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Idaho Supreme Court denies class certification in parent's lawsuit against school district over fees

State Court

By Charmaine Little | Oct 28, 2019

Schools 1280

BOISE, Idaho (Legal Newsline) – In Idaho, a Pocatello/Chubbock School District No. 25 parent has been denied class certification in his lawsuit against the school district over allegations the district charged students illegal fees.

On Oct. 23, the Supreme Court of Idaho denied the certification in Mike Zeyen’s lawsuit, which he filed on behalf of himself and his minor children against the school district. Rachael Booth and her children were also named as plaintiffs in the suit. 

Zeyen filed the appeal after the District Court of the Sixth Judicial District denied the certification for the class, citing that Zeyen lacked standing. Zeyen's suit concerned fees paid for the 2014-2015 academic year and was originally filed in July 2016.

"The court determined that the Educational Claims Act provides the sole mechanism for Zeyen to acquire standing under the Education Article," Chief Justice Roger S. Burdick wrote. 

"Because the Educational Claims Act does not address past wrongs or individual damages, the court ruled that Zeyen failed the typicality requirement for class action standing because he lacked a redressable injury required for individual standing.

“We find no error in the district court’s interpretation of the Education Claims Act. We also decline to entertain Zeyen’s constitutional argument because it was not considered by the district court and therefore, there is no adverse ruling to appeal."

Burdick stated that the Educational Claims Act doesn’t offer relief for previous behavior. It also only gives relief to guardians of current and future students and calls for the court to evaluate how the district spends its funds. In this case, the conduct isn’t considered current because the district has since stopped imposing the fees that Zeyen contested.

While Zeyen tried to convince the Supreme Court to determine that a district court can legally order the reimbursement of the fees already paid, the judges ruled that this would overturn the entire act. 

“Ordering the school district to pay monetary restitution is a backwards way of accomplishing the statutory goal where the action must determine whether the school district has adequate resources, or is properly allocating its resources,” Burdick wrote.

Burdick also refused to agree with Zeyen’s challenge that the act should be ruled as unconstitutional if it doesn’t allow past relief.

Considering the ruling, the Burdick also said that Zeyen wasn’t owed attorney’s fees.

Justices Robyn Brody, G. Richard Bevan and Gregory W. Moeller concurred.

Justice John R. Stegner dissented and said he’d vacate and remand the case back to the district court. Stegner stated that the lower court did abuse its discretion when it shut down Zeyen’s motion to amend because it failed to consider the hardships that the plaintiffs experienced. 

He also disagreed with the lower court’s ruling that denied Zeyen’s motion for class certification because of lack of standing. He said the lower court incorrectly determined if a possible relief was present, and said it erred when it depended on federal standing doctrine.

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