Donohue v. Copiague Union Free School District, 47 N.Y.2d 440 (1979)
A cause of action for “educational malpractice” is not cognizable in New York courts because it would require courts to improperly interfere with the administration of public schools, which is the responsibility of school administrative agencies.
Summary
The New York Court of Appeals addressed whether a student could sue a school district for “educational malpractice” after graduating without basic English comprehension skills. The plaintiff claimed the school district negligently failed to adequately educate him, resulting in his inability to secure employment. The Court held that such a claim is not cognizable, emphasizing that the administration of public schools is constitutionally and statutorily entrusted to educational agencies, not the courts. Allowing such lawsuits would lead to unwarranted judicial interference in educational policy and its implementation.
Facts
The appellant, Donohue, attended Copiague Senior High School from 1972 to 1976 and received a graduation certificate. Despite graduating, Donohue claimed he lacked basic English comprehension skills, hindering his ability to complete job applications. He alleged the school district, through its employees, negligently gave him passing or minimal grades, failed to properly evaluate his mental ability, failed to take reasonable precautions, and failed to provide adequate support services, including psychological testing.
Procedural History
Donohue filed a complaint against the Copiague Union Free School District alleging “educational malpractice” and negligent breach of a constitutional duty to educate, seeking $5,000,000 in damages. The Special Term dismissed the complaint for failure to state a cause of action. The Appellate Division affirmed the dismissal.
Issue(s)
Whether a cause of action exists in New York for “educational malpractice” when a student graduates without basic skills due to alleged negligence by the school district.
Holding
No, because entertaining such a cause of action would require courts to improperly interfere with the administration of public schools, which is the responsibility of school administrative agencies.
Court’s Reasoning
The Court acknowledged that a traditional negligence or malpractice action might be formally pleaded in an “educational malpractice” claim, however, the court determined that public policy considerations precluded judicial intervention. The court emphasized that New York Constitution vests control and management of educational affairs in the Board of Regents and the Commissioner of Education. Quoting James v. Board of Education, 42 N.Y.2d 357, 366, the court noted that the legislative and constitutional system secures review by the board of education and the Commissioner of Education, intending to remove matters pertaining to the general school system from controversies in the courts. Entertaining such a cause of action would require courts to review the day-to-day implementation of educational policies, leading to blatant interference with the responsibilities of school administrative agencies. The court emphasized that administrative processes exist for students and parents to seek the Commissioner of Education’s aid in ensuring proper education, as per Education Law § 310, subd 7, providing an alternative avenue for addressing educational grievances.