T. Prozan v. Millcreek Twp. S.D. Bd. of Directors ~ E. Beckes v. N.E. S.D. Bd. of Directors ~ Appeal of: T. Prozan & E. Beckes

CourtCommonwealth Court of Pennsylvania
DecidedMay 9, 2025
Docket1094, 1115, 1225 & 1295 C.D. 2022
StatusPublished

This text of T. Prozan v. Millcreek Twp. S.D. Bd. of Directors ~ E. Beckes v. N.E. S.D. Bd. of Directors ~ Appeal of: T. Prozan & E. Beckes (T. Prozan v. Millcreek Twp. S.D. Bd. of Directors ~ E. Beckes v. N.E. S.D. Bd. of Directors ~ Appeal of: T. Prozan & E. Beckes) 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
T. Prozan v. Millcreek Twp. S.D. Bd. of Directors ~ E. Beckes v. N.E. S.D. Bd. of Directors ~ Appeal of: T. Prozan & E. Beckes, (Pa. Ct. App. 2025).

Opinion

IN THE COMMONWEALTH COURT OF PENNSYLVANIA

Troy Prozan : CONSOLIDATED CASES : v. : : Millcreek Township School : District Board of Directors : : Erin Beckes, Dan Reese, : Dana Richter, Theresa Richter, : Cliff Smathers, Grace Smathers, : Kirra Tupper, Carolyn Brown, : Glenn Craig, Eve Frank, : Sharon Jones, and Ted Jones : : v. : : North East School District : Board of Directors : : Appeal of: Troy Prozan and Erin : No. 1094 C.D. 2022 Beckes :

Troy Prozan : : v. : : Millcreek Township School District : Board of Directors : : Erin Beckes, Dan Reese, : Dana Richter, Theresa Richter, : Cliff Smathers, Grace Smathers, : Kirra Tupper, Carolyn Brown, : Glenn Craig, Eve Frank, : Sharon Jones, and Ted Jones : : v. : : North East School District Board : of Directors : Appeal of: Millcreek Township School : District Board of Directors and North : No. 1115 C.D. 2022 East School District Board of Directors :

Erin Beckes, Carolyn Brown, Daniel : Reese, Sharon Jones, Eve Frank, : Kirra Tupper, Glenn Craig, Theresa : Richter, Dana Richter, Ted Jones, : Grace Smathers and Clifford : Smathers : : v. : : North East School District Board : of Directors, : No. 1225 C.D. 2022 Appellant :

Erin Beckes, Carolyn Brown, Dan : Reese, Sharon Jones, Eve Frank, : Kirra Tupper, Glenn Craig, Theresa : Richter, Dana Richter, Ted Jones, : Grace Smathers and Clifford : Smathers : : v. : : North East School District Board : of Directors : : No. 1295 C.D. 2022 Appeal of: Erin Beckes : Submitted: April 8, 2025

BEFORE: HONORABLE MICHAEL H. WOJCIK, Judge HONORABLE CHRISTINE FIZZANO CANNON, Judge HONORABLE LORI A. DUMAS, Judge

OPINION BY JUDGE FIZZANO CANNON FILED: May 9, 2025

In these consolidated appeals, groups of constituents (Appellants) from two school districts in Erie County (School Districts) assert error by the Court of Common Pleas of Erie County (Trial Court) in dismissing their petitions (Petitions) for removal of the school boards of their respective districts (School Boards). Appellants insist the School Boards of Millcreek School District (Millcreek) and North East School District (North East) should be removed from office because they instituted legally unauthorized mask mandates for students, staff, and others present on school property during the COVID-19 pandemic.1 The School Boards cross- appeal, alleging error by the Trial Court in its exercise of discretion to refuse their requests for awards of litigation costs against Appellants. Upon review, we affirm the Trial Court’s decision in all respects.

I. Background These cases arose against the backdrop of the COVID-19 pandemic, beginning with a Proclamation of Disaster Emergency (Disaster Proclamation) by then-Governor Tom Wolf (Governor Wolf) on March 6, 2020.2 See Corman v. Acting Sec’y of the Pa. Dep’t of Health, 266 A.3d 452, 456 (Pa. 2021). The Disaster Proclamation was issued under the authority of Section 7301(c) of the Emergency Management Services Code,3 35 Pa.C.S. § 7301(c). Pursuant to the Disaster

