkeye lacked standing to bring the chapter 273 and 28E claims; and (2) Hawkeye failed to allege sufficient facts demonstrating it was entitled to relief under chapter 23A. The court of appeals reversed. The Supreme Court vacated the court of appeals and reversed the district court, holding that the district court erred in (1) dismissing Hawkeye's chapter 273 and 28E claims for lack of standing, as Hawkeye's petition alleged facts that gave it standing to challenge the actions of the AEAs and IEC; and (2) dismissing the action, as the factual allegations set forth in the petition, if proved, stated statutory claims sufficient to defeat a motion to dismiss. View "Hawkeye Foodservice Distrib., Inc. v. Iowa Educators Corp." on Justia Law