Friends of Team Charter Schools, Inc. v. Board of Education of the City of Newark, Etc.

New Jersey Superior Court Appellate Division·Decided January 29, 2026·No. A-1422-23·Published

Opinion

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION

SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION

DOCKET NO. A-1422-23

FRIENDS OF TEAM CHARTER SCHOOLS, INC., APPROVED FOR PUBLICATION

Petitioner-Appellant, January 29, 2026

v. APPELLATE DIVISION

BOARD OF EDUCATION OF THE CITY OF NEWARK, ESSEX COUNTY,

Respondent-Respondent.

Submitted October 21, 2025 – Decided January 29, 2026 Before Judges Sumners, Chase, and Augostini.

On appeal from the New Jersey Commissioner of Education, Docket No. 55-4/21.

Johnston Law Firm LLC, attorneys for appellant (Thomas O. Johnston, on the briefs).

Sattiraju & Tharney, LLP, attorneys for respondent Board of Education of the City of Newark (Matthew J.

Tharney, of counsel and on the brief).

Matthew J. Platkin, Attorney General, attorney for respondent New Jersey Commissioner of Education (Donna Arons, Assistant Attorney General, of counsel;

Ryan J. Silver, Deputy Attorney General, on the brief).

The opinion of the court was delivered by SUMNERS, JR., C.J.A.D.

The issue before us, one of first impression, is whether the Newark Board of Education (School Board) needs prior approval of the Commissioner of Education under the Educational Facilities Construction and Financing Act (EFCFA), N.J.S.A. 18A:7G-1 to -48, to pursue Superior Court litigation to enforce its contractual reversionary rights to property it transferred to the Newark Housing Authority pursuant to a Site Disposition and Development Agreement (agreement). The agreement provided the School Board with rights of reversion if the property is not developed for "housing, redevelopment and economic development" purposes within three years of the school's transfer.

The School Board sued the Housing Authority and Friends of Team Charter Schools, Inc. (FTCS)—which purchased the property from the Housing Authority for use as a charter school—in the Chancery Division to enforce its reversionary rights because the property was not used in accordance with the agreement.

After FTCS's motion to dismiss was denied, it petitioned the Commissioner to require that the School Board obtain the Commissioner's approval under the EFCFA before the School Board can litigate its purported

A-1422-23

reversionary rights. The Commissioner denied relief, deciding that the School Board's litigation to reclaim ownership was "neither a school facilities project nor a land acquisition as contemplated under EFCFA and the related regulations; and that neither EFCFA nor the related regulations required [the School Board] to seek approval from the Commissioner prior to initiating the enforcement litigation." The Commissioner added the EFCFA would only take effect if the School Board reacquired the property and used it for a school facilities project.

We conclude that under our standard of review, the Commissioner's decision was not arbitrary, capricious, or unreasonable because the Commissioner properly interpreted the EFCFA. The Commissioner did not–– nor do we––determine whether the School Board has reversionary rights to the property through its agreement with the Housing Authority. That must be decided in the School Board's pending Superior Court litigation.

I.

In April 2016, the School Board transferred 33-47 Maple Avenue (Maple Avenue School) and eleven other "unutilized or under-utilized public school sites" to the Housing Authority for nominal consideration 1 based upon the "experience, expertise and resources available to [the Housing Authority] in

1 The consideration for Maple Avenue School was for $1.

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order to pursue development and housing opportunities." The parties' transfer agreement provided that the properties were to be sold to third parties for the development of "Site Projects," limited to "housing, redevelopment and economic development" projects. The School Board maintained a "right of reversion" to any of the properties if they were not developed for a Site Project "within three (3) years from the date" the agreement was executed. The Housing Authority's resolution approving the agreement acknowledged the transfers were in accordance with N.J.S.A. 18A:20-9, which provides that if a property "shall cease to be used for any of the purposes contemplated by this section, such property shall thereupon revert to and the title thereof shall vest in the board of education making the conveyance thereof hereunder."

In December 2017, the Housing Authority sold the Maple Ave. School to developer 33 Maple Urban Renewal LLC (33 Maple) for approximately $1 million. In March 2020, 33 Maple sold the property to FTCS for $10 million. The property was renovated and leased to TEAM Academy Charter School, Inc. to house its charter school.

On April 6, the School Board sued the Housing Authority in the Chancery Division to enforce its reversionary rights because the Maple Avenue School was being used as a charter school, a non-permitted use under the transfer

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agreement with the Housing Authority. The School Board did not obtain approval from the Commissioner before suing. FTCS was subsequently added as a defendant. On December 15, the Chancery Division denied FTCS's motion under Rules 4:69-6 and 4:6-2(e) to dismiss the complaint.2 Undeterred, FTCS sought administrative relief. On April 13, 2021, it filed a two-count petition of appeal with the Commissioner. In count one, FTCS alleged the School Board unlawfully commenced the Chancery Division litigation because "important decisions such as capital projects" and "large facility project[s]" require "a certain vote by [the School Board] . . . and [the] Commissioner of Education['s] submission and approval." In count two, FTCS alleged the litigation was a "school facilities project," obligating the School Board under the EFCFA and its regulations to obtain the Commissioner's approval before seeking judicial relief. FTCS requested the Commissioner declare the litigation unlawful and restrain the School Board from prosecuting the litigation without the Commissioner's approval.

2 The court also dismissed count six of the School Board's amended complaint, tortious interference with prospective economic advantage, against FTCS without prejudice. The court allowed the School Board to amend their complaint within ten days.

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The matter was transferred to the Office of Administrative Law as a contested matter. An Administrative Law Judge (ALJ) granted the School Board's motion to dismiss the petition as untimely.

On October 19, 2021, the Acting Commissioner disagreed with the dismissal and remanded the matter to the ALJ to determine whether the Chancery Division litigation "could constitute land acquisition and/or a school facilities project, subject to applicable statutes and regulations."

Following remand, the ALJ heard the parties' respective summary judgment motions. The ALJ denied the motions, determining it was "premature" to decide whether the filing of the Chancery Division litigation constituted a "school facilities project" until the court decided the matter.

On November 14, 2022, the Acting Commissioner again rejected the ALJ's decision, remanding the matter for a ruling on the merits. The Acting Commissioner reasoned "the question of whether the filing of the [Chancery Division] complaint required the approval of the [School] Board, or of the Commissioner as a school facilities project, is ripe for review." The Acting Commissioner instructed the ALJ that: "If it is determined that the [Chancery Division] complaint is a school facilities project, and that the [School] Board

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should have obtained the Commissioner's approval of that project prior to filing the complaint, then the complaint should not proceed."

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Friends of Team Charter Schools, Inc. v. Board of Education of the City of Newark, Etc., (N.J. Ct. App. 2026).

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