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SCHOOL LAW UPDATE! A brief overview of what was hot, and what was not in 2008 – and a peek at where we may be heading… Elizabeth Eynon-Kokrda [email protected] BAIRD HOLM, LLP Supreme Court 2007-2008 The 2007-2008 U.S. Supreme Court term: intriguing and unusual For the first time in over 65 years, the Supreme Court expounded on the 2nd Amendment (gun rights) and on the contemporary relevance of the exhaustion doctrine in patent law. The Court also addressed issues that resulted in unusual justice alignments, leaving commentators wondering whether the notion that a strictly ideological, conservative Court following the Roberts and Alito appointments was accurate Boumediene v. Bush, the Guantanamo detainee case Kennedy v. Louisiana, the execution for child rape case Both thought to be liberal opinions In 2007-2008, the Court witnessed considerably fewer 5-4 splits than the year prior - as only 17% of cases ended in this manner. Surprisingly, unanimity also decreased. Nine-to-zero decisions dropped from 25% last term to 18% this term, though the number of dissenting votes per decision stayed nearly steady. Supreme Court: possible cases Borden v. School Dist. of Twp. of East Brunswick, N.J student initiated religious acts - faculty's silent gestures in support Safford U.S.D. #1 v. Redding strip search of student - qualified immunity Roberts v. Center for Bioethical Reform freedom of speech - graphic display of aborted fetuses outside school Forest Grove Sch. Dist. v. T.A. IDEA - tuition reimbursement for parents who unilaterally place child in private school Horne v. Flores adequacy of state funding on English language learner programs – state’s compliance with Equal Educational Opportunity Act Curry v. Hensinger student speech - cards with religious message affixed to goods "sold" in school-sponsored marketing exercise Lowery v. Euverard dismissal of high school student from athletic team in retaliation for criticism of coach Wilcox v. United States ex rel. Stoner False Claims Act - qui tam suit against state officials - 11th Amendment Fitzgerald v. Barnstable Sch. Comm. sex discrimination - exclusivity of Title IX's implied private right of action Oral Argument 12/2/08 Ysura v. Pocatello Educ. Ass'n payroll deductions for political activities - state ban Argued 11/3/08 Novato U.S.D. v. Smith student speech - fighting words What’s Pending… Pleasant Grove City v. Summum, Religious Monuments: Be Careful What you Ask For…. Summum (established 1975) want the "Seven Aphorisms of Summum" in a public park that already is home to a Ten Commandments display. The Summum argued, and a federal appeals court agreed, that Pleasant Grove can't allow some private donations in its public park and reject others. The worry: a ruling for the Summum would allow almost anyone to erect a monument in a public park, or lead to the removal of war memorials and other longstanding displays. The Justice Department’s position: governments act almost as museum curators when they decide to place some monuments in public parks and not others. What’s Pending… Crawford v. Metropolitan Government of Nashville and Davidson County Title VII retaliation protections – Do they apply to people who haven’t themselves complained about workplace discrimination? Vicky Crawford was fired in 2003 after more than 30 years as school district employee. She did not file a complaint about harassment. But she said she had been subject to unwanted sexual advances when she was interviewed by investigators for the school district who were looking into other employees' allegations against the director of employee relations. Crawford v. Metropolitan Government of Nashville and Davidson County involved a former employee’s claim of retaliatory termination because of her passive cooperation in an internal sexual harassment investigation. The only doubt at the end of arguments was how broadly the Court would rule for the employee. The Bush administration is supporting Ms. Crawford. Lisa Blatt, a Justice Department lawyer, warned the Court about the consequences of a ruling against Crawford. “Witnesses simply are going to be afraid to fully cooperate if they're not given protection,” said Ms. Blatt. However, Justice Antonin Scalia warned that a broad ruling for Crawford would frustrate employers' efforts to get rid of unproductive workers.”Any employee smart enough to come in and testify has a guaranteed job,” he said. “It's about like being a federal judge.” The Eighth Circuit SAGE v. Osseo Area Sch. - Dist. No. 279, No. 07-3576 (8th Cir. Aug. 29, 2008) The U.S. Court of Appeals for the Eighth Circuit (AR, IA, MN, MO, ND, NE, SD) upheld a Minnesota federal district court’s order affording a gay student club the same access provided to other noncurricular high school clubs. The Eighth Circuit agreed with the lower court that some student