Reid Wilkes, V. State Board Of Education

CourtCourt of Appeals of Washington
DecidedAugust 8, 2022
Docket83337-5
StatusUnpublished

This text of Reid Wilkes, V. State Board Of Education (Reid Wilkes, V. State Board Of Education) is published on Counsel Stack Legal Research, covering Court of Appeals of Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Reid Wilkes, V. State Board Of Education, (Wash. Ct. App. 2022).

Opinion

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON REID WILKES AND ADRIENNE STUART, on their own behalf and on behalf of J.W. No. 83337-5-I and C.W., their two children in public schools, CRISTINE BECKWITH, on her DIVISION ONE own behalf and on behalf of B.B. and G.B., her two children in public schools, and UNPUBLISHED OPINION CAROLINA LANDA, on her own behalf and on behalf of Z.L., her child in public schools,

Appellants,

v.

WASHINGTON STATE BOARD OF EDUCATION and WASHINGTON OFFICE OF THE SUPERINTENDENT OF PUBLIC INSTRUCTION,

Respondents.

COBURN, J. — Parents Reid Wilkes, Adrienne Stuart, Christine Beckwith

and Carolina Landa, on their own behalf and on behalf of their children 1 with

disabilities (referred to collectively as the families), appeal the trial court’s

dismissal of their challenge to an April 29, 2020 emergency rule promulgated by

the Office of the Superintendent of Public Instruction (OSPI). The rule permitted

1 Wilkes and Stuart’s children are J.W. and C.W. Beckwith’s children are B.B. and G.B. Landa’s child is Z.L.

Citations and pin cites are based on the Westlaw online version of the cited material. No. 83337-5-I/2

school districts to temporarily petition for funding waivers when they could not

meet school day and instructional hour requirements as a result of school

closures related to the COVID-19 pandemic.

The trial court dismissed the families’ challenge as moot, finding that their

requested remedies were unavailable as the rule had already expired at the time

of the court proceedings. The families appeal the dismissal, arguing that even if

their challenge is moot, their challenge is eligible for the “substantial and

continuing interest” exception. We disagree and affirm.

FACTS

On March 13, 2020, Governor Jay Inslee ordered the statewide closure of

public schools in response to the COVID-19 pandemic. On April 7, 2020, the

Governor extended the closure order to the end of the 2019-2020 school year.

Three weeks later, on April 29, 2020, OSPI invoked its emergency rule-

making authority pursuant to RCW 34.05.350 2 by filing with the Office of the

Code Reviser a new rule for immediate adoption to address the emergency

school closures in the 2019-2020 school year. Wash. St. Reg. (WSR) 20-10-044,

WAC 392-901 (effective Apr. 29, 2020). OSPI’s stated purpose for the rule was

to

2 Under RCW 34.05.350(1), if an agency for good cause finds: (a) That

immediate adoption, amendment, or repeal of a rule is necessary for the preservation of the public health, safety, or general welfare, and that observing the time requirements of notice and opportunity to comment upon adoption of a permanent rule would be contrary to the public interest . . . (2) An emergency rule adopted under this section takes effect upon filing with the code reviser, unless a later date is specified in the order of adoption, and may not remain in effect for longer than one hundred twenty days after filing.

2 No. 83337-5-I/3

establish the terms and conditions governing local education agencies’ entitlement to receive state basic education apportionment allocations during the 2019-2020 school year when the local education agencies could not offer the statutory minimum number of school days or annual average total instructional hour offerings due to emergency closures caused by the COVID-19 pandemic and other unforeseen events. The emergency rulemaking also addresses standards for continuous learning for the remainder of the 2019-2020 school year. OSPI stated that “observing the time requirements of notice and opportunity to

comment upon adoption of a permanent rule would be contrary to the public

interest,” and further explained that

[g]iven the unprecedented effects of the COVID-19 pandemic and the closure of school facilities for the remainder of the 2019-2020 school year, the immediate adoption of this rule is necessary for the preservation of public health, safety, and the general welfare.

OSPI’s April 29, 2020 rule, codified as chapter 392-901 WAC, created

emergency funding waivers that permitted local education agencies (LEAs) 3 to

petition the superintendent to receive full annual funding apportionment when,

due to an emergency school closure, they were unable to meet the 180 school

days and approximately 1,000 4 instructional hours required by RCW

28A.150.220. WSR 20-10-044, WAC 392-901-025, 035, RCW

28A.150.220(2)(a), (5)(a).

The emergency rule cited to RCW 28A.150.290 as OSPI’s authority for

adopting WAC 392-901. Former WAC 392-901-005 (2020). RCW

3 “Local educational agency” refers to school districts, charter schools, or

state-tribal education compact schools. WSR 20-10-044, WAC 392-901-020(4). 4 RCW 28A.150.220(2) states that a basic education includes an average

of 1,000 instructional hours for students in kindergarten through eighth grade and 1,080 instructional hours for grades nine through twelve.

3 No. 83337-5-I/4

28A.150.222(1) permits the superintendent of public instruction to grant waivers

for the 180 day school year, but states that the superintendent may not waive the

minimum instructional hours required by RCW 28A.150.220. However, RCW

28A.150.290 permits the state superintendent to make rules and regulations that

allow school districts to receive state basic education funding when districts are

unable to fulfill the 180 days or instructional hour requirements due to “[a]n

unforeseen natural event” such as an “epidemic . . . that has the direct or indirect

effect of rendering one or more school district facilities unsafe, unhealthy,

inaccessible, or inoperable.”

LEAs could become eligible for an OSPI funding waiver by (1)

implementing a plan that meets certain minimum standards for continuous

learning, 5 (2) the LEA’s governing board supporting the waiver request and

adopting a resolution to approve the continuous learning plan by May 11, 2020,

(3) extending the school year by at least five days, and (4) submitting an

application to the superintendent requesting a waiver. WSR 20-10-044, WAC

5 “Continuous learning” is defined as “establishing and maintaining

connections with students and families to provide learning materials and supports using a variety of modalities including, but not limited to, email, telephone, printed learning materials, or available online platforms, taking into account recommendations provided by [OSPI] in its published guidance and as required under this chapter and applicable state and federal law.” WSR 20-10-044, WAC 392-901-020(1).

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