August 28, 2009
August 2009
U.S. Supreme Court Decisions
Age Discrimination in Employment Act /
Mixed Motive
Gross v. FBL Financial Services, Inc., 129 S.Ct. 2343 (June 18, 2009)
While this case was not directly related to education, it will have an important impact on boards of education across the country, particularly during times of proration. The ADEA makes it illegal to take an adverse employment action “because of” a person’s age. In this case, the 54-year old employee sued his employer claiming that he was demoted in part because of his age. The trial court relied on a Title VII mixed-motives case, Price Waterhouse v. Hopkins, 490 U.S. 228 (1989), in instructing the jury on the shifting burdens of persuasion. Title VII permits “mixed motive” cases like the one here – that is a case where the employee claims that the action was for both a lawful reason and an unlawful reason. The text of Title VII requires only that the employee show that the unlawful reason was a “motivating factor” in the employer’s decision. However, the Supreme Court found here that because the ADEA does not contain similar language, Price Waterhouse was not applicable and mixed-motives cases are not proper under the ADEA. Therefore, the employee must show that “but for” his age, the employer would not have taken the adverse action. The practical impact of this decision on local school boards is that it will make it harder for older workers to prove ADEA claims. One example of this may be when a board takes action to layoff older, higher paid teachers in favor of younger, lower paid teachers in order to save money. Under the Price Waterhouse standard, the older teacher could still be successful even if he admitted that budgetary concerns were a partial motivation. Under the new standard in Gross, the older teacher would have to show that his age was the sole consideration for the layoff.
Strip Searches
Safford Unified School District v. Redding, 2009 WL 1789472 (June 25, 2009)
The plaintiff was a thirteen-year-old female student at Safford Middle School. The assistant principal came into possession of a day planner which contained contraband such as knives, lighters and a cigarette. After he received information that the day planner belonged to the student, he called her to his office. She admitted that the planner was hers, but said that she had loaned it to a friend. She also denied that the contraband in the planner belonged to her. The assistant principal then pulled out several relatively mild pain pills – specifically ibuprofen and naproxen, an over the counter medication similar to Advil – and asked the student if she knew anything about them. When she denied knowing anything about the pills, he told her that he had been told that she had been giving the pills to other students. She again denied the allegation and gave him permission to search her belongings. The assistant principal and a female assistant searched her backpack, but did not find any contraband. He then instructed the woman to take the student to the school nurse to search her for pills. In the presence of the two women, she was made to remove her jacket, shoes and socks as well as her pants and t-shirt until she stood only in her bra and underwear. She was then asked to pull her bra to the side and shake it. They also made her pull the elastic of her underwear out. No pills were found.
As a result of the strip search, the student’s mother filed suit against the district as well as the assistant principal, assistant and school nurse for violating the student’s fourth amendment rights to be free from unreasonable searches. The individual defendants argued that they were entitled to qualified immunity.
Both the trial court and the Ninth Circuit Court of Appeals agreed and granted the individuals qualified immunity. However, the full panel of the Ninth Circuit agreed to hear the matter and reversed the lower court. The individual defendants then appealed to the U.S. Supreme Court and the court agreed to hear the case.
First, the court reviewed the established law regarding school searches. The leading case on school searches is New Jersey v. T.L.O., 469 U.S. 325(1985), which adopted the “reasonable suspicion” standard for reviewing a school search. Reasonable suspicion – a lesser standard than probable cause – requires that there is a “moderate chance of finding evidence of wrongdoing.” The court then looked closer at the facts of this case to determine whether the defendants had reasonable suspicion to search the student. Under the facts of this case, there was no question that the officials were permitted to conduct the search of her backpack and outerwear. However, the court found that to require her to strip to her underwear in search of the medication was unreasonable. First of all, there was no indication that she had stashed the medication in her underwear, but more importantly, the medication at issue was relatively mild in potency. While the court did not question the officials’ motives of protecting the school and students, it found the intrusiveness far exceeded the danger posed by the pills. The court stated plainly:
In sum, what was missing from the suspected facts that pointed to [the student] was any indication of danger to the students from the power of the drugs or their quantity, and any reason to supposed that [the student] was carrying pills in her underwear. We think that the combination of these deficiencies was fatal to finding the search reasonable.