groups designated by the school as “curricular” actually were noncurricular under the federal Equal Access Act (EAA) but, in violation of that act, were given greater access than was given Straights and Gays for Equality (SAGE). Under Osseo Area Schools – District No. 279’s policy, student groups are classified as either curricular or noncurricular. Unlike curricular groups, noncurricular groups may meet only before and after school, may only use a community bulletin board or place a poster outside their meeting place, do not receive school funds, and cannot engage in fundraising or field trips. SAGE, cont. The Eighth Circuit stated that the issue was whether the district court had correctly determined that the student groups that received more favorable access than SAGE also were noncurricular, thus triggering the EEA. While conceding that the EAA does not define “noncurriculum-related,” the appeals court noted the U.S. Supreme Court interpretation as “any student group that does not directly relate to the body of courses offered by the school” and agreed with the lower court that the school’s Spirit Council had been mislabeled curriculum-related when it actually is noncurriculumrelated. Although under Board of Education of the Westside Community Schools v. Mergens, 496 U.S. 226 (1990), “student government may well be curriculum related,” the Eighth Circuit found it does not follow that every student group labeled as a subgroup of student government automatically is curriculum-related. This would allow for easy circumvention of the EAA, the court warned, by identifying favored groups as subgroups of student government. Mergens carefully limited the designation of a school’s student government as curriculum-related “to the extent that [the group] addresses concerns, solicits opinions, and formulates proposals pertaining to the body of courses offered by the school.” Here, by contrast, the Spirit Council’s function was social activity planning. The Eighth Circuit Lowry v. Watson Chapel Sch. Dist., Nos. 07-3437/08-1139 (8th Cir. Sept. 2, 2008) An Arkansas school district violated students’ First Amendment free speech rights by banning their wearing of arm bands at school in protest of the district’s dress code. The ruling also affirmed the lower court’s issuance of a permanent injunction prohibiting school officials from disciplining students for wearing the arm bands and the award of $37,500 in attorneys’ fees, even though the plaintiffs had only recovered nominal damages. On Oct. 6, 2006, 31 Watson Chapel School District (WCSD) junior high and high school students wore the armbands to protest a dress code requiring them to wear khaki pants with belt loops and a white polo-style shirt with two or three buttons. At least 24 of the students were punished. Three of them, with their parents, filed suit in federal district court, alleging that school district officials had violated their First Amendment rights. Prior to trial, WCSD acknowledged that: (1) the discipline was imposed because the armbands signified disagreement with the dress code; and (2) the wearing of the armbands caused no material disruption or substantial interference with school operations. Based on those stipulations, the district court ruled that WCSD had violated the students' rights and held a trial only on the issue of damages. Lowry, cont. The Eighth Circuit affirmed. The court rejected WCSD’s attempt to distinguish Tinker on the basis of the fact that in Tinker the students wore armbands to protest the Vietnam war, while here they merely protested a dress code. “Whether student speech protests national foreign policy or local school board policy is not constitutionally significant,” the court held. The court also concluded that none of the circumstances that led to modification of the Tinker standard in the Supreme Court’s subsequent rulings in Bethel School District No. 403 v. Fraser, 478 U.S. 675 (1986), Hazelwood School District v. Kuhlmeier, 484 U.S. 260 (1988), and Morse v. Frederick, 127 S. Ct. 2618 (2007) were present in the current case. The Eighth Circuit went on to conclude that the district court had properly weighed the factors for issuing its injunction, including balancing the harms to the parties, and that the plaintiffs were entitled to attorneys’ fees even though they only recovered nominal damages, because the fact that obtaining the injunction was not “readily reducible to a sum of money” did not make their victory technical or de minimus. Nuts Washington student charged with using peanut butter in assault on allergic classmate Joshua Hickson, a student at Wenatchee High School, spread peanut butter on the forehead of a student he heard has a peanut allergy. The alleged victim of the attack told Joshua he was allergic to peanut butter and he “shouldn’t do that.” According to the police report, Joshua then got more peanut butter on his fingers