Justia U.S. 5th Circuit Court of Appeals Opinion Summaries

A.P. was a student in Pearland Independent School District who, after a period of homeschooling, returned to the District and began experiencing significant attendance problems. Despite passing her classes with targeted intervention, her absenteeism persisted, and she failed multiple advanced courses that her parents insisted she take against the District’s advice. Her teachers consistently attributed her academic struggles to poor attendance rather than any suspected learning disability. The District recommended less challenging courses and additional support programs, but her parents declined these options and continued to excuse her absences for non-serious reasons.After withdrawing A.P. from the District and homeschooling her, her parents requested a due process hearing, alleging that the District failed to identify and evaluate her for learning disabilities under the Individuals with Disabilities in Education Act (IDEA). The District offered to conduct an evaluation, but her parents refused consent. Instead, they obtained an independent evaluation, which found some learning disabilities but lacked classroom observations and teacher input. The District determined it did not have enough information to assess her eligibility for special education services. A Special Education Hearing Officer found no IDEA violation, and the United States District Court for the Southern District of Texas affirmed, concluding that the District met its child find obligation and that A.P.’s academic issues were primarily due to absenteeism.The United States Court of Appeals for the Fifth Circuit reviewed the case, applying de novo review to mixed questions of law and fact and clear error review to factual findings. The Fifth Circuit held that the District’s child find duty was not triggered by A.P.’s absenteeism or poor grades alone, and that her parents failed to prove she qualified for special education under IDEA. The court affirmed the district court’s judgment. View "A.P. v. Pearland Independent School District" on Justia Law

Several former students and their parents challenged a school district’s policy restricting the length of male students’ hair, alleging that the policy constituted race and sex discrimination and violated constitutional and statutory rights. The school district amended its hair policy during the 2019–2020 school year, removing language that previously allowed certain hairstyles, such as cornrows or locs, if they complied with other requirements. The plaintiffs argued that the enforcement of this policy infringed upon their rights under the Fourteenth Amendment, the First Amendment, Title VI, Title IX, and Texas law.The case was initially heard in the United States District Court for the Southern District of Texas. During discovery, the plaintiffs sought to depose the superintendent and a former board president. The school district moved for a protective order, asserting legislative privilege to prevent inquiries into the subjective motivations of board members regarding the hair policy. The district court partially denied the motion, establishing a procedure where deponents could assert the privilege but would still be required to answer, with disputed portions of testimony marked confidential for later review. The district court declined to rule on the privilege’s applicability until specific questions were asked during depositions.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed whether the district court erred in its handling of the legislative privilege and the protective order. The Fifth Circuit held that none of the appellants—including the school district, the board of trustees, and the individual former officials—had standing to appeal the district court’s order because the privilege holders had not personally invoked the privilege or participated adequately in the proceedings. As a result, the Fifth Circuit dismissed the appeal for lack of jurisdiction and also dismissed the pending motion to stay as moot. View "Arnold v. Barbers Hill Independent School District" on Justia Law

Jane Doe attended high school in City View Independent School District from 2016 to 2020, where she was allegedly sexually abused by her teacher, Robert Morris. The abuse reportedly began when Doe was a fifteen-year-old freshman and continued until she graduated. Doe claims that she reported the abuse to school officials in 2018, but they threatened her with retaliation and did not report the abuse to law enforcement. In 2022, after public outcry over Morris being named coach of the year, Doe publicly stated her experiences, leading to further threats from school officials.Doe filed a lawsuit against City View ISD and several school officials in the United States District Court for the Northern District of Texas on April 4, 2023. The district court dismissed her second amended complaint with prejudice, concluding that her claims were barred by the statute of limitations. Doe appealed the dismissal of her Title IX claims, arguing that her claims were timely due to the continuing violation doctrine or equitable tolling.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court's dismissal. The court held that Doe's Title IX claims were barred by the statute of limitations, as they accrued no later than May 2020 when she graduated. The court also found that Doe's arguments for equitable tolling and the continuing violation doctrine were unavailing. Additionally, the court determined that Doe could not convert her First Amendment retaliation claim, based on a 2022 letter from a school official, into a Title IX retaliation claim. The court concluded that the district court did not abuse its discretion in denying Doe leave to amend her complaint. View "Doe v. City View Independent School District" on Justia Law

