JUDICIAL & ADMINISTRATIVE DECISIONS

Mahanoy Area School District v. B.L., a minor, BY AND THROUGH her father Lawrence Levy and her mother Betty Lou Levy v., 2021 WL 2557069 (U.S. Supreme Ct. 2021)

CIVIL RIGHTS/CONSTITUTIONAL RIGHTS
First Amendment • Speech Protected

The Supreme Court affirmed the Third Circuit’s judgment that upheld the District Court’s grant of summary judgment in B.L.’s favor, finding that Mahanoy Area School District (Mahanoy) violated her First Amendment rights when B.L. was suspended from the junior varsity cheerleading team for a year for posting a profane and vulgar message on Snapchat while off-campus and outside of normal school hours. B.L., disgruntled that she failed to make the varsity cheerleader team, posed in street clothes with a friend, and with her middle finger raised, took a “selfie” at a local store. She added the following text to the picture: “fuck school fuck softball fuck cheer fuck everything.” She posted the picture on her private Snapchat account, where it could be viewed by over 200 students. One student came across the snap, took a screenshot (because the pictures were not public), and shared it with the coaches. The coaches found that B.L.’s snap violated team and school rules, requiring cheerleaders to “have respect for [their] school, coaches, ... [and] other cheerleaders”; avoid “foul language and inappropriate gestures”; and refrain from sharing “negative information regarding cheerleading, cheerleaders, or coaches ... on the internet.” B.L. acknowledged these rules prior to joining the team. They also found B.L.’s snap violated a school rule requiring student athletes to “conduct[ ] themselves in such a way that the image of the Mahanoy School District would not be tarnished in any manner.” The coaches decided to suspend B.L. from the cheerleading team for one year for violating the cheerleading rules by posting the offensive pictures. Mahanoy upheld the coaches’ decision and agreed that B.L. could try out for the team again next year. After a series of appeals to various school officials, B.L. sued Mahanoy, alleging under § 1983 that her suspension from the team violated the First Amendment; that the school and team rules she was said to have broken are overbroad and amount to viewpoint discrimination; and that those rules are unconstitutionally vague.

The Middle District Court (District Court) granted summary judgment in favor of B.L., finding that B.L. did not waive her speech rights by agreeing to the team’s rules and that her suspension from the team implicated First Amendment rights even though extracurricular participation is merely a privilege. The District Court also found that B.L.’s snap was off-campus speech and therefore not subject to regulation under Bethel School District No. 403 v. Fraser. Additionally, because the District Court found that B.L.’s snap had not caused any actual or foreseeable substantial disruption of the school environment, the District Court held that her snap was also not subject to discipline under Tinker v. Des Moines Independent Community School District. The Third Circuit panel unanimously affirmed the judgment of the District Court. The panel found that B.L.’s snap was protected speech that was off-campus and, therefore, fell outside the school context. The Third Circuit also found that Fraser did not authorize Mahanoy’s punishment of B.L. for her off-campus speech and that “Tinker does not apply to off-campus speech – that is, speech that is outside school-owned, -operated, or -supervised channels and that is not reasonably interpreted as bearing the school’s imprimatur.” The panel determined that “Tinker’s focus on disruption makes sense when a student stands in the school context, amid the ‘captive audience’ of his peers. But it makes little sense where the student stands outside that context, given that any effect on the school environment will depend on others’ choices and reactions.”

