Justia Government & Administrative Law Opinion Summaries

After unsuccessfully seeking reimbursement from the State Commissioner of Elementary and Secondary Education, Plaintiffs, a school district and school department, filed a complaint in the superior court alleging that the Commissioner and State Treasurer were required to reimburse them for the salary, fringe benefits, and travel expenses of the directors and guidance counselors in their vocational-technical programs. The superior court dismissed the complaint, concluding that Plaintiffs had an adequate remedy at law and that the Commissioner’s decision to deny Plaintiffs reimbursement was discretionary in nature, rather than ministerial. Plaintiffs subsequently sought a writ of mandamus. The Supreme Court affirmed the judgment of the superior court, holding that Plaintiffs did not have a clear legal right to be reimbursed for certain costs associated with the operation of their career and technical centers. View "Chariho Reg'l Sch. Dist. v. Gist" on Justia Law

The issue this case presented for the Supreme Court's review was the interpretation of the Commonwealth Charter School Law. Pursuant to the Charter School Law, the Walter D. Palmer Leadership Learning Partners Charter School was awarded a charter for a five-year term ending June 30, 2005. In late 2004, the Charter School filed a renewal application. On March 16, 2005, the School Reform Commission of the School District of Philadelphia (“SRC”) adopted a resolution that granted, “upon signing a new Charter Agreement,” the Charter School’s request for renewal of the charter for a second five-year period commencing on September 1, 2005. The SRC denied the Charter School's request for expansion of enrollment, and granted approval "to enroll a maximum of six hundred and seventy five (675) students and serve grades kindergarten through 8." The SRC and the Charter School then entered into, as of September 1, 2005, a legally binding agreement that incorporated the SRC Resolution in its entirety and extended the charter for five years ("the 2005 Charter"). The 2005 Charter explicitly referenced and incorporated the SRC Resolution, one provision of which capped student enrollment, explicitly mandated that the Charter School comply with the SRC Resolution; and explicitly constituted a legally binding, mutual agreement of five years duration, the terms of which could not be changed absent a written agreement signed by both parties. The legally binding nature of the terms of the 2005 Charter was mandated by a provision of the Charter School Law. Notwithstanding the terms of the 2005 Charter, the Charter School consistently enrolled more than the 675 students permitted by that Charter. For the 2007-2008 school year, the Charter School’s average daily enrollment was approximately 729 students; for 2008-2009 and 2009-2010, the average daily enrollment was approximately 732 and 765 students, respectively. In each school year, the School District of Philadelphia provided funding for 675 students based on the 2005 Charter. In July 2010, asserting that it had been underpaid by the School District, the Charter School requested that the Pennsylvania Department of Education withhold $1,678,579 from the School District's basic education subsidy allocation as payment to the Charter School for the students it had educated in addition to the 675 students permitted by the enrollment cap for school years 2007-2008, 2008-2009, and 2009–2010. The School District objected to the withholding and a hearing was held before the Department. The Secretary of Education determined that the Charter School had agreed and legally assented to the enrollment cap when it signed the 2005 Charter, and therefore, the Charter School was not entitled to payment for students enrolled above that cap in the 2007-2008 school year. However, with regard to the school years 2008-2009 and 2009-2010, the Secretary determined that the enrollment cap set forth in the 2005 Charter was no longer valid because of the enactment of an amendment to the Charter School Law which had become effective on July 1, 2008 (24 P.S. section 17-1723-A(d)). Based on his interpretation, the Secretary concluded that, to maintain the 2005 Charter’s enrollment cap subsequent to the effective date of the amendment, the School District was required to re-obtain the Charter School’s “legal assent” to the cap. Ultimately, the Secretary determined that the Charter School was entitled to payment by the School District for the education of all the students enrolled in the school for the years 2008-2009 and 2009-2010, including those enrolled beyond the cap. The School District appealed to the Commonwealth Court, which affirmed. The School District appealed to the Supreme Court, which reversed: "based on the plain text of 24 P.S. section 17-1723-A(d), we conclude that an enrollment cap is valid if agreed to by the parties as part of a written charter." View "Sch. Dist. of Philadelphia v. Dept. of Education" on Justia Law