M.K., a minor, enrolled in the Pearl River County School District after being homeschooled. During his sixth-grade year, he was bullied by boys in four of his classes, who called him names like "gay." In October, M.K. exposed his genitals to one of the boys in a restroom, claiming it was either accidental or an attempt to prove he was not "gay." The District suspended M.K. and required him to attend an alternative school for six weeks, which he refused, considering it akin to a prison. M.K., through his father, sued the District and others, alleging deliberate-indifference sex-discrimination under Title IX.The United States District Court for the Southern District of Mississippi granted summary judgment in favor of the District, concluding that Title IX does not cover sexual-orientation discrimination and that the alleged behavior was not severe enough to be actionable. M.K. appealed this decision.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo. The court affirmed the district court's decision, holding that the student behavior M.K. experienced, while mean-spirited, did not meet the Supreme Court's stringent standard for "severe, pervasive, and objectively offensive" conduct required for a Title IX claim. The court emphasized that the behavior M.K. described, such as name-calling and teasing, is common in schools and does not rise to the level of actionable harassment under Title IX. The court concluded that M.K.'s experiences, though unfortunate, were not sufficient to sustain his Title IX claim against the District. View "M.K. v. Pearl River County School District" on Justia Law

Parents and students in Louisiana challenged a state statute requiring public schools to permanently display the Ten Commandments in every classroom. The statute, House Bill 71 (H.B. 71), mandated that the Ten Commandments be displayed prominently and legibly, with an optional inclusion of other historical documents. Plaintiffs argued that this statute violated the Establishment Clause and Free Exercise Clause of the First Amendment.The United States District Court for the Middle District of Louisiana found the statute facially unconstitutional and issued a preliminary injunction to prevent its enforcement. The court ruled that the statute's primary purpose was religious, not secular, and that it coerced students into religious observance, thus violating the Establishment Clause. Louisiana officials appealed the decision, arguing that the statute had a valid secular purpose and that the plaintiffs lacked standing.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court's decision. The Fifth Circuit held that the statute was unconstitutional under the Establishment Clause, relying on the precedent set by Stone v. Graham, which struck down a similar statute in Kentucky. The court found that the statute's requirement to display the Ten Commandments in every classroom, without integrating them into an educational curriculum, served no secular educational purpose and was inherently religious.The court also determined that the plaintiffs had standing to challenge the statute, as they would be directly affected by the displays. The court rejected Louisiana's arguments regarding ripeness, standing, and sovereign immunity. The preliminary injunction was upheld, preventing the enforcement of H.B. 71 and requiring Louisiana officials to notify all public schools of the court's ruling. View "Roake v. Brumley" on Justia Law

In this case, Olivia Boone, on behalf of her autistic son K.A., challenged the Rankin County Public School District's decision to move K.A. to a new program at a different school without her consent. Boone filed a complaint with the Mississippi Department of Education, alleging that the school district violated the Individuals with Disabilities Education Act (IDEA) by unilaterally making the placement decision. A hearing officer found that the school district violated the IDEA and ordered relief but denied Boone's request for compensatory educational services. Boone then filed a suit seeking compensatory educational services and attorneys' fees.The United States District Court for the Southern District of Mississippi affirmed the hearing officer's decision, holding that Boone was entitled to attorneys' fees but not compensatory educational services. Boone appealed the denial of compensatory educational services, and the school district cross-appealed the finding that it violated the IDEA and the award of attorneys' fees.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court's judgment. The court held that the school district denied K.A. a free appropriate public education by failing to individualize his education plan to address his elopement tendencies and by predetermining his placement without Boone's input. However, the court found that Boone did not prove that Brandon Middle School was not K.A.'s least restrictive environment. The court also held that Boone was not entitled to compensatory educational services, as the district court did not abuse its discretion in limiting relief to address Boone's primary concerns. Finally, the court affirmed that Boone was a prevailing party entitled to attorneys' fees, as the relief awarded altered the legal relationship between K.A. and the school district and fostered the purposes of the IDEA. View "Boone v. Rankin County" on Justia Law

Plaintiffs John and Jane Doe, on behalf of their minor children Janie Doe 1 and Janie Doe 2, alleged that Prosper Independent School District officials, Superintendent Holly Ferguson and former Transportation Director Annamarie Hamrick, failed to prevent school-bus-driver Frank Paniagua from sexually abusing their children. The abuse, which occurred during the 2021-22 school year, was captured on the bus’s video surveillance and reflected in GPS tracking data. Plaintiffs claimed that Ferguson and Hamrick had subjective knowledge of the abuse but failed to act.The United States District Court for the Eastern District of Texas denied Ferguson and Hamrick's motions to dismiss based on qualified immunity, concluding that the complaint plausibly alleged that the defendants were aware of Paniagua’s inappropriate behavior and demonstrated deliberate indifference by failing to take necessary action to stop the abuse. The court allowed the claims under Title IX against Prosper ISD and claims under § 1983 against Paniagua’s estate to proceed, while dismissing the equal-protection and failure-to-train claims without prejudice.The United States Court of Appeals for the Fifth Circuit reviewed the interlocutory appeal concerning the denial of qualified immunity for the supervisory-liability claims under § 1983. The court held that the plaintiffs failed to plausibly allege that Ferguson and Hamrick had subjective knowledge of the abuse. The court emphasized that mere access to information, such as surveillance footage and GPS data, does not equate to subjective knowledge. Consequently, the court vacated the district court's denial of qualified immunity and granted qualified immunity to Ferguson and Hamrick for the supervisory-liability claims under § 1983. View "Doe v. Ferguson" on Justia Law