By an 8 to 1 vote, the Supreme Court affirmed the Third Circuit’s judgment but not its reasoning. The Court recounted that courts “must apply the First Amendment ‘in light of the special characteristics of the school environment’” and pointed out three specific categories of student speech that schools may regulate: (1) “indecent,” “lewd” or “vulgar” speech uttered during a school assembly on school grounds; (2) speech, uttered during a class trip, that promotes “illegal drug use”; and (3) speech that others may reasonably perceive as “bear[ing] the imprimatur of the school,” such as that appearing in a school-sponsored newspaper. The Court opined that the schools “license to regulate student speech” does not disappear when a school regulates speech that takes place off campus and pointed to several types of off-campus behavior that “may call for school regulation” such as “serious or severe bullying or harassment targeting particular individuals; threats aimed at teachers or other students; the failure to follow rules concerning lessons, the writing of papers, the use of computers or participation in other online school activities; and breaches of school security devices, including material maintained within school computers.” However, the Court “hesitate[d] to determine precisely which of many school-related off-campus activities belong on such a list” thereby rejecting the Third Circuit’s reasoning that Tinker was not applicable to off-campus speech. The Court then described three features that “distinguish schools’ efforts to regulate [off-campus] speech from their efforts to regulate on-campus speech.” First, a school “will rarely stand in loco parentis when a student speaks off campus.” Second, “from the student speaker’s perspective, regulations of off-campus speech, when coupled with regulations of on-campus speech, include all the speech a student utters during the full 24-hour day.” This means that “courts must be more skeptical of a school’s efforts to regulate off-campus speech.” Third, while a school may have an interest in regulating disruptive, obscene or speech bearing its imprimatur, it also “has an interest in protecting a student’s unpopular expression” since schools are “nurseries of democracy.” The Court opined that “[t]aken together, these three features of much off-campus speech mean that the leeway the First Amendment grants to schools in light of their special characteristics is diminished.” Thereafter, the Court applied this standard to this case and affirmed the judgment, but not the reasoning, of the Third Circuit.

Justices Alito and Gorsuch filed a concurring opinion describing specific categories of off-campus speech that schools may or may not regulate. Justice Thomas filed a dissenting opinion, quoting parts of the PSBA amicus brief, opining that the Court is choosing “intuition over history when it comes to student speech” when it overlooked the applicability of the doctrine of in loco parentis to this case.

Click here for the opinion.

Editor’s Note: PSBA and NSBA participated as amicus curiae in this case.

Editor’s Note: The Third Circuit opinion is published at 57 SLIE 14 and the Middle District Court opinion is published at 56 SLIE 8.

City of Pittsburgh and School Dist. of Pittsburgh v. Michael K. Lanese, 2021 WL 2328101 (Commw. Ct. 2021)

TAXATION
Tax Collection • Use of Private Tax Collectors

The Commonwealth Court affirmed the order of the Court of Common Pleas of Allegheny County which entered a judgment against Lanese for delinquent taxes. On appeal, Lanese argued that he was aggrieved by an unconstitutional tax assessment, collection and enforcement system in violation of his due process and equal protection rights because “privatized tax collection and enforcement is a non-delegable municipal functions [sic] per the protections of Article III, Section 31 of the Pennsylvania Constitution.” He also argued that his rights were violated because the employees of the private tax collector do not take an oath of office. The City of Pittsburgh and the School District of Pittsburgh (collectively “Pittsburgh”) asserted that despite Lanese’s arguments, he was primarily attempting to challenge the underlying tax assessment on the property. Pittsburgh pointed out that Lanese offered no relevant case law or authority that supported his constitutional challenges and noted the law allows municipalities to “impose the charges, expenses and fees of delinquent real estate tax collection, including reasonable attorney fees and fees of third parties retained by the municipalities upon individual taxpayers.” Regarding the use of private tax collectors, Pittsburgh asserted that levying taxes is different than the administrative function of collecting taxes, and Article III, Section 31 of the Pennsylvania Constitution does not prohibit the delegation of administrative powers.

After reviewing whether Lanese’s brief was defective such that the appeal should be quashed, the Commonwealth Court addressed some of the initial arguments raised by Lanese and found that there was no support for those arguments. Then the Court moved to the crux of Lanese’s appeal – that it was unconstitutional for Pittsburgh to rely on nongovernmental, third-party contractors to collect delinquent real estate taxes. After analyzing the arguments that Lanese raised in support of his position, the Court found that the use of third-party, private entities to collect taxes was not contrary to statutory or case law. In this particular case, the Court found that Pittsburgh delegated the task of delinquent tax collection and not their taxing authority. Accordingly, the trial court’s order was affirmed. Judge McCullough concurred in the decision but pointed out that despite Lanese’s failure to set forth a cogent argument regarding uniformity, it did not minimize the importance of the right to uniform taxation in the Commonwealth.

