April 2026

Dear Readers of the Extra Mile:

April tends to bring with it unique weather. March ran the gamut, from days in the 70s to bitter cold and snow. Nonetheless, the NCAA basketball tournaments have concluded, and we congratulate the Michigan men’s team, and the UCLA women’s team, on capturing their respective national titles.

We hope each of you enjoyed your spring break, wherever it took you. A lot has happened since we last wrote you. We begin, however, with a couple of reminders:

Save the Date for The Year in Review Conferences!

Dates and locations are set for our 2026 The Year in Review conferences in conjunction with our partners at IASPA. Notably, after maxing out our conference space in Peoria and to better serve school leaders across central Illinois, we are pleased to offer the 2026 Year in Review in Bloomington. We think you will enjoy the new location.

Here is the 2026 lineup:

October 6 - Bloomington (Bloomington-Normal Marriott)
October 13 - Collinsville (Doubletree by Hilton)
October 29 - Itasca (Westin Chicago Northwest)

When registration opens in the fall, make your reservation early. Space is limited at all three locations and can sell out quickly.

Student Handbook Checklist

Spring has arrived, and with it, the need for schools to review their student handbooks. Hodges Loizzi has fully revised and updated its Student Handbook Checklist for 2026, and it is now available for purchase through this order form.

Student handbooks have become a source of litigation for many school districts, so ensure yours is complete and up-to-date to avoid litigation and limit your legal costs. Order your checklist today!

If you wish to have a complete review of your student handbook, contact any of our Student/Special Education Practice Group attorneys.

Kluge v. Brownsville Community School Corporation Update

We have been reporting to you on the above litigation (See our August 2025 Extra Mile), which has been going up and down the courts for years. The case arises from Indiana and was last ruled on by the Seventh Circuit Court of Appeals, which governs all Illinois school districts on federal law issues. Reversing its prior decision, it remanded the case back to the trial court for a full trial on the merits.

The case turns on a constitutional claim by a teacher that his faith prohibited him from addressing students by their preferred gender. Ultimately, the teacher resigned.

Faced with a full trial, the school district opted to settle the case with the former teacher for $650,000.

The settlement and multi-year litigation emphasize the complexities school leaders face in accommodating the rights of both staff and students. Contact any of our Student or Personnel attorneys with your inquiries.

Consumer Price Index

The Bureau of Labor Statistics released its March 2026 CPI data on April 10. Inflation was running at the annual rate of 3.3%, in line with expectations. The full BLS report can be accessed below.

In This Issue

Does a first grader have First Amendment rights? A federal appellate court answers.

Are school districts faced with monetary liability for employee injuries outside of workers’compensation? An Illinois appellate court rules.

What happens when parents sue a teacher and a school district claiming their constitutional rights were violated by a teacher who allegedly caused their child to convert to a different religion? A federal trial court rules in multiple cases.

LEGAL NEWS

Six-Year-Old’s First Amendment Claim Allowed to Proceed

Sometimes, even we are surprised by the cases we see. Recently, the federal Ninth Circuit Court of Appeals reversed a trial court’s dismissal of a parent’s lawsuit that their six-year-old child’s First Amendment rights had been violated.

The facts involved a principal who prohibited a child’s drawing that said "Black Lives Mater [sic], any life,” stating that the sign was racist. Read more...

Michelle Todd

Can Public Employers be Sued for Monetary Damages Outside of Workers’ Compensation? The Illinois Appellate Court Says “Yes” Under Limited Circumstances

The Illinois appellate court recently allowed a lawsuit to proceed against a village for general tort monetary liability. The court found that when a plaintiff alleged that intentional conduct caused the injury, the exclusivity of the Workers’ Compensation Act may not apply. The court went on to rule that the Tort Immunity Act also did not protect the village. Read More...

Pam Simaga

Federal Court Finds No Violation of Parents’ Constitutional Rights in Teacher’s Alleged Role in Student’s Religious Conversion

A family sued a high school teacher and an Illinois school district after their daughter converted from Islam to Christianity, alleging the teacher’s conduct violated their constitutional rights. The court dismissed the parents’ claims, finding that the student’s conversion stemmed from her own beliefs rather than from the teacher’s coercion.