However, after finding that the school officials violated her Fourth Amendment rights when it subjected her to a strip search, the court also found the school officials were entitled to qualified immunity for their actions. Qualified immunity, which works to protect government officials from liability when performing discretionary actions, is appropriate when the law has not “clearly established” that their actions were unconstitutional. Here, the court found that T.L.O., the seminal case governing school searches, had been interpreted in such varying ways by lower courts, that the unconstitutionality of the officials’ actions here was not clearly established enough to put the school officials on notice of the wrongfulness of their action. While the officials were protected by qualified immunity here, this holding did not address the liability of the district, which remains a defendant.
IDEA / Private Schools
Forest Grove School District v. T.A., 2009 WL 1738644 (June 22, 2009)
The Supreme Court has already decided in Burlington v. Dept. of Educ., 471 U.S. 359 (1985) that public school districts can be forced to reimburse parents for private school tuition if the district fails to provide free and appropriate education to a student as a result of an inadequate IEP. The question in this case is whether such an award would be appropriate even if the child has never received special education services through the district. The Supreme Court now holds that such an award would be appropriate.
In this case, T.A. attended public school from kindergarten through his junior year of high school and experienced a significant learning difficulties throughout his education. During his freshman year, T.A.’s mother approached the school counselor to discuss T.A.’s continuing problems. T.A. was tested and evaluated by the school psychiatrist who determined that he did not qualify for special education services and did not need any further testing, including ADHD testing. As T.A.’s problems became worse, his family sought outside assistance and T.A. was eventually diagnosed with several learning disabilities as well as ADHD. On the advice of a private specialist, T.A.’s family enrolled him in private academy for children with special needs. Shortly thereafter, T.A.’s parents notified the district of the private placement and requested a due process hearing to determine his eligibility for special education services. The district worked with the family to evaluate T.A. for eligibility and determined that because his ADHD did not have a significant impact on his learning ability, he was not eligible for special education services. As a result of this decision, the family decided that T.A. would remain at the private school to complete his senior year. Following presentation of the evidence, the hearing officer determined that the district had failed to properly identify T.A. for special education services and ordered the district to reimburse T.A.’s family for the cost of his private education. The district appealed to district court and, while the court agreed with the hearing officer’s factual findings, it vacated the reimbursement award as “categorically barred” by the IDEA. T.A. appealed.
Before the Supreme Court, the district argued that the 1997 IDEA amendments, specifically 20 U.S.C. §1412(a)(10)(C)(ii), prohibited private school reimbursement when there had been no provision of services within the public schools. After first determining that the amendments contained no such prohibition, the Supreme Court determined that it would be nonsensical to permit private school reimbursement when a district has failed to adequately provide FAPE, but deny reimbursement when a district has failed to even identify that a child is in need of services. The Supreme Court also rejected the district’s argument that this ruling would impose heavy financial burdens on budget strapped public school systems. The court reasoned that the Burlington decision already contained safeguards to protect districts from improper awards. The Supreme Court also rejected the district’s argument that this holding would encourage parents to opt for private school rather than working with the district to find a solution within the public schools. The court determined that parents would not take the private school step lightly since they would be doing so at their own financial risk. It noted that a parent’s decision to place his child in private school would be tempered by his own knowledge that the federal courts may limit his claim for reimbursement or reject it outright in the future.
Alabama Supreme Court Decision
Fair Dismissal Act / Adequate Notice
Ex parte Soleyn, 2009 WL 1496834 (Ala. May 29, 2009)
Bishop State Community College sent two employees written notification of its intention to terminate them. In addition to the statutory grounds upon which the termination was based, the notices contained the following factual basis for the termination: “You committed financial improprieties in relation to the awarding of financial aid and scholarships.” At the time of the notices, both employees were aware of criminal charges and/or investigations regarding the facts underlying their terminations. The employees appealed the college’s decision to their respective hearing officers. Both hearing officers found that the factual basis had not provided the employees sufficient notice of the allegations made against them and overturned the terminations. The college appealed. The Court of Civil Appeals found that, under the circumstances, particularly as it related to the ongoing criminal investigations, the college had given the employees sufficient notice of the charges against them. The employees appealed to the Alabama Supreme Court and argued that the Court of Civil Appeals had reviewed the hearing officer’s decision de novo in violation of the statute and had improperly considered the circumstances surrounding the terminations. Ala. Code §36-26-104(b) states that the Court of Civil Appeals may not reverse a hearing officer’s decision unless it finds his decision to be arbitrary and capricious. The Court of Civil Appeals stated, and the Supreme Court found, that it conducted a de novo review of the record. However, the Supreme Court disagreed with the employees’ assessment of the proper standard of review. Here, because the facts were undisputed, the hearing officers did not hear any evidence. They merely applied the law to those undisputed facts. Therefore, the Supreme Court held that no presumption of correctness attached to their conclusions of law and the Court of Civil Appeals applied the proper standard of review. However, the Supreme Court also held that by looking to the surrounding circumstances, the Court of Civil Appeals departed from the requirement of the statute that obligated the college to provide the employees a “short and plain statement of the facts” supporting termination. Accordingly, the Court of Civil Appeals was reversed and the case remanded.