OPINION NOT REPORTED

Editor’s Note: Unreported decisions of the Commonwealth Court are not intended to have precedential value but may be cited in legal proceedings for persuasive value.

Click here for the opinion.

Riverview Intermediate Unit #6 v. Riverview Intermediate Unit #6 Education Assoc., 2021 WL 2337138 (Commw. Ct. 2021)

COLLECTIVE BARGAINING; ARBITRATION; LABOR
Essence Test • Rationally Related

The Commonwealth Court reversed the decision of the Court of Common Pleas of Clarion County to vacate a labor arbitration award. Riverview Intermediate Unit #6 (IU) provides special educational services to students in multiple Pennsylvania school districts in four counties. Riverview Intermediate Unit #6 Education Association (Union) is the collective bargaining agent representing certified educational support personnel who are assigned to assist teaching professionals in various separate school districts within the four counties in which the IU provides services. The parties entered into a collective bargaining agreement (CBA), which became effective on July 1, 2015, and continued in effect through June 30, 2020. At the end of the 2017-18 school year, a bargaining unit member was involuntarily realigned, and her new assignment was more than 20 miles roundtrip from her previous assignment but closer to her home. Pursuant to the CBA, she requested mileage compensation for the distance between her old and new assignments for every day she worked during the 2018-19 school year. The IU denied her request and that of three other bargaining unit members because the new assignments were closer to their residential homes and their commutes to work were shorter.

After a grievance was filed, the matter worked its way to binding arbitration. Before the arbitrator, the IU relied heavily on a decision issued in 2007 by another arbitrator (the 2007 Arbitration Case), involving the IU and the Union and the same provisions of the CBA. The IU asserted that the 2007 Arbitration Case was “law of the case” and supported its position that mileage reimbursement is not available under the CBA. However, the arbitrator found in favor of the Union, finding that the displacement mileage benefit provided under the CBA “clearly requires two eligibility requirements, namely, an involuntary transfer [or]… an involuntary realignment… and a new work assignment to be greater than 20 miles, roundtrip, from the previous assignment.” The arbitrator determined that the fact that an employee’s home may be located closer to his or her new assignment was not a relevant factor. Accordingly, the arbitrator found that the IU must provide displacement mileage from “the measurement between two location sites only, namely the previous and new work assignments… regardless of the commuting distance the employees had to travel from their homes.”

The trial court vacated the arbitration decision finding, in relevant part, that the arbitrator’s decision was not rationally related to the terms of the CBA. The trial court concluded “[t]he interpretation of the language of the CBA by the [a]rbitrator resulting in the creation of a ‘mileage benefit’ to employees that are not actually engaging in any [work] travel is not a rational interpretation.” The trial court emphasized that the unambiguous language of the CBA makes it clear that the bargaining unit members are not entitled to travel reimbursement.

The Commonwealth Court started by analyzing the standard of review of a grievance award under the Public Employe Relations Act (PERA) focusing on the “essence test.” The Court determined that the first prong of the essence test was satisfied because the issue that was raised by the parties and addressed by the arbitrator was contemplated by the terms of the CBA. The Court also determined that the second prong of the essence test was met because the essence of the trial court’s opinion was a disagreement with the arbitrator’s interpretation of the CBA, meaning that the trial court exceeded the limited scope of arbitral review. Accordingly, the Court found that the trial court erred in granting the petition to vacate the arbitration award and remanded the matter.

OPINION NOT REPORTED

Editor’s Note: Unreported decisions of the Commonwealth Court are not intended to have precedential value but may be cited in legal proceedings for persuasive value.

Click here for the opinion.