and again put it on the victim. No allergic reaction ensued. The victim’s parents did not want to press charges. The police said they believed a crime had been committed and produced a report that was forwarded to the city attorney. Other assaults by peanut butter have been reported. An eighth-grader in Kentucky was charged with felony assault in April for putting peanut butter cookie crumbs in the lunch box of a classmate with an allergy. In July, a woman in Ohio was charged with assault for throwing peanuts at a man she knew was allergic to them. In Rhode Island, the state Legislature in 2007 passed a peanut law requiring schools to have signs at all entrances to the school and cafeteria stating that a student at the school is allergic to peanuts or other nuts. The law bans schools from selling peanuts in the cafeteria and requires the designation of a nut-free lunch table and nut-free classrooms. Nebraska Update The Nebraska constitutional amendment prohibits state and local governments from giving preferential treatment to people on the basis of race, sex, ethnicity or national origin Do we need to scour programs to see if they violate a ban on affirmative action? A wide range of programs aimed at boosting diversity may be affected, from a math camp for high school girls, to Native American Day, to recruitment of foreign students, to grants that may use race as a factor… The ballot victory for affirmative action opponents is in state court to challenge the validity of petition signatures – the allegation is they were gathered using a “pattern of fraud and illegality.” Open Meetings: Bligh v. Douglas Cty. Sch. Dist. No. 0017 The Nebraska Court of Appeals reversed a teacher's dismissal when it found the Millard School Board violated the Open Meetings Law when it made its decision in a closed session. The case involves the 2006 firing of Tanya Bligh, who was a teacher at Russell Middle School. Following four days of hearings, the board determined that Bligh was an incompetent teacher and failed to meet Millard's performance standards. But in terminating Bligh's contract, the board voted in closed session. The Board announced the decision in open session, but failed to actually hold the vote in open session. Neb. Rev. Stat. § 79-829 (Reissue 2003) specifically provides that a teacher’s contract shall be deemed continuing and remain in full force unless the school board “by a vote of the majority of its members” determines that the contract should be terminated. Nebraska law requires the formal action of a school board in terminating a teacher's contract to be taken in open session. We conclude that the actual vote of the school board on the issue of terminating a contract is “formal action” within the contemplation of the statute. Because the Board failed to hold its vote on Bligh's contract in open session, the judgments of the district court affirming the Board's termination of Bligh's contract was reversed and the case remanded with directions to vacate the decision of the board. Federal Regulations: E-Rate The FCC is considering expanding technology eligible for Erate funding The Federal Communications Commission (FCC) sought comment on whether the following services should be eligible for funding under the E-rate program, which supports technology in schools and libraries: filtering software, a broader classification of basic telephone service, dark fiber, text messaging, firewall service, antivirus/anti-spam software, scheduling services, telephone broadcast messaging, and certain wireless Internet access applications. The FCC also seeks comment on whether to retain interconnected Voice over Internet Protocol (interconnected VoIP) as an eligible service. Comments are due by September 18, 2008, and reply comments are due by October 3, 2008. FCC proposed rule, 73 Fed. Reg. 48,352 (Aug. 19, 2008) Federal Law Changes: The ADA Public Law 110-325 Signed into law Sept. 25, 2008 Effective January 1, 2009 To state a claim for disability discrimination, a plaintiff must show: (1) he is an individual with a disability within the meaning of the Americans with Disabilities Act ("ADA"); (2) he is qualified to perform the essential functions of his job, with or without reasonable accommodations; and (3) he suffered an adverse employment action "because of" a disability. Kellogg v. Union Pacific R.R. Co., 233 F.3d 1083, 1086 (8th Cir. 2000); Buckles v. First Data Resources, 176 F.3d 1098, 1100 (8th Cir. 1999). To start, a plaintiff must prove he is a qualified individual with a disability. The ADA defines a disability as: "(A) a physical or mental impairment that substantially limits one or more of the major life activities of such individual; (B) a record of such an impairment; or (C) being regarded as having such an impairment." 