Articles Posted in Education Law

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At issue in this case was the correct statutory interpretation of the manner in which state education aid funds received by the Bristol Warren Regional School District (the district) should be calculated and apportioned to the towns of Bristol and Warren. The superior court granted Warren’s petition for writ of mandamus, injunctive relief, and a complaint for summary judgment. The Supreme Court affirmed, holding that the superior court (1) did not err when it failed to bar Warren’s claims pursuant to the doctrine of res judicata; (2) did not err by declining to dismiss the action because other school districts had not been joined; (3) did not err when it did not give full deference to the Rhode Island Department of Education’s interpretation of the statutory framework concerning the proper manner of calculating and allocating state aid to regional school districts; and (4) did not misinterpret the governing statutory scheme or ignore the statutory definition of “community” as it applies to funding the district. View "Town of Warren v. Bristol Warren Regional School District" on Justia Law

Posted in: Education Law

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Plaintiff, an attorney employed as a hearing officer for the Rhode Island Department of Elementary and Secondary Education (RIDE), filed a complaint alleging that RIDE and the Rhode Island Board Counsel on Elementary and Secondary Education (collectively, Defendants) violated the Open Meetings Act (OMA) by failing to provide adequate notice of a September 2014 council meeting and by failing to provide any notice of meetings held by the Compensation Review Committee (CRC). The superior court entered summary judgment in favor of Defendants. The Supreme Court reversed in part and affirmed in part, holding (1) Defendants violated the OMA by failing to provide adequate notice of the September 2014 meeting; and (2) the CRC is not a public body and, therefore, is not subject to the OMA. View "Pontarelli v. Rhode Island Board Council on Elementary and Secondary Education" on Justia Law

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After unsuccessfully seeking reimbursement from the State Commissioner of Elementary and Secondary Education, Plaintiffs, a school district and school department, filed a complaint in the superior court alleging that the Commissioner and State Treasurer were required to reimburse them for the salary, fringe benefits, and travel expenses of the directors and guidance counselors in their vocational-technical programs. The superior court dismissed the complaint, concluding that Plaintiffs had an adequate remedy at law and that the Commissioner’s decision to deny Plaintiffs reimbursement was discretionary in nature, rather than ministerial. Plaintiffs subsequently sought a writ of mandamus. The Supreme Court affirmed the judgment of the superior court, holding that Plaintiffs did not have a clear legal right to be reimbursed for certain costs associated with the operation of their career and technical centers. View "Chariho Reg’l Sch. Dist. v. Gist" on Justia Law

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David Alba was appointed to serve as principal of an elementary school in Cranston, Rhode Island. Alba and the Cranston School Committee subsequently entered into an employment contract. Later, after a hearing, the Committee rejected a recommendation to renew Alba’s employment contract. Alba appealed the Committee’s decision. The Commissioner of Education denied and dismissed Alba’s appeal, concluding that Alba had received all the process to which he was entitled under the contract and the School Administrators’ Rights Act. The Board of Regents affirmed the Commissioner’s decision. The Supreme Court affirmed, holding (1) the Committee acted within its authority when it voted against the recommendation to renew Alba’s contract; and (2) the Committee’s nonrenewal of Alba’s contract did not deprive Alba of his rights under the Administrators’ Rights Act. View "Alba v. Cranston Sch. Comm." on Justia Law

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Plaintiffs, school committees of Woonsocket and Pawtucket and unnamed students, parents, and the superintendents from both districts, brought suit against the legislative and executive branches of Rhode Island’s state government challenging the state’s school funding formula. Specifically, Plaintiffs alleged violations of the Education Clause as well as violations of their substantive due process and equal protection rights because the formula failed to allocate adequate resources to less affluent communities. The superior court granted Defendant’s motion to dismiss the complaint. The Supreme Court affirmed, holding (1) prior case law as well as the separation of powers doctrine warranted dismissal of Plaintiffs’ Education Clause claim; and (2) Plaintiffs’ complaint was insufficient to establish potential substantive due process claims. View "Woonsocket Sch. Comm. v. Chafee " on Justia Law