The case involves Jennifer Sugg, a student who was dismissed from her Certified Registered Nurse Anesthesiology (CRNA) program at Midwestern University after failing several required courses. Sugg sued Midwestern University and EmergencHealth (EH), alleging breach of contract and fraud. The United States District Court for the Southern District of Texas granted summary judgment in favor of the defendants on all causes of action, and Sugg appealed.Sugg enrolled in Midwestern's CRNA program in 2016. She failed a course in her first semester and was placed on academic leave. After retaking the course and receiving a passing grade, she was placed on academic probation due to her low GPA. Sugg later failed her first clinical rotation course and was dismissed from the program. She appealed the decision, and the dismissal was overturned so she could retake the course. However, after failing another course, she was dismissed again. Sugg appealed this decision as well, but it was upheld by the university's Promotion and Graduation Committee and the Dean of the College of Health Sciences.The United States Court of Appeals for the Fifth Circuit affirmed the lower court's decision. The court found that Midwestern University did not breach the contract as it followed its guidelines and dismissed Sugg based on her academic performance. The court also found that Sugg failed to show that the university's decision was a substantial departure from accepted academic norms. Regarding the claims against EH, the court found that EH did not interfere with Sugg's contract with Midwestern University and did not make any false or misleading statements. Therefore, the court affirmed the summary judgment in favor of the defendants. View "Sugg v. Midwestern University" on Justia Law

The case involves Elliott Sterling, who was convicted for engaging in a fraudulent scheme to obtain loan and grant funds from the Department of Education’s Federal Student Aid Program. Sterling submitted fraudulent applications on behalf of students, both real and fictional, and also committed fraud in connection with his educational consulting business. He was indicted for multiple counts of wire fraud, financial aid fraud, and engaging in monetary transactions involving property derived from specified unlawful activity. Sterling chose to represent himself during the trial after his request for a new counsel was denied.The district court found Sterling competent to waive his right to counsel and allowed him to proceed pro se in his defense. After a 9-day jury trial, Sterling was convicted on all counts. He was sentenced to 132 months of imprisonment, followed by a 3-year term of supervised release. Sterling appealed, raising several Sixth Amendment claims.The United States Court of Appeals for the Fifth Circuit affirmed the district court's decision. The court found no merit in Sterling’s procedural or substantive challenges. It held that Sterling's waiver of counsel was clear, unequivocal, and voluntary, and that he was competent to represent himself at trial. The court also found that the district court did not err in allowing Sterling to represent himself at his own competency hearing, and that the district court's determination of Sterling's competence did not constitute an abuse of discretion. View "United States v. Sterling" on Justia Law

The case revolves around a dispute between the Career Colleges and Schools of Texas (CCST) and the United States Department of Education over new regulations that will facilitate certain student loan discharges. The contested rule overturns recent regulations issued by the previous administration and alters thirty years of regulatory practice. The CCST challenged the regulations, arguing that they create uncertainty and potentially significant liability for its members. The district court declined to issue a preliminary injunction against the rule, stating that the plaintiffs had not demonstrated irreparable harm.CCST argued that the new regulations are beyond the Department of Education's statutory authority, violate the Administrative Procedure Act (APA), and infringe on the due process rights of its members. The United States Court of Appeals for the Fifth Circuit disagreed with the lower court's findings, concluding that CCST is likely to succeed on the merits of its challenge and that its members will face immediate and irreparable harm if the new regulations are allowed to go into effect.The court reversed the district court's judgment and remanded the case with instructions to enjoin and postpone the effective date of the challenged provisions pending final judgment. The court ruled that the Department of Education's new regulations are likely unlawful and that their implementation would cause immediate and irreparable harm to CCST and its members. The court ordered the lower court to issue a preliminary injunction to delay the implementation of the new regulations until the case is finally resolved. View "Career Colleges and Schools of Texas v. United States Department of Education" on Justia Law