David Alba was appointed to serve as principal of an elementary school in Cranston, Rhode Island. Alba and the Cranston School Committee subsequently entered into an employment contract. Later, after a hearing, the Committee rejected a recommendation to renew Alba’s employment contract. Alba appealed the Committee’s decision. The Commissioner of Education denied and dismissed Alba’s appeal, concluding that Alba had received all the process to which he was entitled under the contract and the School Administrators’ Rights Act. The Board of Regents affirmed the Commissioner’s decision. The Supreme Court affirmed, holding (1) the Committee acted within its authority when it voted against the recommendation to renew Alba’s contract; and (2) the Committee’s nonrenewal of Alba’s contract did not deprive Alba of his rights under the Administrators’ Rights Act. View "Alba v. Cranston Sch. Comm." on Justia Law

Plaintiffs, school committees of Woonsocket and Pawtucket and unnamed students, parents, and the superintendents from both districts, brought suit against the legislative and executive branches of Rhode Island’s state government challenging the state’s school funding formula. Specifically, Plaintiffs alleged violations of the Education Clause as well as violations of their substantive due process and equal protection rights because the formula failed to allocate adequate resources to less affluent communities. The superior court granted Defendant’s motion to dismiss the complaint. The Supreme Court affirmed, holding (1) prior case law as well as the separation of powers doctrine warranted dismissal of Plaintiffs’ Education Clause claim; and (2) Plaintiffs’ complaint was insufficient to establish potential substantive due process claims. View "Woonsocket Sch. Comm. v. Chafee " on Justia Law

The Board and School District appealed from the district court's grant of summary judgment permanently enjoining defendants from enforcing Reg. I.Q. Reg. I.Q. governs the "extended use" of school facilities outside of school hours by outside organizations and individuals. The district court found that enforcement of Reg. I.Q. to exclude religious worship services would violate the Free Exercise and Establishment Clauses. The court concluded that the Free Exercise Clause did not entitle Bronx Household to a grant from the Board of a subsidized place to hold religious worship services; the Supreme Court's ruling in Church of the Lukumi Babalu Aye, Inc. v. City of Hialeah that invidiously discriminatory ordinances targeting a religious practice of a particular religion were subject to strict scrutiny had no application to Reg. I.Q.; if the Board has a reasonable, good faith concern that making its school facilities available for the conduct of religious worship services would give rise to a substantial risk of violating the Establishment Clause, the permissibly of the Board's refusal to do so did not turn on whether such use of school facilities would in fact violate the Establishment Clause; and therefore, Reg. I.Q. did not violate plaintiffs' rights to free exercise of religion, whether or not it was subject to strict scrutiny. The court also concluded that the district court erred in concluding that Reg. I.Q. violates the Establishment Clause because it compelled the Board to become excessively entangled with religion by deciding what were religious worship services. The court considered Bronx Household's other arguments and found them to be without merit. Accordingly, the court reversed the judgment of the district court and vacated the injunction barring enforcement of Reg. I. Q. View "Bronx Household v. Board of Education" on Justia Law

C.S., who turned eighteen in March 2012, received special education services from the Butte School District until June 2013. In January 2013, the Montana Office of Public Instruction directed the School District to obtain appointment of a surrogate parent for C.S., who lived with his Foster Father, for educational purposes. The district court subsequently appointed Mary Jo Mahoney as C.S.’s surrogate parent. In March 2013, C.S. filed a motion to vacate the appointment of Mahoney and to substitute Foster Father as his surrogate parent. The court denied the request. The Supreme Court reversed, holding (1) the district court’s refusal to vacate its appointment of Mahoney was not mooted even though C.S. no longer qualified for special education services from the School District; and (2) the district court erred when it refused to remove Mahoney and appoint Foster Father as C.S.’s surrogate parent for educational purposes. View "In re C.S." on Justia Law