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Plaintiffs in this case included fifteen minor children and their parents who participated in the family court's truancy court diversion calendar program. The diversion program allowed family court magistrates to conduct court sessions at public schools where truancy had become an issue. Plaintiffs brought an action against the judicial officials who were sitting in the truancy court, family court administrators, and five municipalities. Plaintiffs requested that the superior court declare the previous procedures in the truancy court to be unconstitutional and enjoin the family court from enforcing the prior procedures. The superior court denied Defendants' motions to dismiss under Sup. Ct. R. Civ. P. 12(b)(1). The Supreme Court quashed the superior court's order denying Defendants' motions to dismiss, holding that Plaintiffs' claims were moot, as (1) Plaintiffs' constitutional challenges were obviated by an administrative order that reformed the truancy program and by existing law; and (2) there were no ongoing truancy petitions that continued to be affected by the earlier court procedures. View "Boyer v. Bedrosian" on Justia Law

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Plaintiff, who was employed as a school bus driver, broadcasted that the bus she was driving, which was full of elementary-school children, had been struck by gunfire and that panic had spread among the children. Displeased with the manner in which Plaintiff handled the situation, the Town of Johnson school department requested that Plaintiff no longer be assigned to transport Johnson students. Eventually, Plaintiff left her employment. Plaintiff subsequently filed suit for wrongful termination against members of the Johnson public schools (Defendants), alleging that Defendants wrongfully requested that Plaintiff be terminated from her employment. In response to the trial justice's remarks, Plaintiff moved to amend her complaint to include a claim of tortious interference, which the trial justice denied. Thereafter, the superior court granted summary judgment against Plaintiff. The Supreme Court vacated the judgment of the superior court, holding that the court abused its discretion in denying Plaintiff's motion to amend her complaint without specific findings. Remanded. View "Lomastro v. Iacovelli" on Justia Law

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Plaintiffs brought suit against Defendant, the Cranston School Department, seeking grievance arbitration of adverse actions taken against them as to their respective coaching positions at Cranston West High School. Plaintiffs, both of whom were teachers at Cranston West, separately filed grievances against Defendant in accordance with the collective bargaining agreement (CBA) that was in place between the Cranston Teacher's Alliance and the school department. Defendant responded that the CBA did not apply to Plaintiffs in their capacity as coaches, and it refused to submit to arbitration. Plaintiffs filed suit, seeking a declaratory judgment that they were entitled to binding arbitration as guaranteed by the CBA. The superior court ruled in favor of Defendant, determining that Plaintiffs, in their capacity as coaches, were not entitled to avail themselves of the CBA's grievance procedures. The Supreme Court affirmed, holding (1) the trial justice was correct in determining that Plaintiffs' coaching positions were contractually distinct from their teaching positions and did not constitute professional employment; and (2) Plaintiffs in their coaching capacities had no right to pursue relief based on the rights bargained for by the alliance on behalf of its teacher-members and as contained in the CBA. View "Sacco v. Cranston Sch. Dep't" on Justia Law

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In a financial dispute between two charter schools and a local school district about how the local share of the charter school tuition reimbursement should be computed, the commissioner of elementary and secondary education directed that enrollment during the reference year, or 2008, be used to calculate the district's share. The board of regents reversed, interpreting the Charter Public School Act of Rhode Island to mean that the district must pay sums due to charter schools using as a computational basis the current fiscal year, or 2010. The Supreme Court upheld the board's decision, holding that the statute is subject to more than one reasonable interpretation, and the board's determination was not clearly erroneous. The Court also found that the board did not err when it affirmed the commissioner's decision to sever the district's asserted defense of unclean hands and treat it as a counterclaim. View "Kingston Hill Academy and The Compass Sch. v. Chariho Reg'l Sch. Dist." on Justia Law