Melanie Ackerman v. Wilkinsburg School District, 2021 WL 2434503 (W.D. Pa. 2021)

EMPLOYMENT DISCRIMINATION
Family Medical Leave Act • Retaliation

The District Court denied the motion for summary judgment filed by Wilkinsburg School District (Wilkinsburg) in this case alleging retaliation under the Family Medical Leave Act (FMLA). Ackerman is employed by Wilkinsburg as an elementary teacher. In November 2018, Ackerman suffered three fractured ribs from a fall at her home and requested, and was granted, leave pursuant to the FMLA. Following her return to work, Ackerman received her professional evaluation for the 2017-18 school year citing that she “Needs Improvement” and she was placed on an Employee Improvement Plan (Plan). Pursuant to the Plan, her teaching was regularly observed by her supervisors and ultimately, approximately 150 to 160 “negative write-ups” were placed in the electronic teacher evaluation portal after she returned from her FMLA leave. Prior to her FMLA leave, Ackerman had three comments and they were all of a positive nature. She has not been demoted, suspended or denied any salary increases or any other compensation or benefits. While acknowledging that she did not suffer any economic loss caused by the school district’s actions, Ackerman alleges that she suffered emotional damages and believes her “job fundamentally changed since she returned from FMLA [leave].” Accordingly, she filed a complaint alleging FMLA retaliation, among other claims that were dismissed earlier in the case.

The court analyzed the types of relief that are available under FMLA – consequential damages and equitable relief. The court determined that Wilkinsburg sufficiently asserted that Ackerman was not entitled to consequential damages but did not argue about the availability of equitable relief. As a result, the court found that Wilkinsburg did not show that it was entitled to summary judgment and denied the motion.

Click here for the opinion.

Alexander G., through his parents Stephen G and Shiela G v. Downingtown Area School District, 2021 WL 1614400 (E.D. Pa. 2021)

SPECIAL EDUCATION; SECTION 504; ADA; GIFTED EDUCATION
FAPE • Compensatory Education • Tuition Reimbursement

The District Court denied the plaintiff’s motion for judgment on the administrative record finding that Downingtown Area School District (Downingtown) provided the plaintiff with a free, appropriate public education (FAPE). In August 2015, while attending parochial school and prior to the start of the plaintiff’s fourth-grade year, his parents asked Downingtown to conduct a full evaluation of the plaintiff. The evaluation revealed that the plaintiff was eligible for special education under the classification of a specific learning disability in reading. In January 2016, his parents removed him from the parochial school and enrolled the plaintiff in Downingtown. Shortly after beginning in Downingtown, the plaintiff was given benchmark testing and his initial proposed individualized education program (IEP) was revised to include this updated information. In September 2016, his parents expressed concern with the plaintiff’s progress in reading, writing and math and requested that Downingtown conduct a reevaluation. The reevaluation report in December 2016 found that the plaintiff continued to be eligible for education services and continued to display a need for specially designed reading instruction. That same month, the IEP team convened to develop a new annual IEP and decided to add additional supports for math. After more evaluations during the plaintiff’s sixth grade year, his parents expressed their belief that the program for the plaintiff was not appropriate and provided Downingtown with written notice of their intent to place the plaintiff in a private school and seek tuition reimbursement in the event they could not agree on the plaintiff’s IEP at the upcoming IEP meeting. Following that IEP meeting, his parents decided to place the plaintiff at a private school for seventh grade.

The parents filed a due process complaint and ultimately, the hearing officer determined that Downingtown provided the plaintiff with a FAPE and concluded the plaintiff was not entitled to compensatory education or tuition reimbursement. This complaint followed and the issue at this stage of the litigation was whether the plaintiff was denied a FAPE and, if he was, whether the court should award him a compensatory education, private school tuition and reimbursement for a private speech and language evaluation.

The court analyzed the hearing officer’s report and found that the hearing officer’s findings were supported by the record, particularly the factual findings and conclusions that the plaintiff made progress relative to his potential. The court also found that the reading program was reasonable and the other supports and IEPs were adequate. All were reasonably calculated for the plaintiff to make meaningful progress relative to his potential and accordingly complied with the FAPE requirements of the IDEA. As a result, the court determined that the plaintiff was not entitled to compensatory education, tuition reimbursement or reimbursement for an independent educational evaluation.

