Justia Connecticut Supreme Court Opinion SummariesArticles Posted in Education Law
Graham v. Friedlander
The Supreme Court affirmed the judgment of the trial court denying certain defendants' motion to dismiss Plaintiffs' complaint, holding that Defendants were not entitled to sovereign immunity.Plaintiffs, the parents of four school-age children diagnosed with autism spectrum disorder, brought this action seeking judgment from the City of Norwalk's Board of Education and three of its members. Plaintiffs alleged that the negligent hiring and supervision of Stacy Lore, who was hired to provide autism related services to children in the school district, proximately caused them to suffer permanent and ongoing injuries and losses. The Board filed a motion to dismiss for lack of jurisdiction and, in the alternative, claiming that the doctrine of sovereign immunity mandated dismissal of the claims. The trial court granted the motion to dismiss on the ground that Plaintiffs had failed to exhaust their administrative remedies. The Supreme Court affirmed but on other grounds, holding (1) the trial court improperly dismissed this action on the ground that Plaintiffs had not exhausted their administrative remedies; and (2) the Board and its members were not entitled to sovereign immunity because they were acting under the control of, and as an agent of, the municipality rather than the state. View "Graham v. Friedlander" on Justia Law
Osborn v. Waterbury
The Supreme Court reversed the judgment of the Appellate Court reversing the judgment of the trial court after concluding that expert testimony was necessary to establish the standard of care in this negligence action, holding that, under the facts of this case, expert testimony was not necessary.Plaintiffs, a minor child, by and through her mother, alleged that the City of Waterbury and the Waterbury Board of Education were negligent for injuries sustained by the child during recess at a Waterbury public school. The trial court rendered judgment in favor of Plaintiffs. The Appellate Court reversed, concluding that the trial court improperly found in the absence of expert testimony that Defendants breached their duty of care to the child on the basis that there was an inadequate number of adults on the playground to supervise the students at the time the child was injured. The Supreme Court reversed, holding that the fact finder here did not need to apply scientific or specialized knowledge to determine whether Defendants adequately supervised the children in this case. View "Osborn v. Waterbury" on Justia Law
Martinez v. New Haven
At issue was whether the trial court erred in determining that Plaintiff proved the imminent harm to identifiable persons exception to the defense of governmental immunity with respect to injuries he sustained when other students ran with a pair of scissors in the auditorium of his school.Plaintiff filed suit against the City of New Haven, the Board of Education of the City of New Haven, and the Superintendent of New Haven Public Schools seeking damages for, inter alia, negligent supervision of students. The trial court found in favor of Plaintiff on his negligent supervision claim. The Supreme Court reversed in part the judgment of the trial court, holding (1) Plaintiff failed to prove that Defendants’ conduct subjected an identifiable person to imminent harm; and (2) the trial court implicitly granted Defendants’ request to amend their answer to plead governmental immunity as a special defense. View "Martinez v. New Haven" on Justia Law
Connecticut Coalition for Justice in Education, Inc. v. Rell
The trial court did not err in determining that Plaintiffs failed to establish that the state’s educational offerings are not minimally adequate under Conn. Const. art. VIII, 1.Plaintiffs brought this action seeking, inter alia, a declaratory judgment that various state officials and members of the State Board of Education failed to provide “suitable and substantially equal educational opportunities” in violation of Conn. Const. art. VIII, 1 and Conn. Const. art. I, 1 and 20, as amended by articles five and twenty-one of the amendments. The trial court concluded that the state’s educational policies and spending practices violate article eighth, section one and rejected Plaintiffs’ remaining arguments. The Supreme Court affirmed in part and reversed in part, holding that Plaintiffs failed to establish that Defendants violated Plaintiffs’ rights under article eighth, section one and article first, sections one and twenty. View "Connecticut Coalition for Justice in Education, Inc. v. Rell" on Justia Law
Gould v. Freedom of Info. Comm’n
The parties in this case - a board of education and an education association - proceeded to arbitration on a dispute. The parties proceeded on a three member arbitration panel. When a journalist with a newspaper sought to cover the arbitration proceedings, the panel adjourned to what it designated an executive session, closed to the public. The journalist and newspaper (together, Defendants) filed a complaint with the Freedom of Information Commission, claiming that the panel violated the open meetings provision of the Freedom of Information Act (FOIA). The Commission ordered the members of the arbitration panel and the Department to create a transcript of the hearing and provide that transcript to Defendants, concluding that the arbitration panel was a committee of the Department of Education and that the evidentiary portion of the arbitration proceeding under the Teacher Negotiation Act (TNA) was subject to the open meetings provision of the FOIA. The Supreme Court reversed, holding that because a TNA arbitration panel is not a “committee of” the Department, it does not constitute a “public agency.” View "Gould v. Freedom of Info. Comm’n" on Justia Law
Frank v. Dep’t of Children & Families
After a hearing, the Department of Children and Families substantiated allegations that Plaintiff, an elementary school teacher, emotionally abused one of his students and recommended that Plaintiff’s name be placed on the Department’s central registry of child abuse and neglect. The trial court affirmed, ruling that the ultimate finding of the administrative hearing officer was supported by substantial evidence. The Appellate Court reversed and ordered the Department to remove Plaintiff’s name from the central registry. The Supreme Court reversed, holding that the Appellate Court (1) failed properly to credit the factual findings and legal conclusions of the administrative hearing officer; and (2) improperly concluded that the definition of “abused” found in Conn. Gen. Stat. 46b-120(3) was void for vagueness as applied to the facts of this case. View "Frank v. Dep’t of Children & Families" on Justia Law
Lopez v. Bd. of Educ.