Alabama Court of Civil Appeals
Fair Dismissal Act / Supplemental Contracts
Simmons v. Coosa County Board of Education, 2009 WL 1717004 (Ala.Civ.App. June 19, 2009)
In this case, the board sought to terminate the supplemental contracts of several aides. The aides, who each enjoyed nonprobationary status in their regular aide positions, held supplemental contracts during each of the five school years preceding the terminations. Those contracts were entitled “Temporary Work Contracts” and contained provisions reinforcing that the contracts were supplemental in nature and not eligible for nonprobationary status. The aides requested hearings pursuant to the Fair Dismissal Act, but the board refused asserting that the subject contracts were supplemental and therefore, ineligible for FDA protections. The employees filed suit in the circuit court and alleged that the termination of their temporary contracts constituted a partial termination of their regular contracts. After the circuit court upheld the board’s actions, the aides appealed to the Court of Civil Appeals. The court held that the action was not a partial termination of the aides’ regular contracts and stated that the limiting language of the temporary contracts was so clear that the employees could not have possibly had a reasonable expectation of continued employment. Accordingly, inasmuch as no action was taken against their regular contracts, this action was not a partial termination and the aides were therefore not entitled to the protection of the FDA.
Salary Schedules
Dees v. Coaker, 2009 WL 2096250 (Ala.Civ.App. Jul. 17, 2009)
In the last issue of Court Report, we summarized Coaker v. Dees, a trial court opinion from Washington County issued in 2008. In that case, the support personnel plaintiffs sued the board and superintendent claiming that their salary schedules failed to comply with Ala. Code §16-22-10, the statute which requires boards to maintain a written salary schedule for its employees, because they did not contain escalating “steps.” While the board’s salary schedule for certified personnel contained steps as separately required by Ala. Code §16-22-13 and -13.5, the statutes which control raises for board employees, the board’s salary schedule for classified personnel did not. The trial court held that the board was in violation of the Ala. Code §16-22-13 and -13.5 and ordered it to provide escalating steps based on longevity for support personnel. The board appealed to the Court of Civil Appeals. While the Court of Civil Appeals agreed with the trial court that Ala. Code §16-22-13 and -13.5 do require steps for support personnel, it disagreed with the trial court’s assumption that those steps had to be based on longevity. Further, the court held that the trial court violated the board’s sovereign immunity by dictating that the steps had to be based on longevity. The court found that the statute was silent as to the basis of the steps, leaving that criterion to the individual boards.