42 U.S.C. § 12102(2). Merely having a physical or mental impairment is insufficient to be considered disabled under the ADA. Rather, to constitute a disability, "the impairment must substantially limit one or more of the individual's major life activities." Id. PL 110-325 (ADA), cont. Findings In enacting ADA, intended to provide broad protections Holding in Sutton v. United Airlines (1999) et al have narrowed the scope of protection intended to be afforded by the ADA, thus eliminating protections Congress intended or mental impairment with medication and assistive devices are not individuals with a disability Holding in Toyota Motor Mfg, Kentucky, Inc. v. Williams (2002) et al further narrowed the broad scope of protection intended by the ADA Sutton held that individuals who are able to mitigate the symptoms of their physical Toyota held that the ADA needed to be “strictly interpreted,” that individuals faced a “demanding standard for qualifying as disabled,” and that “major life activities” including only those activities of “central importance to daily life” This interprets the term “substantially limited” to “require a greater degree of limitation than required by Cong.” Current EEOC regs defining “substantially limited” as “significantly restricted” are inconsistent with Cong. Intent and too high Result of these cases is that lower courts have incorrectly found that people with a range of substantially limiting impairments are not people with disabilities PL 110-325 (ADA), cont. Purposes Reinstate the broad scope of protection under the ADA Reject requirement in Sutton that whether Q. of “substantially limits” is determined with reference to ameliorative effects of mitigating measures Reject Toyota’s standards and convey Cong. Intent that Toyota “created an inappropriately high level of limitation necessary to obtain coverage under the ADA” “The primary object of cases brought under the ADA should be whether entities covered under the ADA have complied with their obligations” and “convey that the question of whether an individual’s impairment is a disability under the ADA should not demand extensive analysis.” PL 110-325 (ADA), cont. Expands the definition of “major life activities” to include, but not be limited to: Caring for oneself Performing manual tasks Seeing Hearing Eating Sleeping Walking Standing Lifting Bending Speaking Breathing Learning Reading Concentrating Thinking Communicating Working Is there anything not on this list?! PL 110-325 (ADA), cont. For the first time defines “major life activity” to also include “major bodily functions,” including, but not limited to: Functions of the immune system Normal cell growth Digestive, bowel, bladder, brain, respiratory, circulatory, endocrine, and reproductive functions Expands definition of “being regarded as having such an impairment” Individual is “regarded as” if he or she establishes that he or she has been ‘subjected to an action prohibited under this Act’ (discrimination) because of an actual or perceived physical or mental impairment whether or not the impairment limits or is perceived to limit a major life activity “Regarded as” does not apply to impairments that are transitory (6 months or less) and minor PL 110-325 (ADA), cont. Impacts on employers: More people with things like diabetes, epilepsy, heart disease, mental disabilities, and cancer will not fall under the umbrella of the ADA Expansion of definition of disability also will likely result in an increase in the number of lawsuits filed against employers Disability should be considered without considering mitigating measures Depression and epilepsy – where disabilities only occur in episodes, they are assessed when their symptoms are present Employers previously had been very successful in securing dismissals of ADA claims based on argument that plaintiff was not an individual with a disability More employees will be considered disabled and will not need medical expert to prove disability Expansion of the definition of disability will make it more difficult for employers to qualify for summary judgment With the expanded number of conditions which qualify as a disability, employers will be required to make reasonable accomms in a greater variety of situations More accommodation requests Since more employees are now covered under the law, employers must treat all requests carefully More focus on the interactive process Eighth Circuit: “[F]or purposes of summary judgment, the failure of an employer to engage in an interactive process to determine whether reasonable accommodations are possible is prima facie evidence that the employer may be acting in bad faith.” Fjettlesad v. Pizza Hut of America (8th Cir. 1999). Section 504 and the ADAAA Section 504 establishes that disabled/ "medically fragile" students, whose impairments may not limit their ability to learn, have a right to a free, appropriate public education. School districts have to provide the necessary educational services, aids and accommodations