B.A.S. v. PA Dept. of Ed. (PSPC)

CourtCommonwealth Court of Pennsylvania
DecidedAugust 11, 2025
Docket1007 C.D. 2024
StatusUnpublished

This text of B.A.S. v. PA Dept. of Ed. (PSPC) (B.A.S. v. PA Dept. of Ed. (PSPC)) is published on Counsel Stack Legal Research, covering Commonwealth Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
B.A.S. v. PA Dept. of Ed. (PSPC), (Pa. Ct. App. 2025).

Opinion

IN THE COMMONWEALTH COURT OF PENNSYLVANIA

B.A.S., : Petitioner : : No. 1007 C.D. 2024 v. : : Argued: April 8, 2025 Pennsylvania Department of : Education (Professional Standards : and Practices Commission), : Respondent :

BEFORE: HONORABLE MICHAEL H. WOJCIK, Judge HONORABLE CHRISTINE FIZZANO CANNON, Judge HONORABLE LORI A. DUMAS, Judge

OPINION NOT REPORTED

MEMORANDUM OPINION BY JUDGE DUMAS FILED: August 11, 2025

B.A.S. petitions for review from the order entered by the Professional Standards and Practices Commission (Commission), suspending her teaching certificate under the Educator Discipline Act (Act).1 B.A.S. contends that the Commission’s adjudicatory framework violates the law and the Commission relied on inadmissible hearsay to find she posed a threat to students. We affirm in part, reverse in part, vacate in part, and remand. I. BACKGROUND2 B.A.S. was a teacher in Westmoreland County when, in 2023, she was 1 Act of December 12, 1973, P.L. 397, as amended, 24 P.S. §§ 2070.1a-2070.18a. The Act’s section numbers are distinct from “the sections provided in Purdon’s Pennsylvania Statutes, which is an unofficial codification of Pennsylvania law.” Herold v. Univ. of Pittsburgh, 329 A.3d 1159, 1166 n.1 (Pa. 2025). We refer to provisions of the Act “only by their Purdon’s citation.” Id. 2 We state the facts in the light most favorable to the Department as the prevailing party. See Cinram Mfg., Inc. v. Workers’ Comp. Appeal Bd. (Hill), 975 A.2d 577, 583 (Pa. 2009); M.T. v. Dep’t of Educ., 56 A.3d 1, 9 (Pa. Cmwlth. 2010); Boguslawski v. Dep’t of Educ., 837 A.2d 614, 616 charged with multiple counts of endangering the welfare of children, 18 Pa.C.S. § 4304(a)(1). Notice of Charges, 4/11/24, at Ex. 1 (criminal complaint and affidavit of probable cause). According to the affidavit of probable cause, in 2023, B.A.S., inter alia, (1) sprayed lemon juice and soapy water on one student, and (2) improperly restrained other students on multiple occasions. Id. B.A.S. was arrested and the charges bound over after a preliminary hearing. In 2024, the Department of Education (Department) commenced disciplinary proceedings via a notice of charges that attached the criminal complaint, affidavit of probable cause, and criminal docket. B.A.S. admitted she was charged and requested a hearing.3 At the hearing, the Department introduced the criminal complaint, affidavit of probable cause, and criminal docket. B.A.S. objected based on hearsay, contending that the documents contained double hearsay. Notes of Testimony (N.T.), 5/13/24, at 16-17, 23. B.A.S. noted the “multiple levels of hearsay contained in the police complaint and the affidavit of probable cause.” Id. at 20. In her view, the Department was “bootstrapping” the hearsay to prove that B.A.S. posed a threat to the safety of students. Id. The Department countered that the documents were not hearsay because they were “not being offered to prove the truth of the allegations asserted within . . . .” Id. at 18. In support, it emphasized it was offering the documents “to establish the conduct underlying why [B.A.S.] was charged in this matter,” id., because the “general nature of the allegations” alone was “sufficient evidence to prove the threat component.” Id. at 21.4 The hearing officer overruled the hearsay

n.2 (Pa. Cmwlth. 2003). 3 In this case, the hearing officer was not empowered to decide anything. Rather, the Commission directed the hearing officer to only hold an evidentiary hearing and certify the record. See generally 24 P.S. §§ 2070.13(c), 2070.14. 4 For completeness, the Department argued as follows: “With regards to the hearsay

