FILTERS



Find by DATE
Reset

Latest Cases & Developments


  • Date:

    Whipper v. Green (D. Conn. July 1, 2024)

    Order denying Defendants’ Motions to Dismiss. Plaintiff, an inmate and student in the Wesleyan University Center for Prison Education (CPE) Program at Cheshire Correctional Institution, represented by court-appointed pro bono counsel, brought First Amendment retaliation claims against Department of Correction (DOC) officials and conspiracy to commit First Amendment retaliation claims against DOC officials and the University’s administrator for the CPE Program after he was removed from the program for refusing to sign a form related to rules of conduct for inmates. He alleged that the form was a way to implement “punitive practices against inmates in response to restrictions placed on DOC personnel by the passage of the Connecticut Protect Act” and that University volunteers disapproved of the requirement. Plaintiff also alleged that his transfer to a different facility for security concerns was pretextual to avoid a possible injunction. In permitting the First Amendment retaliation claim to proceed against the DOC defendants, the court found that (1) refusal to sign the form may be protected expressive activity and (2) plaintiff had also sufficiently alleged adverse actions and causal connection. In permitting the conspiracy claim to proceed against the University’s program administrator, it held that allegations that the administrator was aware of the plan to pressure inmates to sign the form and subsequently participated in removing plaintiff from the program were sufficient to allege that he had agreed to act in concert with the DOC Defendants, notwithstanding the University’s MOU granting the DOC unilateral authority to remove inmates from the program.

    Topics:

    Constitutional Issues | Discrimination, Accommodation, & Diversity | First Amendment & Free Speech | Retaliation

  • Date:

    Stoffel v. The Regents of Univ. of Cal. (Cal. App. June 25, 2024) (unpub.)

    Opinion vacating dismissal. Plaintiffs, students at various campuses of the University of California in Spring 2020, on behalf of themselves and a putative class, brought contract and related claims related to tuition and fees against the University after it ceased in-person instruction and closed campus facilities in March 2020 due to the coronavirus pandemic. The trial court dismissed the complaint for failure to allege a “specific promise” of an in-person, on-campus education. In vacating dismissal, the California Court of Appeals held that plaintiffs’ assertions about statements in various marketing materials was sufficient to allege an implied promise of in-person, on-campus education over the expected duration of a full degree, which was affirmed each academic session. It then found that the relevant time for determining if the implied promise had been accepted was at the time in February 2020 when students registered and paid tuition for Spring 2020, rather than the deadline to withdraw and receive a refund. It also found that the Regents’ express reservation of rights to set tuition levels was not sufficient to give the Regents authority to change the terms of an implied contract retroactively.   

    Topics:

    Campus Police, Safety, & Crisis Management | Coronavirus

  • Date:

    360 Degree Educ. v. U.S. Dep’t of Education (N.D. Tex. June 21, 2024)

    Memorandum Opinion & Order granting-in-part and denying-in-part Plaintiffs’ Motion for Preliminary Injunction. Plaintiffs, “a coalition of vocational schools with a member-program in Arlington, Texas,” challenged the Department of Education’s new maximum program length regulation, which provides that vocational programs may require no more than the minimum number of hours a state requires for licensure in a given field, alleging that (1) the Department exceeded its authority under the HEA and that the Rule violates the Administrative Procedure Act (APA) because it is arbitrary and capricious and was not a “logical outgrowth” of the Department’s Notice of Proposed Rulemaking (NPRM). The Rule would replace the Department’s “150% Rule,” which provides access to federal student aid up to 150% of the state’s required hours and does not entirely deny eligibility to programs exceeding this threshold. The court held plaintiffs were likely to succeed on the merits of their APA claims, finding that (1) the Department had not sufficiently explained either the grounds for “converting a program intended to be a safe-harbor into a strict-liability trap” or for altering the 150% rule after 30 years and (2) the NPRM did not signal that the Department “was considering removing one leg from the triad, accreditors, from the process entirely” by “imposing an absolute condition precedent to federal funds.” The court found, however, that plaintiffs failed to show that the proposed regulation “usurp[ed] authority traditionally reserved for states,” noting that courts have long recognized the federal government’s power to “regulate-by-incentivization.”   

    Topics:

    Accreditation, Authorizations, & Higher Education Act | Financial Aid, Scholarships, & Student Loans | Higher Education Act (HEA) | Students

  • Date:

    Koerner v. Mercer Univ. (M.D. Ga. June 21, 2024)

    Order granting Defendant’s Motion to Dismiss. Plaintiff, a student at Mercer University in Spring 2020, on behalf of herself and a putative class, brought contract and unjust enrichment claims against the University after it ceased in-person instruction and closed campus facilities due to the coronavirus pandemic. In dismissing plaintiff’s implied contract claim, the court found that the University catalog’s reservation of rights clause, which included the right “to change its rules affecting … the granting of credit or degrees,” together with its detailed emergency response plan, which provided for “academic or administrative space adjustments,” were sufficient to prevent the University from being held liable for the shift to remote instruction. It dismissed her unjust enrichment claim as precluded by her implied contract claim.  