Plaintiffs, school districts and individuals, filed suit against the State, alleging, among other claims, that the State violated the Kansas Constitution by failing to provide a suitable education to all Kansas students. A district court panel concluded (1) the State violated Kan. Const. art. VI when the legislature underfunded K-12 public education between fiscal years 2009 and 2012; (2) the legislature failed to consider the actual costs of providing a constitutionally required education before making its funding decisions; and (3) the legislature withheld or reduced certain funding to which school districts were statutorily entitled. The Supreme Court affirmed in part and reversed in part, holding (1) certain Plaintiffs did not have standing to bring some claims; (2) the panel did not apply the correct constitutional standard in determining that the State violated the Article 6 requirement of adequacy in public education; and (3) the State created unconstitutional, wealth-based disparities by (i) withholding all capital outlay state aid payments to which certain school districts were otherwise entitled, and (ii) prorating the supplemental general state aid payments to which certain districts were entitled. Remanded. View "Gannon v. State" on Justia Law

The Boulder Monitor, which regularly attended meetings of the full Jefferson County High School Board, sued Jefferson High School District No. 1, claiming that a meeting of the Board’s budget subcommittee violated statutory open meeting and public participation requirements because there was a quorum of the Board present at the subcommittee meeting, the meeting discussed personnel matters in addition to the 2012-2013 budget, that all Board members present participated in the discussion, and that the public notice of the subcommittee meeting was inadequate. The district court granted summary judgment to the Monitor, concluding that the Board violated Montana law in the manner in which the budget subcommittee meeting was conducted. The Supreme Court reversed, holding that summary judgment in this case was improper because contested issues of fact existed that may not be resolved on summary judgment. Remanded. View "Boulder Monitor v. Jefferson High Sch. Dist. No. 1" on Justia Law

Chad Jones petitioned the Supreme Court for a writ of mandamus to direct the Circuit Court to vacate its order denying his motion for a summary judgment in an action filed against him by Latonya Hall, individually and as mother and next friend of Demetrius Hall, a minor, and Maurice Caffie, individually (collectively referred to as "Hall"), and to enter a summary judgment in his favor on the basis of State-agent immunity. Jones was employed as a physical-education teacher at Gresham Middle School and Demetrius Hall and Michael Boyd were students. A fight between the young men broke out during a school basketball game. According to Demetrius, he was guarding Boyd tightly when Boyd became angry and threw the basketball at him, striking him in the face with the ball. Demetrius responded by pushing Boyd and throwing a punch. After the two exchanged insults, another student unexpectedly shoved Demetrius into Boyd, and Boyd responded by "slamming" Demetrius into some nearby metal stairs and striking him in the head. Demetrius was seriously injured as the result of the altercation. Jones contends that he was at the opposite end of the gym when the altercation occurred. Hall sued Jones, Sokol, and Sammy Queen, (another school physical-education teacher) asserting claims of negligence and wantonness and alleging that the defendants had breached their duty to reasonably supervise Demetrius and Boyd by leaving them unattended for an extended length of time. Concluding that Jones failed to demonstrate that he had a clear legal right to the relief sought, the Supreme Court denied his petition for a writ of mandamus. View " Hall v. Jones" on Justia Law

In this matter, petitioner is one of the founders of the proposed Quest Academy Charter School of Montclair (Quest Academy), which sought licensure pursuant to N.J.S.A. 18A:36A-4 to operate as a charter school for high school students. The Commissioner of Education denied the application. The Commissioner granted petitioner the opportunity to revise the application, as well as an opportunity to participate in a training program for preparing an application for the upcoming application deadline. Following petitioner’s filing of a notice of appeal to the Appellate Division, the Commissioner issued a written amplification of reasons for denial of the application. The Appellate Division upheld the Commissioner’s action on the grounds that the decision was not arbitrary, capricious, or unreasonable. The Supreme Court, after review, concluded that the Commissioner's decision to deny Quest Academy’s charter school application was amply supported by the record and was not arbitrary, capricious, or unreasonable. View "IMO Proposed Quest Academy Charter School of Montclair Founders Group" on Justia Law