1 A claim related to this matter was before this Court in a previous appeal filed by Troy Prozan (Prozan), the named plaintiff in the Millcreek action. That appeal related to a separate lawsuit filed by Prozan against Millcreek alleging a violation of the Sunshine Act, 65 Pa.C.S. §§ 710-716, arising from the School Board’s failure to take its official action to authorize its cross- appeal in this action in a public meeting. Prozan v. Millcreek Twp. Sch. Dist. (Pa. Cmwlth., No. 645 C.D. 2023, filed July 16, 2024), slip op. at 2-3. Concluding that Millcreek was not the proper party and that the school directors should have been the named defendants, the trial court dismissed the claim with prejudice. Id. at 5. On appeal, this Court vacated the trial court’s order and remanded to the trial court with a directive to dismiss the claim without prejudice. Id. at 15-16. 2 The Disaster Proclamation is available online at https://www.governor.pa.gov/wp- content/uploads/2020/03/20200306-COVID19-Digital-Proclamation.pdf (last visited May 8, 2025). 3 35 Pa.C.S. §§ 7101-79C13.

2 Proclamation, Governor Wolf, and by his authorization, Pennsylvania’s then- Secretary of Health, Rachel L. Levine (Secretary Levine), issued a series of directives aimed at restricting person-to-person contact throughout Pennsylvania in an effort to combat the spread of the COVID-19 virus. Corman, 266 A.3d at 456. Secretary Levine’s directives included a universal mask mandate, which was subsequently lifted on June 28, 2021, although masking was still urged. Id. at 457 (citing Press Release, “Department of Health Lifting Universal Masking Order on June 28, Urging Pennsylvanians to Follow Mask-Wearing Guidance Where Required,” 6/25/2021 (hereinafter, DOH Press Release)).4 On August 23, 2021, the Erie County Department of Health (Erie DOH) issued an order that masks be worn in all public and private schools.5 Three days later, on August 26, 2021, the Erie DOH rescinded a religious exemption that was originally part of the mask mandate.6 Erie County’s mask mandate for schools was rescinded effective January 6, 2022.7 Appellants demand removal of the elected members of both School Boards because the School Boards continued to require masking after health department public mandates had ended. Appellants maintain that the School Boards refused or neglected to perform mandatory duties imposed on them by the Public

4 Available at https://www.media.pa.gov/pages/health-details.aspx?newsid=1505 (last visited May 8, 2025). 5 Erie County Department of Health, press release, August 26, 2021, available online at https://eriecountypa.gov/erie-county-department-of-health-rescinds-religious-exemption-from- masking-order/ (Erie DOH Press Release) (last visited May 8, 2025). 6 Erie DOH Press Release. 7 Erie County’s School Mask Order Rescinded Starting Wednesday, ERIE NEWS NOW, Jan. 5, 2022, available at https://www.erienewsnow.com/story/45581199/erie-countys-school-mask- order-rescinded-starting-wednesday (last visited May 8, 2025).

3 School Code of 19498 (School Code), within the meaning of Section 318 of the School Code, 24 P.S. § 3-318, because the mask mandates exceeded the authority conferred on school districts by Section 407 of the School Code to adopt “reasonable rules and regulations for [their] government and control . . . .” 24 P.S. § 4-407. Appellants also protest that the School Districts’ mask mandates did not include provisions for religious exemptions. Appellants base their argument for such an exemption on their suggestion that masks constitute forced medical treatment that parents of students are entitled to refuse on their children’s behalf. See Prozan v. Millcreek Twp. Sch. Dist. Bd. of Dirs. (Erie, C.P., Nos. 10937-2022 & 90026-2022, filed Sept. 13, 2022) (Trial Ct. Op.) at 2. The School Boards filed motions to quash the Petitions, arguing that the Petitions did not state cognizable claims for relief. After consolidation, briefing, and argument, the Trial Court agreed and, on September 13, 2022, issued an opinion and order granting the School Boards’ motions and dismissing the Petitions. See generally Trial Ct. Op. The Trial Court cited the broad discretion conferred on school directors by Section 510 of the School Code to adopt such rules and regulations as they may “deem necessary and proper” in order to perform the functions and duties delegated to them in the School Code. Trial Ct. Op. at 6 (quoting 24 P.S. § 5-510). The Trial Court also observed that cause for removal of school directors under Section 318 is limited to instances of nonfeasance in failing or refusing to perform mandatory duties, not to instances of alleged malfeasance. Trial Ct. Op. at 4-5.

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T. Prozan v. Millcreek Twp. S.D. Bd. of Directors ~ E. Beckes v. N.E. S.D. Bd. of Directors ~ Appeal of: T. Prozan & E. Beckes, Counsel Stack Legal Research, https://law.counselstack.com/opinion/t-prozan-v-millcreek-twp-sd-bd-of-directors-e-beckes-v-ne-sd-pacommwct-2025.