    Topics:

    Campus Police, Safety, & Crisis Management | Coronavirus

  • Date:

    OCR Resolution Agreement with Brown University re: Title VI Compliance (July 8, 2024)

    Resolution Agreement between the U.S. Department of Education, Office for Civil Rights (OCR) and Brown University of Rhode Island resolving a complaint that it responded inadequately to alleged harassment based on shared Jewish ancestry. The associated Resolution Letter noted (1) additional incidents of alleged harassment based on shared Palestinian, Arab, and/or Muslim ancestry and (2) that the University had “begun implementing changes to its Title VI organizational structures, reporting processes, and resources” in support of newly adopted “key priorities.” Through the Agreement, the University agreed to make additional updates to its policies and procedures; provide training to all employees and students; engage in detailed record keeping, review, and reporting on its responses to complaints; and engage in continued analysis and action pursuant to a climate assessment it had already begun. 

    Topics:

    Discrimination, Accommodation, & Diversity | Race and National Origin Discrimination | Religious Discrimination & Accommodation

  • Date:

    U.S. Dep’t of Education Unified Regulatory Agenda for Spring 2024 (July 5, 2024)

    U.S. Department of Education Unified Regulatory Agenda for Spring 2024. Among its filings with the White House Office of Information and Regulatory Affairs (OIRA), the Department indicates plans for proposed rules (NPRMs) or Final Actions on the following timeline: for July 2024, NPRMs on Documentation of Foreign Source Gift and Contracts (Section117), Return to Title IV, Cash Management, and Distance Education; for September 2024, an NPRM on Student Debt Relief Hardship; for October 2024, Final Action on  Student Debt Relief and NPRMs on Cybersecurity Standards for Institutions of Higher Education and FERPA; for November 2024, NPRMs on Nondiscrimination on the Basis of Disability (Section 504 of the Rehabilitation Act), Accreditation and Related Issues, and State Authorization; for December 2024 NPRMs on Discrimination Based on Shared Ancestry or Ethnicity and Nondiscrimination on the Basis of Sex and Disability (Vocational Program Guidelines); for May 2025, Final Action on Public Service Loan Forgiveness (Employer Eligibility), and for June 2025, an NPRM on Third-Party Servicers and Related Issues. The Department moved its anticipated Final Action on Nondiscrimination on the Basis of Sex re: Sex-Related Eligibility Criteria for Male and Female Athletic Teams to the Long-Term Actions listing with an anticipated date of “To Be Determined.”   

    Topics:

    Accreditation, Authorizations, & Higher Education Act | Higher Education Act (HEA)

  • Date:

    U.S. Dep’t of Education Announcement re: Temporary Injunction on Program Length Regulations (July 3, 2024)

    U.S. Department of Education, Office of Federal Student Aid Announcement re: Temporary Injunction on Program Length Regulations. Noting the preliminary injunction from the Northern District of Texas on the July 1, 2024, on implementation of the maximum length of gainful employment (GE) programs, the Department announced that “until further notice” institutions must continue to comply with the existing regulations, which “limit the maximum program length of GE programs to 150 percent of a state’s minimum educational requirements for licensure, or 100 percent of the requirements of an adjacent state, whichever is greater.” 

    Topics:

    Accreditation, Authorizations, & Higher Education Act | Financial Aid, Scholarships, & Student Loans | Higher Education Act (HEA) | Students

  • Date:

    U.S. Dep’t of Education Fact Sheet re: Harassment Based on Race, Color or National Origin (July 2, 2024)

    U.S. Department of Education, Office for Civil Rights (OCR) Fact Sheet on Harassment Based on Race, Color, or National Origin on School Campuses. Noting that “OCR’s enforcement activities have demonstrated that discriminatory harassment of students based on their race, color, or national origin continues to be a concern on school campuses,” the Fact Sheet describes prohibited harassment, including harassment that creates a hostile environment, under Title VI and outlines schools’ response obligations. The Fact Sheet provides several hypothetical examples of factual allegations OCR might investigate to determine whether a hostile environment exists and whether a school has responded adequately to such information, as well as a list of additional related resources.  

    Topics:

    Discrimination, Accommodation, & Diversity | Race and National Origin Discrimination

  • Date:

    U.S. Dep’t of Education Notice of CIP Codes for Graduate Programs Eligible for Extended Earnings Measurement Period (June 28, 2024)

    U.S. Department of Education, Office of Postsecondary Education List of Approved Classification of Instruction Program (CIP) Codes for Qualifying Graduate Programs. Under its Financial Value Transparency (FVT) and Gainful Employment (GE) final regulations “the Department recognized that certain graduate programs, mostly concentrated in medical and clinical fields, are associated with an initial period of depressed graduate earning while graduates complete a required period of postgraduate clinical or residency work necessary to obtain a professional licensure.” This notice provides the CIP codes for programs for which the department will measure income for completers from “the sixth and seventh award year prior to the year of the earnings data, meaning that income is measured three years farther out after graduation for completers of such programs.”  

    Topics:

    Accreditation, Authorizations, & Higher Education Act | Financial Aid, Scholarships, & Student Loans | Higher Education Act (HEA) | Students

  • Date:

    ACE Letter to the State Department on Addressing Visa Processing Delays (July 5, 2024)

    Letter from the American Council on Education (ACE) and 19 other organizations to the State Department on Addressing Visa Processing Delays.  Noting that students from India have recently made up over a quarter of all international students in this country, the letter expresses concerns over delays in processing F-1 and J-1 visa applications at U.S. consulates in India.  It notes, in particular, “reports of students receiving dates for interviews 100-200 days into the future, which will cause them to miss the start of their academic programs in the fall.”   

    Topics:

    Immigration | International Students