Christian Heyne et al. v. Metropolitan Nashville Board of Public Education

Summary

The Tennessee Supreme Court reviewed a public high school student's challenge to a ten-day suspension imposed after he injured another student with his automobile on school property. The Court addressed the scope of judicial review under a common-law writ of certiorari and the student's procedural due process claims concerning alleged bias and combined prosecutorial and decision-making roles. The Court affirmed the Court of Appeals' judgment upholding the disciplinary decision.

Holdings

1. The combination of functions performed by a school disciplinary official does not, by itself, violate procedural due process. Because the record did not establish additional circumstances creating an intolerably high risk of actual bias, Perry's dual role did not invalidate the disciplinary proceeding.
2. The evidence was insufficient to overcome the presumption that school officials acted in good faith or to establish that the risk of actual bias was intolerably high. The disciplinary proceeding therefore was not constitutionally invalid on bias grounds.
3. Material evidence supported the school officials' finding that Heyne's conduct constituted reckless endangerment, and the disciplinary decision was therefore not arbitrary or illegal.
4. Because the Heynes failed to establish a constitutional violation, they were not entitled to recover attorneys' fees or costs under 42 U.S.C. § 1988.

Questions Presented

1. Whether Heyne's procedural due process rights were violated because Fran Perry participated in investigating and initiating the disciplinary charges, presided over the disciplinary hearing, and participated in deliberations.
2. Whether school officials' alleged bias and partiality rendered the disciplinary proceeding fundamentally unfair and violated procedural due process.
3. Whether material evidence supported the finding that Heyne's conduct constituted reckless endangerment under the Student-Parent Code of Conduct and Handbook.
4. Whether the trial court had authority to award Heyne and his parents attorneys' fees and costs.

Disposition

affirmed