Click here for the opinion.

PUBLIC SECTOR ARBITRATION

Thank you to all who plan to or who have contributed recent or older but useful arbitration opinions and awards.

PLEASE KEEP THEM COMING!

Tulpehocken Area Education Association and Tulpehocken Area School District

Martin Herring, Esq., arbitrator

Discipline/Dismissal (professional employee)

This grievance concerning the termination of a tenured public school teacher was denied. The parties are subject to a collective bargaining agreement (CBA). On December 13, 2018, the grievant was supervising a seventh period physical education class. Because the students were being called out during the class for vision testing, the grievant decided to permit the students to have a free period. The students were permitted to use the equipment in the gymnasium to play games of their choosing. The grievant remained in the gymnasium observing the students. Some students used school district “scooters” and gymnasium mats, an activity they had engaged in prior to this time, so that they could be pulled around the gymnasium floor. The boys pulled the scooters and the mats, and the girls sat on the mats. One of the scooter mats collided with a hockey goal and as a result a student, O.T., was injured. The injured student and another student ran into the locker room while the grievant remained in the gymnasium supervising the students who were leaving and arriving for the next period. When the grievant went to the locker room, she found that the students had gone to the nurse’s office. Eventually, the grievant worked her way to the nurse’s office, only stopping relative to student council issues and to speak to another teacher, and was informed by the nurse that the injured student was picked up by her parent(s). Tulpehocken School District (Tulpehocken) began an investigation that involved several interviews, including interviews with the grievant on five different occasions. At the conclusion of the investigation, the superintendent recommended to the Tulpehocken Board of School Directors that the grievant’s employment be terminated, and she was terminated by board action on February 9, 2019, on the grounds of immorality and persistent and willful misconduct.

Tulpehocken asserts that the grievant was not truthful about knowing the nature of the injury to O.T. and claiming that she went to the nurse as soon as possible without speaking to anyone about the incident. The union asserts that the grievant was truthful during the investigation. The arbitrator started by reviewing the testimony of the various witnesses. He concluded that the grievant was not untruthful but clearly did not grasp the seriousness of the incident and the investigation. He was impressed by the testimony of the superintendent and accordingly found that the grievant singularly created an unsafe atmosphere for the students by allowing the activity in the gym. Accordingly, the grievance was denied.

Click here for the opinion.

In the Matter of Arbitration between Boyertown EA/PSEA/NEA and Boyertown School District

John M. Skonier, Esq., arbitrator

Arbitrability

In this matter, the arbitrator found that the “just cause” provision of the collective bargaining agreement (CBA) was inapplicable to a disciplinary suspension that did not exceed 12 days. The parties are subject to a CBA for the school years 2019-20 through 2022-23. In September 2019, the grievant received a 15-day suspension for allegedly making culturally and racially insensitive comments to a student in her class. The CBA states: "No Employee in the Bargaining Unit shall be discharged or suspended without pay for disciplinary reasons in excess of twelve (12) working days without just cause."

On September 18, 2019, the union grieved the suspension, stating that the grievant denied making the racially insensitive comments to a student. In October 2019, after hearing the grievant’s side of the story and reviewing witness statements, Boyertown School District (Boyertown) offered to reduce the suspension to 10 days with the proviso that the grievant complete cultural awareness/sensitivity training. Ultimately, in January 2020, the suspension was reduced to 10 days. The grievance was bifurcated so the question of procedural arbitrability could be decided first.

The union asserted that the grievant’s due process rights were being denied by Boyertown since her suspension was less than 12 days. It argued that the just cause provisions of the CBA must be applied to all disciplinary matters and not just those suspensions that exceed 12 days. On the other hand, Boyertown argued that there is no presumption of arbitrability in this case because the CBA language expressly excludes this matter from the contractual grievance process. This means that the arbitrator has no jurisdiction to proceed since the CBA precludes arbitration of this issue. In essence, the union “seeks to gain that for which it did not bargain.”

