Justia U.S. 8th Circuit Court of Appeals Opinion Summaries

The Eighth Circuit affirmed the district court's dismissal of plaintiff's Missouri state-law claims for breach of contract, breach of the implied covenant of good faith and fair dealing, and fraudulent misrepresentation against St. Louis University. Plaintiff's claims stemmed from his unsuccessful attempts to receive a Ph.D from the university in mechanical and aerospace engineering in four years.The court held that the educational malpractice doctrine barred all of plaintiff's claims. In this case, all of the statements plaintiff relied on in the student catalog and handbook were aspirational in nature. The court also held that the district court did not abuse its discretion by denying plaintiff leave to amend his complaint when he did not submit a proposed amendment or include anything in his motion to indicate what an amended complaint would contain. View "Soueidan v. St. Louis University" on Justia Law

The Eighth Circuit affirmed the district court's judgment in favor of the school district in an action originally alleging that plaintiff's daughter, a young student with autism and significant intellectual deficits, was not provided a free appropriate public education (FAPE) under the Individuals with Disabilities Education Act (IDEA). Plaintiff also brought additional claims for constitutional violations under 42 U.S.C. 1983, disability discrimination and retaliation under section 504 of the Rehabilitation Act, disability discrimination under Title II of the Americans with Disabilities Act (ADA), and violations of Arkansas law.The court found no clear error in the district court's factual findings and gave due weight to the hearing officer's credibility determinations, concluding that the child was not denied a FAPE. The court also held that the district court did not abuse its discretion in denying plaintiff's motions for extensions of time and her motion to accept her summary judgment response out of time. The court also held that some of plaintiff's claims were barred for failure to exhaust and that her retaliation claim based on a violation of the IDEA also failed. View "Albright v. Mountain Home School District" on Justia Law

Two male students filed suit against Minnesota's high school athletic league and others, alleging that the league unlawfully discriminated against them on the basis of sex through its rule prohibiting boys from participating on high school competitive dance teams. The Eighth Circuit reversed the district court's denial of the students' motion for preliminary injunction and directed the district court to enter a preliminary injunction.The court held that the heightened, likely-to-prevail standard did not apply to the boys' preliminary injunction motion, but instead, whether the boys have a fair chance of prevailing. On the merits, the court held that the boys had more than a fair chance of prevailing on the merits of their equal protection claim where the league has not asserted an exceedingly persuasive justification for keeping them from participating on high school competitive dance teams. Furthermore, the remaining Dataphase factors favored a preliminary injunction. View "D.M. v. Minnesota State High School League" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment to the University in a Title IX action alleging that plaintiff was excluded from participation in and denied the benefits of the educational programs at the University as a result of its response to her sexual assault by another student. The court assumed, without deciding, that plaintiff's claim survived Iowa's statute of limitations and held that plaintiff's Title IX claim failed on the merits. The court held that there was no genuine dispute as to whether the University was deliberately indifferent after its investigative report concluded that plaintiff was sexually assaulted. In this case, the University was waiting to take action until the hearing process concluded and it had instituted a no-contact order between plaintiff and the other student. View "Maher v. Iowa State University" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment for the school district in an action under Section 504 of the Rehabilitation Act. The court held that, where parents refuse special education services for their child under the Individuals with Disabilities Education Act (IDEA) and bring suit under another act, they must first exhaust their administrative remedies under the IDEA if the relief they seek in the suit is also available under the IDEA. Therefore, because plaintiffs failed to exhaust their administrative remedies under the IDEA in this case, the school district was entitled to summary judgment. View "E. D. v. Palmyra R-I School District" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment to the school district in an action filed by plaintiffs of a student, alleging violation of the student's rights under the Rehabilitation Act when the school district failed to make reasonable accommodations for her. The court held that the parents' complaint sought relief available under the Individuals with Disabilities Education Act (IDEA) -- relief for the denial of a free and appropriate public education-- and thus they must exhaust their administrative remedies unless an exception to the exhaustion requirement applied. In this case, none of the three exceptions to the exhaustion requirement applied. Therefore, the district court properly granted summary judgment for failure to exhaust administrative remedies under the IDEA. View "Nelson v. Charles City Community School District" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment to the school district and the Arkansas Department of Education, in an action alleging that plaintiffs' children were denied a free appropriate public education (FAPE) as required by the Individuals with Disabilities Education Act (IDEA). The court held that Child A and Child L were provided a FAPE and the district court did not err in rejecting their families' claims. The court noted that the district court's strategies, while they might have been imperfect, complied with the IDEA, included detailed strategies to address the children's behavioral problems and contained evidence that the children were progressing academically. The court held that Child S and Child G's claims were not administratively exhausted and the district court properly granted the district's motion for summary judgment on their claims. Finally, the district court did not abuse its discretion by excluding an expert report as a sanction for plaintiffs' failure to disclose the report on a timely basis, and the report was conclusory and non-specific and would not have materially impacted the court's analysis. View "Parrish v. Bentonville School District" on Justia Law

Charter school parents sought to intervene in the St. Louis public school desegregation litigation to enforce a 1999 Desegregation Settlement Agreement. The Eighth Circuit reversed the district court's denial of the charter parents' motion to intervene, holding that the charter parents had standing. In this case, their pleading alleged that the charter schools will suffer a loss of funding and a decline in funding if plaintiffs prevailed and tens of millions of dollars could be transferred from the charter schools. Therefore, such an injury was neither conjectural nor hypothetical, and was sufficiently imminent to constitute an injury in fact. The court also held that the charter parents have established the elements of traceability and redressability. The court remanded for the district court to determine in the first instance whether the charter parents meet the requirements under Federal Rule of Civil Procedure 24 for intervention as of right or for permissive intervention. View "Ross v. Special Administrative Board of the Transitional School District of the City of St. Louis" on Justia Law

The NAACP filed suit against the school district for voter dilution under section 2 of the Voting Rights Act of 1965 (VRA). The Eighth Circuit affirmed the district court's finding that (1) the NAACP had proved the preconditions for a section 2 vote dilution claim, and (2) the totality of the circumstances indicated that the district's black voters had less opportunity to elect their preferred candidate than other members of the electorate. The court held that the district court found a section 2 violation after engaging in the requisite precondition analysis and conducting a thorough totality-of-the-circumstances balancing. View "NAACP v. Ferguson-Florissant School District" on Justia Law

The Eighth Circuit affirmed the district court's denial in part of the University's motion to dismiss an action alleging violations of Title IX of the Education Amendments of 1972. The district court refused to dismiss the Title IX claims on the basis of sovereign immunity. The court agreed that the University waived its sovereign immunity under the Remedies Equalization amendment by accepting federal funds. View "Fryberger v. University of Arkansas" on Justia Law