Defendant was selected by the City of Bridgeport Board of Education to serve as its acting superintendent of schools. Because Defendant was not certified as a school superintendent in Connecticut, Defendant completed an independent study course, and the Commissioner of Education granted a waiver of certification for Defendant pursuant to Conn. Gen. Stat. 10-157(b). Plaintiffs sought a writ of quo warranto that would remove Defendant from his office as acting superintendent. The trial court rendered judgment in favor of Plaintiffs, concluding that because Defendant did not complete a school leadership program required by section 10-157(b), he was not entitled to a waiver of certification. Defendant appealed. The Supreme Court reversed, holding that a quo warranto action may not be utilized to avoid that administrative process by mounting a collateral attack on an administrative agency's decision to issue a waiver that renders a public officer qualified to hold his position. Remanded.View "Lopez v. Bd. of Educ." on Justia Law
Perez-Dickson v. City of Bridgeport
Plaintiff Carmen Perez-Dickson brought this action claiming that Defendants, the city board of education, the former assistant superintendent of the school district, and the former acting superintendent of the school district, disciplined her for exercising her right to free speech protected by the state and federal Constitutions in violation of Conn. Gen. Stat. 31-51q and 17a-101e, discriminated against her on the basis of her race, and intentionally caused her severe emotional distress. The jury returned a verdict in favor of Plaintiff on all counts. The Supreme Court reversed, holding (1) Defendants did not violate section 31-51q because any relevant speech by Plaintiff had been pursuant to her official job duties and such speech is not protected by the First Amendment; (2) Plaintiff failed to prove her claim of racial discrimination; and (3) Plaintiff failed to prove that Defendants had intentionally inflicted severe emotional distress on her. Remanded with direction to render judgment for Defendants. View "Perez-Dickson v. City of Bridgeport" on Justia Law
Pereira v. State Bd. of Educ.
The local board of education of the City of Bridgeport passed a resolution requesting the state board of education to authorize the commissioner of education to reconstitute the local board. The state board voted to authorize the commissioner to reconstitute the local board. In three separate actions, former local board members and residents and electors of the City filed actions against the state board, local board, and others, alleging state statutory and constitutional violations. The trial court reserved the action for the advice of the Supreme Court. At issue was (1) whether the failure of the state board to require the local board to undergo and complete training, as mandated by Conn. Gen. Stat. 10-223e(h), rendered void the state board's authorization; and (2) whether the local board's resolution requesting that the state board authorize reconstitution resulted in a waiver of the state board's obligation to require training. The Supreme Court concluded (1) the state board's failure to require training rendered void its authorization of reconstitution under section 10-223e(h); and (2) the local board's resolution had no effect on the operation of the statute. View "Pereira v. State Bd. of Educ." on Justia Law
Coe, et al. v. Board of Education
Plaintiffs sued defendants, the board of education of the town of Watertown ("board"), the town of Watertown ("town"), and two teachers employed by the board, claiming that, as a result of defendants' negligence, one plaintiff severely injured her foot at a school dance sponsored by the board. At issue was whether the trial court improperly granted defendants' motion to strike the claims on the grounds that negligence claims against the town and board were barred by the doctrine of governmental immunity and did not come within the scope of the statutory waiver of government immunity set forth in General Statutes 52-557n; that the claims against the two teachers were barred because section 52-557n did not create a cause of action against individual municipal employees; and that, in the absence of a common law negligence claim against the teachers, there was no basis for an indemnification claim pursuant to General Statutes 7-465. The court held that the trial court properly granted defendants' motion to strike count one as to the town and the board because they were immune from suit pursuant to 52-557n(a)(2)(B) and properly determined that section 52-557n did not authorize suit against individual government employees. The court also held that the trial court improperly granted the motion to strike the first count of the complaint as to the two teachers and the entire second count seeking payment from the town and the board pursuant to section 7-465 on the ground that plaintiffs had not alleged common law negligence against the teachers. The court further held that the trial court's ruling could be affirmed on the alternate ground that the teachers were immune from liability under the doctrine of qualified immunity. Accordingly, the judgment was affirmed.