Parents United for Better Schools, Inc. v. School District of Philadelphia Board of Education

646 A.2d 689, 166 Pa. Commw. 462, 1994 Pa. Commw. LEXIS 454
CourtCommonwealth Court of Pennsylvania
DecidedAugust 5, 1994
Docket2670 C.D. 1992
StatusPublished
Cited by22 cases

This text of 646 A.2d 689 (Parents United for Better Schools, Inc. v. School District of Philadelphia Board of Education) 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
Parents United for Better Schools, Inc. v. School District of Philadelphia Board of Education, 646 A.2d 689, 166 Pa. Commw. 462, 1994 Pa. Commw. LEXIS 454 (Pa. Ct. App. 1994).

Opinions

DOYLE, Judge.

Parents United for Better Schools (PUBS) appeals an order of the Court of Common Pleas of Philadelphia County dismissing their complaint in equity for lack of standing.

On June 24, 1991, the Board of Education of the School District of Philadelphia adopted Policy 123 entitled Adolescent Sexuality (Policy 123). Policy 123 provides for the development of broad, abstinence-based curricula focused at preventing sexually transmitted diseases. The program includes a provision for the availability of condoms to students upon request at school-based health clinics.

On December 2, 1991, letters were mass-mailed to parents by the principals of the pilot schools of the program advising them of the availability of condoms to students as part of the “health services” program. Parents were informed that they were required to reply only if they did not wish for their child to participate in the program. Parents were asked to respond within two weeks. The condom distribution program began on December 17, 1991.

PUBS, a non-profit corporation, many of whose members have children who attend public high schools in Philadelphia, and seven individuals1 filed a complaint in equity on January 13, 1992, seeking injunctive and declaratory relief. PUBS alleged, among other things, that its right to affirmatively consent prior to the rendition of health or medical services at school is violated by the Policy 123 “opt-out” provision. That is, parents do not expressly consent to the distribution of condoms to their children, but their consent is presumed by a parent’s lack of response to the letter sent by the principals.

[465]*465The Board filed a motion for judgment on the pleadings which was denied. The case was listed for trial; the Board filed a motion for summary judgment, asserting that PUBS lacked standing to sue and, therefore, their complaint should be dismissed. The trial court granted the motion, and this appeal followed.2

PUBS argues that (1) the trial court erroneously found that they had failed to assert an adversely affected interest; and (2) erroneously failed to consider the organizational standing of PUBS when it held that PUBS had failed to allege an interest separate and distinct from the seven individually named plaintiffs.

The essential inquiry in determining the standing of a litigant is:

Have the [litigants] alleged such a personal stake in the outcome of the controversy as to assure the concrete adverseness which sharpens the presentation of issues upon which the court so largely depends for illumination of difficult ... questions.

Baker v. Carr, 369 U.S. 186, 204, 82 S.Ct. 691, 703, 7 L.Ed.2d 663 (1962). Taking guidance from federal interpretation of standing principles, our Supreme Court has outlinéd the factors which must be considered in William Penn Parking [466]*466Garage, Inc. v. City of Pittsburgh, 464 Pa. 168, 346 A.2d 269 (1975). First, the litigant must allege an interest which has been adversely affected; that is, has the party been harmed by the action which is challenged. Second, there must be a discernible adverse effect to some interest other than that shared by the public at large. Third, the adverse effect must be direct and immediate, and not remote in consequences. Id.

First, PUBS contends that the trial court erred in dismissing their complaint for lack of standing. We agree.

PUBS argues that Policy 123 improperly infringes on the common law parental right to expressly consent before medical treatment is administered to their minor children because the condom distribution program presumes consent by a parent’s silence (not sending in the “veto” form):

The requirements of prior parental consent (opt-in) and parental veto (opt-out) are functionally and procedurally different. Parental consent is more stringent, more protective of the rights at stake because it requires the entity seeking consent to wait until consent is affirmatively given. For example, if a parent does not act, consent is not given. Opt-out, on the other hand, allows the entity seeking approval to proceed until the parent actually vetoes their child’s participation. For example, if a parent does not act, consent is assumed.

PUBS Brief at 8.

The principle that parental consent must be secured before medical treatment provided is time honored and has been recognized by both the courts and the legislature.3 Generally, it is for the parent in the first instance to decide what is actually necessary for the protection and preservation of the life of his or her child. 59 Am.Jur.2d Parent and Child § 48 (1987); 67A C.J.S. Parent and Child § 11 (1978). Hence, medical personnel can be found liable for treating a child without the consent of the parent, even where the child [467]*467appears to have consented. See, e.g., Zaman v. Schultz, 19 D & C 309 (1933) (parents recovered damages because blood was taken from their minor child without their express consent).

The legislature also has recognized the principle of express prior parental consent. There are numerous statutes which forbid or punish certain activities that may endanger minors and, therefore, require prior parental consent. E.g., Section 6311 of the Crimes Code, 18 Pa.C.S. § 6311 (it is a misdemeanor to tattoo a minor without the prior consent of a parent).4

Parental consent is further recognized by the exceptions which have been carved out by the legislature, most notably the Minor’s Consent to Medical, Dental and Health Services, Act of February 13, 1970, P.L. 19, 35 P.S. §§ 10101-10105, which enumerates the specific circumstances where express parental consent is not necessary for the administration of medical treatment. See also Section 1 of the Act of December 9, 1969, P.L. 333, as amended, 35 P.S. § 10001 (a minor under the age of seventeen cannot donate blood without the prior consent of a parent); Section 12 of the Pennsylvania Drug and Alcohol Abuse Control Act, Act of April 14, 1972, P.L. 221, as amended, 71 P.S. § 1690.112 (parental consent is not necessary for the treatment of substance abuse); Section 14.1 of the Disease Prevention and Control Law of 1955, Act of April 23, 1956, P.L. (1955) 1510, as amended, 35 P.S. § 521.14a (no liability attaches for the treatment of a minor for venereal disease). Our review of these statutes leads us to the conclusion that the principle that a parent must consent to certain activities prior to the commencement of those activities, while not an absolute right or without limit, is nevertheless a recognized and substantial interest that can be protected.

[468]*468The Board argues that PUBS has failed to allege any interest that is not common to the public at large in that they are only attempting to protect a general right to “raise their children in the way in which they see fit.” We strongly disagree. PUBS has articulated a specific and substantial right which they perceive has been improperly limited by a specific action of the Board, viz. Policy 128. It is not relevant that it is an interest shared by all parents of Philadelphia schoolchildren.

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Bluebook (online)
646 A.2d 689, 166 Pa. Commw. 462, 1994 Pa. Commw. LEXIS 454, Counsel Stack Legal Research, https://law.counselstack.com/opinion/parents-united-for-better-schools-inc-v-school-district-of-philadelphia-pacommwct-1994.