The arbitrator determined that this provision of the CBA was appropriately bargained. The provision was not new to the parties and only recently reduced from 30 days to 12 days. The arbitrator specifically found that “it can be said ‘with positive assurance that the arbitration clause is not susceptible of an interpretation that covers the asserted dispute.’” Clear, unambiguous language that has been bargained for and that has existed in the parties’ contract for decades must be followed.

Click here for the opinion.

In the Matter of Arbitration between West Chester Area School District and West Chester Area SSP

Scott E. Buchheit, arbitrator

Discipline/Dismissal (support personnel)

This grievance concerning the termination of a custodian was denied. The parties are subject to a collective bargaining agreement (CBA). The grievant was hired in August 2018 to work as a full-time, third-shift custodian. His working hours were from midnight to 8:30 a.m. In January 2019, which was still in his probationary period, the grievant was discovered sleeping on the job. He was placed on a four-day suspension with notice that further instances of sleeping on the job could result in termination. Then, on April 23, 2019, the grievant was discovered sleeping in the janitor’s closet. This was reported to the head custodian, who found the grievant sleeping in the closet the next day, April 24, 2019. Thereafter, the superintendent recommended that the grievant be terminated. This grievance followed, alleging that the grievant was suspended and then terminated without just cause.

The arbitrator first considered whether West Chester Area School District (West Chester) established that the grievant was sleeping in his janitor closet during his overnight shifts. The arbitrator gave great credence to the two witnesses who found him sleeping. He stated that to do otherwise would mean that both were deliberately testifying untruthfully. Because West Chester met this burden, there was just cause to discipline the grievant. The arbitrator turned to whether the level of discipline was appropriate. Because the grievant was placed on notice the first time that further incidents of sleeping on the job could subject him to termination, the arbitrator determined that West Chester did not exceed its reasonable authority when it terminated the grievant. Accordingly, the grievance was denied.

Click here for the opinion.

IN OTHER NEWS

Volume III 2021 of the Policy News Network+
PSBA Policy Services issued Volume III 2021 of the Policy News Network+ addressing updates to policies and administrative regulations for threat assessment and the requirement for a threat assessment team to be established by each school entity by the beginning of the 2021-22 school year, as well as updates regarding Act 57 of 2020 requiring background investigations for school security personnel. Information on the School Wellness policy triennial assessment is also included in this issue.

U.S. Department of Education Confirms Title IX Protects Students from Discrimination Based on Sexual Orientation and Gender Identity
Effective June 22, 2021, the U.S. Department of Education's Office for Civil Rights issued a Notice of Interpretation explaining that it will enforce Title IX's prohibition on discrimination on the basis of sex to include: (1) discrimination based on sexual orientation; and (2) discrimination based on gender identity. Title IX of the Education Amendments of 1972 prohibits discrimination on the basis of sex in any education program or activity offered by a recipient of federal financial assistance. The department's interpretation stems from the landmark U.S. Supreme Court decision in Bostock v. Clayton County, in which the Supreme Court recognized that it is impossible to discriminate against a person based on their sexual orientation or gender identity without discriminating against that person based on sex.

Click here for the Notice of Interpretation published in the Federal Register.

District seeking solicitor
The Belle Vernon Area School District in Westmoreland County is inviting proposals from school law firms/attorneys interested in appointment as the district solicitor. The Request for Proposals may be found at this link. Proposals are due no later than July 1, 2021.

MARK YOUR CALENDAR

Register now! Solicitors Symposium: July 8 & 9, 2021
The School Solicitors Symposium is an annual, multiday educational and networking program specially focused on issues and trends having particular impact on legal representation of public school entities. As many aspects of life and law practice begin to return to some semblance of normalcy, we are increasingly eager to resume the informative and collegial gatherings of the PA School Board Solicitors Association. Although the 2021 Symposium will be conducted remotely due to the ongoing pandemic, like the traditional in-person event, it will include networking and brainstorming opportunities in addition to topical presentations, all offered in a relaxed atmosphere. We look forward to “seeing” you there! Attendees can earn seven continuing legal education credits (six substantive, one ethics). Click here to register now! The first 100 registrants will receive a “swag bag” mailed to their home prior to the event.