The teacher later resigned and brought his own Title VII suit against the district. That case was dismissed in 2024. Read more...

Frazier Satterly

INSIGHTS FOR SCHOOL LEADERS

IASBO 2026 Annual Conference

Jeff Goelitz will share his expertise and experience on “Preparing for Contract Negotiations: Strategies, Market Data, and Current Trends“ on April 29 at IASBO's 2026 Annual Conference in Peoria.

Steve Richart will also present and share his knowledge on “Outsourcing and Contracting for Hard-to-Fill Positions: Legal Pitfalls“ on May 1.

Registration is now open!

AASPA 88th Annual Conference

As you get your “Boots On“ at AASPA’s 88th Annual Conference, on October 12-16 in Austin, TX, don’t miss Barb Erickson’s session on “FMLA & ADA and What You Should and Shouldn’t Say.“ Barb will break down the communication do’s and don’ts every school administrator needs to know to protect employees, support compliance, and lead from the ground up.

Don't miss the chance to visit Austin and the famed Texas Hill Country while enjoying Barb’s presentation.

NOTES AND REMINDERS

May 31 is the deadline to complete your "timely and meaningful" consultation with representatives of private and home-schooled students to determine the allocation of "proportionate share" special education and related services. Contact Michelle Todd with your inquiries.

As spring arrives, check contracts for auto-renewal provisions. School district contracts often renew on July 1, with required termination notice deadlines as early as 120 days prior. Don’t get stuck in a contract you don’t intend to! Contact James Levi or Kerry Pipal to review renewal provisions or prepare non-renewal notices.

If you are considering entering into a finance lease for technology, school buses, or other equipment, contact Heather Brickman or Kerry Pipal to discuss. Financing companies often require opinions of counsel that can be most efficiently provided if we are involved before board approval.

CONCLUSION

As noted above, the NCAA basketball tournaments provided their usual share of thrilling finishes (especially the incredible last shot, come-from-behind victory of Connecticut over Duke in the East Regional Final). We hope you all enjoyed the games (and the pools) as much as we did. We note that Kalshi, the prediction market, offered a $1 billion prize for a perfect bracket. Warren Buffett had a similar contest in prior years, limited to Berkshire Hathaway employees, and no one ever claimed the billion.

National Nebraska Day

Each year, April 5 is National Nebraska Day. We hope you celebrated with a Runza and a La Casa Pizza. For those of you who have not yet visited Omaha, plan on attending the Men’s College World Series in June. No sporting event is quite like it.

Our Viewing Recommendations

We briefly mentioned last month that Paradise had returned for its second season. We can now report that Season 2 is every bit as good as the remarkable Season 1. The scope has broadened beyond Paradise, and the mysteries deepen. What, exactly, is being built in Paradise? Sterling K. Brown is remarkable in the lead.

Last month, we also mentioned Love Story (currently on Hulu), the story of the romance and marriage of John F. Kennedy Jr. and Carolyn Bessette. Having watched the season, we highly endorse the series, especially for the era it evokes and the underlying story.

For a new series, we recommend The Madison on Paramount+. For those of you of a certain age, imagine Green Acres as a drama written by Taylor Sheridan.

In Conclusion

We know you may be stressed with the end of the school year upon us. We stand at the ready to support our clients and help you succeed in your educational mission. Whatever legal problem you may face, we have successfully dealt with it before.

Thanks for reading the Extra Mile, your gateway to the stability, service, and excellence of Hodges Loizzi.

We will write you again in May.

The Attorneys and Support Staff of

Hodges, Loizzi, Eisenhammer, Rodick & Kohn

CONSUMER PRICE INDEX

Latest figures: March 2026

The Extra Mile is intended solely to provide information to the school community. It is neither legal advice nor a substitute for legal counsel. It is intended as advertising but not as a solicitation of an attorney/client relationship.

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