to ensure this right. WHO IS PROTECTED UNDER SECTION 504? Students whose physical or mental impairments substantially limit one or more "major life activities," such as caring for oneself, seeing, breathing, learning and walking, are protected by Section 504. Section 504's definition of a disabling condition is broader than that of the Individuals with Disabilities Education Act (IDEA), which describes a disabled child as one whose impairment requires special education and related services because the disability limits the student's ability to learn. Medically fragile students, on the other hand, often need not and should not be placed in special education programs as called for in IDEA. Special education students, however, are also Section 504 eligible. Section 504 and the ADAAA, cont. It is important to understand that the ADA and Section 504 define disability in a similar way, and therefore, ADA case law is applicable to 504 cases. Because the harmful ADA cases were also applicable to 504, the reforms apply to both laws. These reforms include the following highlights. Section 504 and the ADAAA, cont. Unlike the situation with employment, most school districts appropriately applied the law to 504 eligibility questions, and accommodated a range of students with disabilities. Thus, the ADAAA will not make any substantial changes in what most districts already do. But the law provides an important remedy for those children who have inappropriately been denied 504 eligibility. COPAA had received reports of some school districts denying 504 eligiblity to children with diabetes, life-threatening food allergies, learning disabilities, ADHD, Aspergers Syndrome, and other disabilities. For example, one school district argued that because a 6yo with a life-threatening nut allergy could care for himself about as well as other 6yos, and because he could breathe just fine when not suffering from anaphylaxis, he wasn't substantially limited and didn't have a disability under 504. Other 504 situations involved children with disabilities who are unable to obtain 504 plans with appropriate behavioral supports and access to appropriately challenging school work. Federal Regulation: FMLA The Department of Labor has issued final regulations under the Family Medical Leave Act of 1993. The final regulations are over 200 pages long and cover numerous topics that affect school districts including: the definitions of serious health condition, continuing treatment, and chronic condition; use of intermittent leave; substituting paid leave for unpaid FMLA leave; consequences for interfering with FMLA rights; waiver of FMLA rights; employer notices; consequences of employer's failure to designate leave as FMLA leave; medical certifications; and fitness for duty requirements. A notable change in the final rules is that employers will be able to require employees to follow call-in policies to provide notice of planned leave instead of employees being able to wait until two days after an absence to notify the employer. The final regulations also address the new military leave entitlements which provide additional leave to employees who provide care to covered service members with a serious injury or illness or because of qualifying exigencies arising out of a covered service member's call to active duty. The final rule is effective January 16, 2009. 73 Fed. Reg. 67934 (Nov. 17, 2008) Federal Regulations: ESEA The Department of Education issued a notice of final interpretations under Title III of the Elementary and Secondary Education Act as amended by the No Child Left Behind Act. These final interpretations address the annual administration of English language proficiency assessments (ELP) for limited English proficient (LEP) students served by Title III, the establishment of annual measurable achievement objectives (AMAOs), and the implementation of Title III accountability provisions. More specifically, the final interpretations cover the following 10 topics: annual ELP assessment of LEP students; use of annual ELP assessment scores for AMAOs 1 and 2; students included in Title III accountability; exclusion of Title III-served LEP students “without two data points” from AMAO-1; attainment of English language proficiency and “exiting” the LEP subgroup; use of minimum group size in Title III accountability; all LEP students, adequate yearly progress, and AMAO 3; AMAOs and the use of cohorts; determining AMAOs for consortia; and implementation of corrective actions under Title III. The final interpretations are effective November 17, 2008. 