Justia Pennsylvania Supreme Court Opinion Summaries

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

The Supreme Court granted review to determine whether a public school district was obligated to fund a kindergarten program offered by a cyber charter school for a four-year-old student when the district exercised its discretion not to offer such a program in its public schools. In 2006, the Secretary of Education notified Appellant Slippery Rock Area School District that funds had been deducted from the district's state subsidy and made payable to Appellee Pennsylvania Cyber Charter School. The Secretary deducted funds because Slippery Rock failed to pay Cyber School for numerous students residing in the district who were attending Cyber School. Slippery Rock objected to the withholding of $1,716.63 for a four-year-old female student enrolled in Cyber School’s kindergarten program. Slippery Rock averred that while it operates a discretionary kindergarten program for five-year-old children, the student at issue did not meet the age requirements for admission into the district’s kindergarten program, Slippery Rock argued that it was not obligated to "assume the costs or obligation of this individual’s enrollment into [Cyber School]." The Secretary concluded that Slippery Rock could not deny payment to Cyber School simply because Slippery Rock did not have a four-year-old kindergarten program. Subsequently the Secretary granted Cyber School's motion to dismiss Slippery Rock's objection. The Commonwealth Court affirmed the Secretary, but the Supreme Court reversed the Commonwealth Court and the Secretary: "[t]o hold that Slippery Rock is obligated to fund educational opportunities for students not yet eligible to attend the district’s public schools would allow those students who enroll in Cyber School to receive greater benefits than a similarly-situated student who chooses to attend the public school." View "Slippery Rock Area Sch. Dist. v. Pa. Cyber Charter Sch." on Justia Law