2 objection and admitted the documents. Id. at 24. Neither party presented any witnesses before resting. The hearing officer did not bar B.A.S. from rebutting the Department’s case. Id. at 28. Both parties filed post-hearing briefs and proposed findings of fact. See, e.g., Dep’t’s Br., 6/10/24, at 17-18 (maintaining that either the charges or allegations underlying the charges established that B.A.S. posed a threat); B.A.S.’s Br., 6/10/24, at 6 (arguing “the Department relied only on documents that contained multiple levels of hearsay to make their case”). The Commission heard oral arguments and suspended B.A.S.’s certificate. The Commission held that the affidavit was not offered for the truth of its contents because the “allegations underlying the” charges support “a finding that the educator poses” a threat. Comm’n Op., 7/10/24, at 9. “The truth of those allegations is immaterial” because the Commission was making “no assertion about the educator’s guilt or innocence of the charges alleged in the indictment.” Id. In sum, the Commission held that because the affidavit “was not offered for the truth of the matter asserted, it cannot be characterized as hearsay.” Id. The Commission rendered 14 findings of fact, all but 4 of which were based on the affidavit. Id. at 3-5 (qualifying each such finding with the phrase, “According to the affidavit” and, for example, referencing witness statements). The Commission noted that B.A.S. failed to present any evidence or testimony that she did not pose a threat. Id. at 8. Based on its findings, the Commission held that the Department proved that B.A.S. poses a threat to students. Id. at 5. The Commission argument, these documents are not hearsay. They are not being offered to prove the truth of the allegations asserted within the document. We’re purely offering them to establish the conduct underlying why [B.A.S.] was charged in this matter. . . . The Commission is not tasked with determining whether the allegations are true for the purposes of an immediate suspension, but rather that they exist.” N.T. at 18-19. The “Commission repeatedly has found that just the general nature of the allegations is sufficient evidence to prove the threat component.” Id. at 21.

3 explained that “an indictment alone can satisfy both prongs of the Department’s burden because the indictment is an ‘objective fact’ that must be based upon probable cause.” Id. at 10-11. Combined with the magistrate judge’s holding that probable cause existed, the Commission reasoned that if it accepted the factual allegations as true, B.A.S. was unfit to protect her students. Id. at 8-9, 11. B.A.S. timely appealed. II. ISSUES First, B.A.S. contends that the Commission’s legal framework improperly removes the Department’s burden to prove that B.A.S. poses a threat to students. B.A.S.’s Br. at 4. Second, B.A.S. alleges the Commission erred by relying on hearsay within the indictment to prove she posed a threat to students. Id. III. DISCUSSION5 A. No Rebuttable Presumption Exists In support of her first issue, B.A.S. argues that the Commission’s framework for implementing the Act’s hearing shifted the burden of proof to her to disprove that she posed a threat to students. Id. at 11-12. B.A.S. reasons that at the hearing, the Department was required to “adduce evidence” to prove she was a threat. Id. at 11. B.A.S. faults the Commission for creating a “rebuttable presumption based solely on the existence of the indictment.” Id. at 12. In her view, the indictment is not evidence she poses a threat, and thus, the Commission essentially required B.A.S. “to prove she is not a threat.” Id. at 13. In support, she reasons that the Act requires a meaningful hearing, which cannot occur if the Commission allows

5 We must affirm the agency’s order unless we conclude that it violates the petitioner’s constitutional rights, violates the law, or any fact necessary to the order is unsupported by substantial evidence. 2 Pa.C.S. § 704. “Substantial evidence is more than a mere scintilla.

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