Justia Missouri Supreme Court Opinion Summaries

Articles Posted in Education Law
by
The Supreme Court vacated the judgment of the circuit court reversing the decision of the Board of Education of the Jefferson City Public School District to terminate Tammy Ferry's contract with the District, holding that the Board had the authority to terminate the contract.The Board decided to terminate Ferry's contract after she transferred confidential student information from the District's Google for Education account to her personal Google account. The circuit court vacated the Board's decision, finding that Ferry had not "disclosed" confidential student information, as that term is defined in the Family Educational Rights and Privacy Act of 1974 (FERA), 20 U.S.C. 1232g. The Supreme Court vacated the circuit court's judgment, holding (1) the Board's findings that Ferry violated the Board's policies and procedure and did so willfully were supported by competent and substantial evidence; and (2) the Teacher Tenure Act authorized the Board to terminate Ferry's indefinite contract with the District. View "Ferry v. Board of Education of Jefferson City Public School District" on Justia Law

by
The Supreme Court held that Missouri's Legal Expense Fund had no obligation to satisfy a default judgment against Allen Merry, an employee of the St. Louis Public School District.S.M.H., a student in the Transitional School District of the City of St. Louis, sued Merry, a former teacher, and obtained a default judgment against him for $4 million. Because the Transitional School District had lost its state accreditation, the Special Administrative Board (Board) of the Transitional School District governed the district and employed Merry. S.M.H. subsequently filed a declaratory judgment action seeking satisfaction of the judgment from the Legal Expense Fund. The circuit court granted summary judgment for S.M.H. The Supreme Court reversed, holding (1) the Board was not an "agency of the state" for purposes of the Legal Expense Fund, and therefore, the Fund was not liable for damages against employees of the Transitional School District; and (2) S.M.H. was not entitled to judgment as a matter of law. View "S.M.H v. Schmitt" on Justia Law

by
The Supreme Court made permanent a preliminary writ of prohibition it issued barring the circuit court from taking any further action other than to vacate an order overruling Relator's motion for summary judgment and to enter judgment for Relator, holding that Relator was entitled to official immunity.Israel Mariano, a student at Independence Academy, filed a negligence suit against Relator, an in-school suspension teacher, in his individual capacity for injuries Mariano sustained when Relator physically restrained him and broke his arm. The circuit court overruled Relator's motion summary judgment claiming he was entitled to official immunity. Relator sought a writ of prohibition. The Supreme Court granted the writ, holding that Relator was entitled to official immunity under the circumstances of this case. View "State ex rel. Alsup v. Honorable James F. Kanatzar" on Justia Law

by
The Supreme Court vacated the judgment of the circuit court dismissing with prejudice R.M.A.’s petition alleging that Defendants, a school district and school board, unlawfully discriminated against him on the grounds of his sex in violation of the Missouri Human Rights Act (MHRA), Mo. Rev. Stat. 213.065, holding that R.M.A.’s petition alleged facts that, if taken as true, established the elements of a claim under section 213.065.R.M.A. filed suit alleging that his “legal sex is male” and that, by denying him access to the boys’ restrooms and locker rooms, Defendants discriminated against him in the use of a public accommodation “on the grounds of his sex.” The circuit court dismissed the complaint for failure to state a claim upon which relief could be granted. The Supreme Court vacated the judgment below and remanded the case to the circuit court for further proceedings, holding that R.M.A. stated a claim under section 213.065.2. View "R.M.A. v. Blue Springs R-IV School District" on Justia Law

by
Byrne & Jones Enterprises, Inc. filed an action against Monroe City R-1 School District alleging that it was denied a fair and equal opportunity to compete in the bidding process for a public works contract to build an athletics stadium. The trial court dismissed the petition, concluding that Byrne & Jones, as an unsuccessful bidder, lacked standing to challenge the school district’s award of the contract to another bidder because it did not bring the action in the interest of the public or as a taxpayer. The Supreme Court affirmed, holding (1) Byrne & Jones had standing to challenge the award of the contract to another bidder; but (2) the trial court did not err in dismissing the petition because Byrne & Jones was not entitled to the relief requested in the petition. View "Byrne & Jones Enters., Inc. v. Monroe City R-1 Sch. Dist." on Justia Law