Alabama District Court Decisions
Education Funding
Lynch v. State of Alabama, 568 F.Supp.2d 1329 (N.D.Ala. Jul. 24, 2008)
In this case, several public school students from Lawrence County and Sumter County filed a class action claiming that Alabama’s property tax system is racially discriminatory in violation of the Equal Protection Clause and Title VI of the Civil Rights Act. Specifically, the students claimed that the system hinders their legislators’ abilities to raise the revenue to support their public school systems. For this reason, the students asked the court to enjoin the enforcement of the property tax restrictions found in Alabama’s Constitution and give the Legislature an opportunity to adopt a proper tax scheme. The state moved for summary judgment. The state first argued that the students lacked standing to bring this action. In order to have standing, the plaintiff must show an injury to himself, a connection between the complained-of action and that injury and a substantial likelihood that the relief requested will correct the injury. The court agreed with the plaintiffs here that one element of standing, causation, is an element of these and most causes of action. As the court noted, any ruling on standing would necessarily serve as an unintentional “tip of the hat” to the merits of the plaintiffs’ case. Accordingly, as long as the case is not frivolous, the court must assume standing and address the merits of the case separately. Given previous litigation in the state regarding denial of equal access to educational benefits as well as a review of the current allegations, the court found that the complaint was not frivolous. The state also argued that the suit is a violation of the Tax Injunction Act which prohibits federal courts from taking action challenging state taxation. However, given the U.S. Supreme Court’s ruling in Hibbs v. Winn, 548 U.S. 88 (2004), the court rejected that argument as well. In Hibbs, taxpayers launched a challenge against a tax credit used in support of private schools. The Hibbs plaintiffs were neither attempting to reduce their own tax liability nor stop the state from collecting taxes. The Supreme Court distinguished between suits brought to avoid paying taxes from suits which merely challenged the constitutionality of certain provisions of the tax code. The court here noted that the student plaintiffs were not trying to avoid the payment of taxes, but rather were challenging the constitutionality of Alabama’s tax code. Lastly, the state argued that the doctrine of “comity” barred the federal court from hearing this matter. Comity is a principle that, under the facts here, would discourage the federal court from ruling on the merits of the state tax system until the state courts have had an opportunity to do so. However, the court rejected this argument as well, noting that comity was a principle, not a jurisdictional mandate. The trial of this case is October 2009.
Title IX / Deliberate Indifference
J.R. v. Pike County Board of Education, 2008 WL 2438664 (M.D.Ala. June 13, 2008)
Because this case provides a near roadmap on how to properly conduct an investigation, a full explanation of the facts is provided. J.R. was a special education student at Pike County High School who was diagnosed as mentally retarded. School administrators investigated various allegations lodged against the school’s band teacher between 2004 and 2005. Specifically, he was accused of driving students in his private car against board policy, allowing a student to use his cell phone, smoking on campus, and on one occasion, choking a student. A parent also reported that the teacher may have offered students marijuana. This allegation was investigated and he was warned about his conduct. Each incident that was reported to the principal was investigated or otherwise handled within the school and then reported to the superintendent. In March 2005, the superintendent received word from a local police officer that the teacher had smoked marijuana with students in his car. He gave the superintendent the names of several students who may have been involved. J.R. was not one of them. The police officer also told the Superintendent that there was rumor that one of the teacher’s students was his “butt buddy.” The teacher was immediately placed on administrative leave while school officials investigated the police officer’s allegations and also attempted to determine if he was engaging in any other inappropriate conduct. The superintendent wanted three questions investigated: (1) did the teacher use marijuana, (2) who was his “butt buddy,” and (3) was there any other inappropriate conduct, sexual or not, involving any student. The superintendent ordered the teacher to undergo a drug test, which came back negative. He made a list of students to question regarding the teacher’s behavior which included the five students named by the police officer and two other students that were involved in prior incidents. School administrators talked with each student about the teacher’s behavior, specifically including the marijuana use and the connotation of the “butt buddy” reference. As to the possible “butt buddy,” the administrators could neither determine what student was being referred to nor whether or not the term had a sexual connotation. When the administrators inquired further, the context the students used the term in indicated that the term meant his “favorite” or “teacher’s pet.” The administrators did not refer specifically to any possible sexual misconduct, but asked generally about inappropriate conduct. They opted not to ask about inappropriate touching directly so as not to lead the students. No allegations of sexual misconduct were made during the course of this investigation and no allegations were made by or related to J.R., nor did his name surface during the course of the investigation.
Following the investigation, the superintendent discussed the results with the reporting police officer as well as the police chief. They all agreed that the investigation had not yielded enough information to take any further action and that the teacher could return to work. The superintendent reprimanded him in writing for smoking and permitting students to ride in his car. He also advised him that, while law enforcement had been advised of the allegations, the school’s investigation was effectively closed barring further information.
Following the teacher’s return to school, J.R. broke a window in the band room after other students held the door shut and refused to let him out. During the investigation of this incident, the principal learned that J.R. had called the teacher on his cell phone from the room. No allegations of possible sexual abuse were made during the investigation of this incident. One month later, the teacher retired.
