Ronald H. Brown Charter School v. Harrisburg City School District

928 A.2d 1145, 2007 Pa. Commw. LEXIS 362
CourtCommonwealth Court of Pennsylvania
DecidedJuly 5, 2007
StatusPublished
Cited by12 cases

This text of 928 A.2d 1145 (Ronald H. Brown Charter School v. Harrisburg City School District) 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
Ronald H. Brown Charter School v. Harrisburg City School District, 928 A.2d 1145, 2007 Pa. Commw. LEXIS 362 (Pa. Ct. App. 2007).

Opinion

OPINION BY

Judge PELLEGRINI.

The Ronald H. Brown Charter School (School) appeals from an order of the State Charter School Appeal Board (Board) upholding the decision of the Harrisburg City School District (School District) denying renewal of the School’s charter for violations of the charter.

The School was granted a five-year charter in January 2000 and was operating as a Pennsylvania Charter School pursuant to Section 1701-A of Act 22 of 1997 (the Charter School Law) 1 24 P.S. § 17-1701-A. On November 30, 2004, the School applied to the School District to renew its charter. 2 Three days of hearings were held to determine if the charter should be renewed. On September 12, 2005, the Board of Control of the School District determined that the School’s charter should not be renewed based on its failure to comply with, among other violations, 3 the financial and performance standard requirements pursuant to Section 1729-A(a)(l)-(4) of the Charter School Law, 24 P.S. § 17-1729-A(a)(l)-(4). 4

*1147 On October 14, 2005, the School appealed to the Board which was comprised of seven members. However, while the appeal was pending before the Board, there were two vacancies on the Board leaving only five Board members. On May 23, 2006, only four of the five Board members were present constituting a quorum, one of those members having previously recused, leaving three members of the Board to vote on the School’s appeal. Those three remaining members voted unanimously to affirm the Board of Control’s revocation of the School’s charter. Based on that vote, a written order with findings of fact and conclusions of law was entered on July 19, 2006, denying the School’s appeal and affirming the decision of the School District. This appeal followed. 5

I.

On appeal, 6 the School argues that the Board’s decision is invalid because Section 1721-A(b) of the Charter School Law, 24 P.S. § 17-1721-A(b), requires that four members, not three members, were needed to vote on its renewal petition. That section provides:

A majority of the members of the appeal board shall constitute a quorum, and a majority of the members of the appeal board shall have authority to act upon any matter properly before the appeal board.

The School District responded stating that at common law, once a quorum was established, only a majority of the quorum was needed to act on a matter. Because there was an even number under the School’s interpretation as a quorum of four members were present, the question then is whether this provision requires a majority of the members present to vote or whether a majority of the members of the Board at full strength — seven—is required to take action.

Unless there is contrary legislative intent to the common law rule requiring a vote of a full body to be valid, all that is needed is a majority of a quorum to take action; not that all the members of the Board must vote who are authorized but are not seated. In DiGiacinto v. City of Allentown, 486 Pa. 436, 406 A.2d 520 (1979), our Supreme Court explained the common law rule and the policy reasons behind the rule as follows:

In determining the number of votes necessary for a deliberative body to take official action, Pennsylvania follows the common law rule. Stoltz v. McConnon, 473 Pa. 157, 373 A.2d 1096 (1977); *1148 Munce v. O’Hara, 340 Pa. 209, 16 A.2d 532 (1940); see also Commonwealth of Pennsylvania ex rel. Zimmerman v. Kleiman, 485 Pa. 421, 402 A.2d 1343 (1979); Federal Trade Commission v. Flotill Products, 389 U.S. 179, 88 S.Ct. 401, 19 L.Ed.2d 398 (1967). Under the common law rule so long as a quorum is present at a meeting, all that is required is that the highest vote be equal to a majority of the quorum number, even though the highest vote constitutes only a plurality of all the legal votes cast. This is true even if more than the quorum number is present at the meeting. For example, if there are seven members of a body and four of those members constitute a quorum and attend a meeting, a majority of the four, which would be three, is necessary to take official action of any kind. Even if all seven members, more than the necessary quorum of four, attend the meeting, the same number of votes, namely three, is all that is necessary to take official action if that is the highest number of votes cast (plurality) in a given matter. Thus, if the minimum quorum of four is present, and the vote on a particular proposal is 3 in favor and 1 against, the proposal is adopted. If all seven members of the body attend and the vote on a particular proposal is 3 in favor, 1 against and 3 abstentions, the proposal is likewise adopted by the plurality vote. Cf. United States v. Ballin, 144 U.S. 1, 12 S.Ct. 507, 36 L.Ed. 321 (1892) (statute lawfully enacted where vote in House of Representatives was 138 yeas, 0 nays, and 189 not voting). Under this common law rule, in a seven-person body, the highest number of votes necessary to take official action is not dependent upon the fortuity of whether 4, 5, 6, or 7 members choose to attend the meeting so long as the minimum quorum number is present. If the rule were otherwise, a member could attend the meeting and abstain from voting and have a different effect than if that person were absent from the meeting. The common law rule does not permit a member to attend and abstain from voting and yet demand that the highest number of votes required to take official action be more than if that member had been absent. This Court has previously observed that a member who attends a meeting and abstains can have the same paralytic effect as one who is absent: “[Ojne or a relatively few persons could, by their intentional absence from, or by their presence at a meeting and their failure to vote, or their casting a blank or illegal ballot, block indefinitely an important election or important legislation and thus paralyze government with obviously great harm to the public interest.” Meixell v. Borough Council of Borough of Hellertown, 370 Pa. 420, 425, 88 A.2d 594, 596. (Emphasis added.)

Zemprelli v. Daniels, 496 Pa. 247, 436 A.2d 1165 (1981), applied the common law rule and dealt with language in the Pennsylvania Constitution that is similar to that contained in Section 1721-A(b) of the Charter School Law.

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Bluebook (online)
928 A.2d 1145, 2007 Pa. Commw. LEXIS 362, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ronald-h-brown-charter-school-v-harrisburg-city-school-district-pacommwct-2007.