by
In 2011, the State Board of Education voted to classify the Kansas City Public Schools (KCPS) district as "unaccredited", which required accredited school districts to accept transfer of KCPS's students pursuant to Mo. Rev. Stat. 167.131. Taxpayers in five accredited school districts filed this action against KCPS and the State, asserting that section 167.131 violates the Hancock Amendment to the Missouri Constitution because it mandates that, in educating the transfer students, the school districts perform a new or increased level of activity. The trial court (1) concluded that the statute mandates a new activity but found that to violate the Hancock Amendment the activity must result in increased costs; and (2) entered judgment in favor of three school district taxpayers and against two school district taxpayers. While the case was pending on appeal, the Supreme Court issued Breitenfeld v. School District of Clayton, which held that section 167.131 merely reallocates responsibilities for educating students among districts, which the Hancock Amendment does not prohibit. The Supreme Court affirmed in part and reversed in part based on Breitenfeld, holding that section 167.131 does not mandate a new or increased level of activity but merely reallocates responsibilities among school districts. View "Blue Springs R-IV Sch. Dist. v. Sch. Dist. of Kansas City" on Justia Law

by
After the St. Louis Public School District (SLPS) became unaccredited in 2007 and was operated by the Transitional School District of St. Louis, some parents sought to have their children obtain Mo. Rev. Stat. 167.131 transfers that would enable the children to attend school in the Clayton school district. The parents (Plaintiffs) also requested that the transitional school district pay for their children's education in Clayton. The trial court held in favor of the school districts (Defendants). The Supreme Court reversed, holding that section 167.131, the "Unaccredited District Tuition Statute," was applicable to the transitional school district and required that it pay Plaintiffs' children's tuition costs for attending Clayton. On remand, the trial court allowed taxpayers from Clayton and SLPS to intervene. The trial court found in favor of Defendants, holding that section 167.131 was unenforceable as applied to Defendants because (1) it violated the Hancock Amendment of the Missouri Constitution, and (2) Defendants' compliance with the statute was impossible. The Supreme Court reversed, holding (1) section 167.131, as applied to Defendants, did not violate the Hancock Amendment; and (2) the trial court erred in finding it would be impossible for Defendants to comply with the requirements of the statute. Remanded. View "Breitenfeld v. Sch. Dist. of Clayton" on Justia Law

by
The American Federation of Teachers, its St. Louis affiliate, and individual representatives appealed the trial court's summary judgment declaring that the board of education of the Construction Career Center Charter School District and the individual members of the board had no duty to "meet and confer" or to bargain collectively in good faith with the union. The Supreme Court reversed, holding that because Mo. Const. art. I, 29 provides that all employees, public and private, have a right to organize and to bargain collectively, it necessarily requires the board to meet and confer with the union, in good faith, with the present intention to reach an agreement. Remanded. View "Am. Fed'n of Teachers v. Ledbetter" on Justia Law

by
The City of St. Louis appealed the trial court's holding that the prohibition against special laws contained in Mo. Const. art. III, 40 was not violated by Mo. Rev. Stat. 320.097. That statute exempted certain veteran firefighters who lived in areas with unaccredited or provisionally accredited school districts from any local laws requiring them to live in their home district. The State also appealed, alleging (1) the trial court erred in holding that section 320.097 violated what the trial court believed was the "broad measure of complete freedom from State legislative control" given to constitutional charter cities by the Missouri Constitution, and (2) the trial court erred in holding that the statute violated the equal protection clauses of the Missouri and U.S. constitutions because it was not rationally related to any legitimate purpose. The Supreme Court (1) affirmed the trial court's holding that the statue was not a special law in violation of the Missouri Constitution; (2) reversed the trial court's holding that the statute violated the state constitution because it interfered with the City's right to set its employees' and officers' powers, duties and compensation; and (3) reversed the trial court's holding that the statute violated equal protection guarantees. View "City of St. Louis v. State" on Justia Law

by
Jordan Danielle King-Willmann filed a petition seeking a writ of mandamus requiring the Webster Groves school district to enroll her in the district pursuant to Mo. Rev. Stat. 167.131.2. The school district contested certain material facts alleged by King-Willmann and asserted several defenses, including a claimed violation of Mo. Const. art. X, sec. 21, the Hancock amendment. The school district requested an evidentiary hearing, which the trial court did not hold. The court issued the writ granting King-Willmann relief. The Supreme Court reversed the judgment and remanded because contested issues of fact existed. On remand, the Court instructed the trial court not to consider the Hancock amendment claim as the school district had no standing to bring such a claim. View "King-Willmann v. Webster Groves Sch. Dist." on Justia Law