Shortly after his retirement, a student filed a criminal complaint against the teacher with the police department. He was arrested soon thereafter on charges related to the complaining student and another student whose name arose during the criminal investigation. Following his arrest, the police contacted the child advocacy center and asked the director to interview J.R. J.R. told the director that the teacher had sodomized him in the band room and in J.R.’s home during the 2004-2005 school year. However, when J.R. was interviewed by the police, while he admitted to some inappropriate touching over the clothes, he would not admit to any sodomy. The teacher was subsequently charged with sexual abuse of J.R. occurring in June 2005 after he had retired. School officials had no knowledge of the abuse or any allegations of abuse until he was arrested in July 2005.
J.R. sued the board, superintendent, principal and assistant principal for (1) violating his right to equal protection; (2) failing to have a policy and training to specifically protect special education students from harm pursuant to §1983; (3) discriminating against him because of his disability pursuant to §504; (4) acting with deliberate indifference and failing to act when it should have known about the teacher’s abuse pursuant to Title IX; (5) negligence for violating the mandatory reporting statute; and (6) wantonness. While J.R. did not claim that the administrators were actually aware of the abuse, he claimed that given the teacher’s violations of policy and procedure and the call from the police officer regarding the marijuana, they should have been aware that he may have been molesting a student.
In a lengthy opinion, the court found that the actions taken by the school officials were reasonable and appropriate given the information they had. The teacher was immediately placed on leave and the officials interviewed not only the students mentioned by the police officer, but students involved in prior incidents. The superintendent was cooperative and shared his information with law enforcement. The court specifically found that these acts were not deliberately indifferent as required to find a §1983 or Title IX violation. As to the lack of policies and training to specifically protect special education students, the court found that employees were trained on sexual abuse, but that no school system in Alabama had a special policy specifically related to special education students. Further, as there had been no prior incidents of sexual abuse, the board was not on notice that such a policy was necessary. Therefore, the board’s policies and practices were reasonable. As to the individual school officials, the court noted that they could not be held liable for the teacher’s actions unless they personally participated in the abuse or somehow caused the abuse by their action or inaction. J.R. could show a causal connection in only two ways: (1) that there was a “history of widespread abuse” that the officials failed to correct, or (2) that the officials maintained a custom or policy which resulted in the abuse. Here, there was no history of abuse as to this teacher or any other teacher. Further, there was no custom or policy (or any lack thereof) that resulted in his abuse of J.R.
As to the §504 claims, J.R. was required to prove that the officials acted in bad faith or with gross misjudgment. The court found no such evidence here where the officials appropriately investigated the allegations given the information reported to them. Further, no board policy could have protected J.R. when officials had no cause to be suspicious of the teacher’s conduct in that regard. As to the remaining claims of negligence and wantonness, the court similarly found that the officials acted appropriately under the circumstances. Therefore, all counts were dismissed as to the school officials.
Editor’s note: J.R. also sued the teacher, but because he did not answer the suit, default judgment was entered against him. In August 2008, he was ordered to pay nearly $220,000 in compensatory damages, nearly $660,000 in punitive damages and nearly $30,000 in attorneys’ fees. The teacher, who served approximately 18 months in prison and is now a registered sex offender, did not appeal this near-million dollar judgment.
Attorney General’s Opinions
Open Records Act / Fees
A.G. No. 2009-076 (June 10, 2009)
This opinion was requested by the Sumter County Probate Judge. First, he asked whether his office could charge the regular copy fee if a citizen used his personal camera or other electronic device to copy a public record. In the event the Attorney General determines that no fee may be collected under such circumstances, he asked if he had the authority to prohibit the use of such devices to copy public records. The Attorney General answered both questions in the negative. As to the first question, the Attorney General determined that no fee can be charged for the actual copies made by the citizen’s personal electronic devices; however, a fee can be charged for retrieving the information, but only if a cost can be properly attributed thereto. However, that information retrieval fee must be charged to all citizens irrespective of their method of copying. His opinion was based on previous Attorney General opinions, which concluded that reasonable fees could be assessed for copying public records. The term “reasonable fee” has been previously defined as the actual cost of providing the information. The fee should never be charged in an effort to restrict public access.