73 Fed. Reg. 51,828,(Oct. 17, 2008) Federal Regulations: Title I Final Title I regulations seek to clarify and strengthen current Title I regulations in the areas of assessment, accountability, public school choice, and supplemental educational services (SES). The most far-reaching change in these regulations is in how states, school districts, and schools are held accountable for graduating students from high school. Additionally, new requirements governing SES and public school choice are intended to ensure that parents and students are informed of their options in a timely and effective manner and that school districts effectively use funding. Changes addressing the inclusion of student subgroups in school and school district adequate yearly progress determinations are intended to ensure greater accountability for the achievement of all groups of students. Amendments to the regulations governing restructuring of schools in improvement are intended to ensure that school districts take significant reform actions. Requiring the inclusion of state data from the National Assessment of Educational Progress on state and local report cards will provide parents and the public with additional information about student performance. These regulations are effective November 28, 2008. 73 Fed. Reg. 64436 (Oct. 29, 2008) Federal Regulation: 403(b) On July 26, 2007, the IRS released final 403(b) regulations for public school employee retirement plans. The final rules represent a significant increase in administrative responsibility for school superintendents and districts. For the first time, they will assume full responsibility for administering public school systems’ retirement savings plans. The regulations, which are published in the July 26 Federal Register will, for the most part, take effect on Jan. 1, 2009. Federal Regulations: FLSA Deadline for FLSA comments extended The Department of Labor (DOL) has extended by 15 days the period for filing written comments on proposed revisions to regulations issued under the Fair Labor Standards Act (FLSA) that have become out of date because of subsequent legislation or court decisions. Among other things, FLSA governs minimum wage, overtime, and other pay requirements. The proposed revisions are at the second link below. Comments are due by September 26, 2008. DOL notice of extension, 73 Fed. Reg. 49,621 (Aug. 22, 2008) DOL proposed rule, 73 Fed. Reg. 43,654 (July 28, 2008) Federal Notices: Religious Discrimination Citing changing demographics and a steady increase in complaints from people of faith, the U.S. Equal Employment Opportunity Commission (EEOC) last week released an updated compliance manual on religious discrimination in the workplace. The agency issued the guidance after consultation with religious groups, employers, and labor organizations. The number of religious-discrimination charges reported to the agency has more than doubled over the last 15 years. The new manual provides safeguards for workers who request time off for religious observances, and protects workers whose faith requires they wear specific religious garments, such as hijab. Muslims have faced the sharpest increase in workplace discrimination of any major religious in recent years. Between 1997 and 2007, the number of discrimination charges filed by Muslims more than doubled, from 398 to 907. Religious Discrimination, cont. The Section addresses what constitutes “religion” within the meaning of Title VII; disparate treatment based on religion; the requirement to reasonably accommodate religious beliefs and practices; religion-based harassment; and retaliation. The Section also provides guidance on the sometimes complex workplace issues involved in balancing employees’ rights regarding religious expression with employers’ need to maintain efficient, productive workplaces. The EEOC issued this section in response to an increase in charges of religious discrimination, increased religious diversity in the United States, and requests for guidance from stakeholders and agency personnel investigating and litigating claims of religious discrimination. Religious discrimination charge filings with the EEOC nationwide have risen substantially over the past 15 years, doubling from 1,388 in Fiscal Year 1992 to a record level of 2,880 in FY 2007 What to expect in 2009? It’s the economy, to begin with… NE has $593 million cash reserve fund The Nebraska Economic Forecast Advisory Board met in October and projected relatively modest, but still positive increases in state revenue: $49 million for FY2009-10 and $117 for FY2010-11 BUT the Tax Rate Review Committee predicts a $377 million shortfall for the 2009-11 biennium budget. Against this backdrop, the state aid formula (TEEOSA) is projected to require an increase of $73 million ($60 of which comes from cuts last year…) for 2009-10 to fully fund the formula, as revised by LB 988 (2008). The “new” Legislature Long session Increase in introduced legislation expected Changes on the Education Committee And to end with… The economy at the federal level will drive funding for promised initiatives in NCLB, IDEA, Medicaid, etc. Innovations in teacher pay may be part of the picture: DC story; OEA plan