2021 topics include:

Title IX Update – a look at the future of the 2020 regulations, protection of LGBTQ students and other emerging issues
School Law Update – a lively overview of what’s happening in the courts, new statutes and regulations, and other developments directly impacting public school operations and liability exposures
Achieving a Sane Work-Life Balance (ethics and professionalism)
Reviewing Board Policies with an Equity Lens – the solicitor’s role in identifying potential equity barriers and shortfalls in the way district policies are worded and implemented
Economic Furloughs of Professional Employees – legal requirements and practical considerations involved in preparing for and implementing reductions in force for purely economic reasons
Cybersecurity & Privacy Compliance – what solicitors need to know to help clients ensure that district systems and data are protected from cyber threats and privacy breaches

The program also will include multiple roundtable discussion sessions where attendees can exchange information, ideas and strategies about trends in various focus areas, such as:

Arbitrators and Arbitrations
Pandemic Response and Recovery
Labor Negotiation Trends
Special Education Hotspots
Tax Assessment Litigation Developments
Developing Policies Protecting Transgender Students

Save the Date: School Law Workshop - September 27, 2021
The School Law Workshop on Monday, September 27 will be an in-person event, as planned, at Kalahari Resorts & Conventions in the Pocono Mountains. More information to come!

CONTINUING LEGAL EDUCATION WEBINARS

The Continuing Legal Education (CLE) Distance Learning area of the PSBA website and distance learning platform has gone live and is now available here! This spring, PSBA concluded a 12-week series of CLE webinars for attorneys. Recordings of these webinars can be accessed at any time, at the convenience of the participant. Most recorded programs provide one CLE credit hour. A list of currently available programs that can be purchased for viewing and credit can be found here.

Questions? Contact PSBA Legal Services staff at clelegal@psba.org.

INFORMATION FROM PSBSA

For questions about Pennsylvania School Board Solicitors Association (PSBSA) membership status and dues invoices, as well as about the PSBSA officers, board of directors, bylaws and other governance information, please call Stuart Knade at (800) 932-0588, ext. 3377, or email him at Stuart.Knade@psba.org.

The Solicitors Association is looking forward to the upcoming year of programs and dissemination of information regarding legal developments in school law. If you have ideas for legal programs, please send the ideas to your regional director or Stuart Knade or Linda Randby.

Let us Know
Got a tip, a link, a correction, a question, a comment, an observation, a clarification, a wisecrack, an idea you’d like to see addressed? We are always glad to hear from you.

Have you changed your email address, mailing address, or phone number? Please let us know. For questions about this publication, contact Linda Randby (717) 506-2450, ext. 3378.

School Board Solicitors Association Officers

John G. Audi, Esq., President
Rachel K. Lozosky, Esq., President-Elect
Benjamin L. Pratt, Esq., Secretary
Vincent L. Champion, Esq., Immediate Past-President

Legal Services Team

Stuart L. Knade, Esq.
Linda J. Randby, Esq.

Copyright © 2021 Pennsylvania School Boards Association, All rights reserved.
No claim of copyright to information on other websites or to original U.S. Government Works.

The School Law EDition is a biweekly publication of the Pennsylvania School Board Solicitors Association (PSBSA) and the Pennsylvania School Boards Association (PSBA). This publication is distributed to members of the Solicitors Association and administrators who have purchased the comprehensive subscription package. Except for distribution within the school entity or law office, no part of this publication may be reproduced, stored in a retrieval system or transmitted in any form or by any means, electronic or mechanical, including photocopying, recording, or otherwise, without the prior written permission of PSBA. This material cannot be shared with other school entities or law firms. All inquiries about reprint permission should be sent to Linda Randby, Editor.

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