As to the second question, the Attorney General noted that neither Alabama state or federal courts have ruled on whether public officials can restrict use of such devices for making copies. However, he noted that a court in Illinois found such devices proper describing the technology as “accurate, harmless, noiseless and time saving.” He also noted that the Alabama Supreme Court has determined that the Open Records Act is to be liberally construed in favor of the public in Water Works & Sewer Bd. of City of Talladega v. Consol. Pub., Inc., 892 So.2d 859, 862 (Ala. 2004). Based on that rationale, while officials may place reasonable limitations upon the public’s access to and copying of records, as long as the technology does not interfere with office operations, it should not be abridged.
Majority Vote
A.G. No. 2009-082 (June 23, 2009)
Ala. Code §16-8-4 requires any motion or resolution be passed by a majority of the whole board. The Attorney General noted that statutory construction requires the word “majority” be given its plain meaning unless otherwise specified. Accordingly, motions and resolutions must be approved by a simple majority of votes, or half plus one. The Geneva County Board of Education received settlement funds as a result of litigation. Because some members of the board wanted to prevent the use of those funds for ordinary operating expenses, they asked whether they could require more than a majority vote of the board before those funds are spent. For this five-member board, this would require an affirmative vote of four of the five members or a super-majority. The Attorney General determined that, because the board is limited by statute, it cannot require a super-majority to pass any motion or resolution. Further, the Attorney General noted that to pass any motion or resolution, a majority of the whole board must vote in favor of the motion, not just a majority of the members who happen to be present for the vote. Therefore, if only a quorum were present for a particular vote – here, 3 members – the vote of the members present would have to be unanimous to pass the motion or resolution.
Funding
A.G. No. 2009-083 (June 23, 2009)
The Secure Rural Schools and Community Self-Determination Act of 2000 is a federal statute which provides state governments with funds derived from national forests within their borders. Ala. Code §9-13-2 sets forth the framework used by Alabama’s government to distribute those funds to the counties housing those forests. That statute requires the subject county commission to pay half the funds to the “public schools of such county” and to use the other half for public roads within the county. The Covington County Commission distributes these funds to Covington County Schools, but does not give funds to Opp City or Andalusia City Schools. The Opp school officials sought an opinion as to whether the system is entitled to a portion of the funds; that is, are all boards of education located in a particular county, whether a city or county board, entitled to funds under the statute. Because the rules of statutory construction require words to be given their plain meaning, the Attorney General found the phrase “public schools of such county” to mean “county boards of education.” The Attorney General found that to expand that unambiguous language beyond its plain meaning would violate the rules of statutory construction. Therefore, city boards of education are not entitled to funds gained by the act.
Salaries
A.G. No. 2009-087 (June 30, 2009)
Since 1994, pay increases for local school CNP employees have been funded by the State Department of Education. In 2008, the department decided that while the state will continue to fund fringe benefit expenses, they will no longer fund those legislatively mandated pay raises enacted prior to the 2001-2002 fiscal year. Rather, the raises will be paid from the local school cafeteria’s operating funds. The Attorney General was asked whether the department could arbitrarily change the method by which these raises are funded and whether A.G. Opinion No. 95-00003, which determined that Ala. Code §16-22-11 required raises to be funded by the state, not cafeteria funds, was controlling. The answer was that A.G. Op. No. 95-00003 was controlling and that local cafeteria funds could not be used to fund CNP employee raises. After reviewing the varying language of the pay raise statutes, the Attorney General found that the clear intent of the Legislature was for CNP employee raises to be funded by the state, not by local cafeteria funds. In particular, it was noted that raises were to be funded by the Foundation Program through the “other current expense” category.
Classroom Supplies
A.G. No. 2009-095 (Jul. 28, 2009)
A teacher certified by the National Board for Professional Teaching Standards received a monetary bonus to purchase classroom supplies, materials and/or equipment. The teacher is planning to retire and wishes to take some of those items with her. The employing school board asked whether this was permissible. The Attorney General said it was not permissible citing the state Department of Education policies which state “[i]f a teacher retires or leaves employment at an Alabama school system, he/she cannot take any of the items purchased with him/her.” The opinion also noted that, because the bonus constitutes an expenditure of public funds, it is subject to the provision of Alabama’s Constitution which prohibits public funds from being expended for private purposes.
-— Jayne Harrell Williams
Jayne is with the law firm of Hill, Hill, Carter, Franco, Cole & Black in Montgomery, Ala.
info@alabamaschoolboards.org
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