Save Our School v. Colonial School District

628 A.2d 1210, 156 Pa. Commw. 671, 1993 Pa. Commw. LEXIS 412
CourtCommonwealth Court of Pennsylvania
DecidedJuly 8, 1993
Docket1517 C.D. 1992
StatusPublished
Cited by11 cases

This text of 628 A.2d 1210 (Save Our School v. Colonial 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
Save Our School v. Colonial School District, 628 A.2d 1210, 156 Pa. Commw. 671, 1993 Pa. Commw. LEXIS 412 (Pa. Ct. App. 1993).

Opinion

SMITH, Judge.

Colonial School District (District) and the nine members of its School Board appeal a July 7, 1992 order of the Court of Common Pleas of Montgomery County granting Save Our School’s preliminary injunction ordering the School Board to rescind a resolution closing the Conshohocken Elementary School (CES) and enjoining it from voting to close CES at its scheduled August 20, 1992 meeting without fully complying with Section 780 of the Public School Code of 1949 (Code), Act of March 10, 1949, P.L. 563, as amended, added by Section 1 of the Act of April 4, 1984, P.L. 19, 24 P.S. § 7-780. 1 The *674 issues presented here are whether the trial court erred in concluding that the School Board voted to close CES at its April 23, 1992 meeting; and whether the trial court erred when it determined that Section 780 of the Code applied to the School Board’s actions.

In an appeal from the entry of an order granting a preliminary injunction, this Court’s scope of review is to determine whether there were any apparently reasonable grounds in the record to justify its issuance. Fischer v. Department of Public Welfare, 497 Pa. 267, 439 A.2d 1172 (1982). This Court will not interfere with the trial court’s decision absent a plain abuse of discretion, where no grounds exist to support the decree, or where the rule of law relied upon was palpably misapplied. Unionville-Chadds Ford School District v. Rotteveel, 87 Pa.Commonwealth Ct. 334, 487 A.2d 109 (1985).

Furthermore, for a preliminary injunction to be sustained, the plaintiffs right to relief must be clear, the need for relief must be immediate, and the injury must be irreparable if the injunction is not granted. Id. Although courts are not super school boards and should not interfere with the discretionary exercise of a school board’s power, a mandatory preliminary injunction interfering with that discretion is appropriate where a school board’s action is based on a misconception of the law. Id. This Court must therefore examine the factual and legal bases for the issuance of the preliminary injunction and determine whether there were apparently reasonable grounds for the trial court’s action.

At the hearing before the trial court, Save Our School introduced the testimony of the District superintendent, Dr. Stanley Durtan, who testified that in the fall of 1992, the District began considering options to maintain acceptable student-to-teacher ratios in its schools. At a March 16, 1992 *675 meeting, Dr. Durtan presented the School Board with a list of options including what came to be known as “Option Three” which required closing one of the District’s kindergarten through third grade (K-3) schools and reassigning its students to the District’s remaining schools. Dr. Durtan testified that the drafting and presentation of Option Three was premised upon the closing of CES. After studying the issue, the District reduced the number of available options to four, including Option Three.

Dr. Durtan placed in the April 8, 1992 Norristown Times Herald the following notice:

Pursuant to Section 780 of the Public School Code of 1949, a public hearing will be held at 7:30 p.m. on Thursday, April 23, 1992 on the question of a permanent closing of a public school in the Colonial School District. The meeting will be held in the Administrative Board Room of the Colonial Elementary School.

The notice did not specify the name of the school targeted for closing. In addition, before the April 23 hearing, the District sent to the parents of CES students a “news alert” which explained the four options and stated that if CES were closed, about 297 CES K-3 students would be reassigned to other schools. The news alert did not mention the possibility of closing any schools other than CES.

The April 23 public hearing was not held in the Colonial Elementary School as advertised, but rather at the PlymouthWhitemarsh High School. On that same date, the School Board held its regular monthly meeting. When the special public hearing began, the president of the School Board announced that the one-half hour hearing was being held to consider the closing of CES, and that it would also address the issue during its regular session following the special hearing. During its regular session, the School Board continued to discuss the closing of CES, and then passed a resolution adopting Option Three. The president of the School Board gave assurances that the District would maintain the closed CES building.

*676 Although the final draft of the minutes of the School Board’s April 28 regular session does not specifically mention that the Board was closing CES, the School Board president testified that he was referring to CES when he discussed the closed school building. 2 Dr. Durtan testified that shortly after the Board adopted Option Three, all CES students were assigned to other schools, the CES principal and all CES teaching and support staff were reassigned, and all items pertaining to CES were deleted from the District’s budget. Notwithstanding the above evidence, the District maintains that it did not vote to close CES at its April 23 meeting, but merely adopted a redistricting plan. However, as the record indicates, there were apparently reasonable grounds for the trial court to find that the School Board’s April 23 action was a vote to permanently close CES.

The District next argues that it has the statutory authority to close a school without notice to the public and without holding a public hearing because Section 1311 of the Code, 24 P.S. § 13-1311, authorizes school boards to close public schools in their districts. 3 In 1984, however, the legislature enacted Section 780 of the Code which sets forth specific procedures to involve the public in school board decisions related to closings of public schools. Section 780 clearly requires that school boards obtain community input at a duly advertised public meeting at least three months before voting to permanently close a school or substantially all of its facilities. Since the adoption of Option Three had the effect of *677 permanently closing CES, the School Board was required to comply with Section 780. Because the public hearing was held on the same night that the Board voted to close CES, it violated the three-month waiting period required by Section 780. Therefore, the trial court did not err in ordering the Board to rescind its Option Three resolution to the extent that it had the effect of closing CES. 4

The trial court’s July 7 order also enjoined the School Board from voting to close CES on August 20 because the notice for the April 23 public meeting did not specify the name of the school being considered for closing.

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Bluebook (online)
628 A.2d 1210, 156 Pa. Commw. 671, 1993 Pa. Commw. LEXIS 412, Counsel Stack Legal Research, https://law.counselstack.com/opinion/save-our-school-v-colonial-school-district-pacommwct-1993.