A.S. v. Office for Dispute Resolution (Quakertown Community School District)
88 A.3d 256
| Pa. Commw. Ct. | 2014Background
- Parents seek review of a Hearing Officer's finding that no valid settlement existed between Parents and Quaker-town Community School District regarding S.S.'s IDEA dispute.
- Negotiations occurred in September 2012; Agreement One was drafted by the District and sent for review in October 2012.
- Parents drafted Agreement Two at Parents' direction after revising Agreement One; Agreement Two was signed by Parents on October 8, 2012 and delivered to the District.
- District officials proceeded as if Agreement Two reflected the terms negotiated, and the School Board approved Agreement Two on October 25, 2012.
- Discrepancies between Agreement One and Agreement Two led the District to rescind Agreement Two; the Hearing Officer found no valid settlement, which the court later reversed in favor of Agreement Two.
- The appeal to this court raised timeliness issues regarding the May 2013 corrected decision, with the court addressing timeliness under 42 Pa.C.S. § 5571 and § 5572.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Jurisdiction of the Hearing Officer to decide settlement validity | Parents contended the Hearing Officer had authority to determine settlement validity. | District argued no statutory basis for such jurisdiction. | Hearing Officer has jurisdiction to determine settlement existence. |
| Validity of Agreement Two as a settlement | Agreement Two, signed by Parents, reflected terms they believed were negotiated. | Agreement Two did not constitute a valid offer/was not properly communicated. | Agreement Two is a valid settlement agreement. |
| Effect of unilateral district mistake on enforceability | The District's unilateral mistake should rescind Agreement Two. | No rescission due to lack of fraud; mutual assent issues control. | Mutual mistake not found; Agreement Two remains enforceable. |
| Timeliness of Parents' appeal | Appeal timely due to May 8, 2013 corrected decision notice. | Untimeliness should bar appeal. | Appeal timely; not dismissed for untimeliness. |
Key Cases Cited
- I.K. v. School District of Haverford Township, 961 F.Supp.2d 674 (E.D. Pa. 2013) (district court findings on hearing officer jurisdiction and settlement treatment)
- J.K. v. Council Rock School District, 833 F.Supp.2d 436 (E.D. Pa. 2011) (hearing officers may consider settlements but lack enforcement power)
- Holt v. Department of Public Welfare, 678 A.2d 421 (Pa.Cmwlth. 1996) (mutual mistake defense; lack of fraud standard)
- Cobaugh v. Klick-Lewis, Inc., 385 Pa.Super. 587, 561 A.2d 1249 (Pa. Super. 1989) (contracts; offer/acceptance and definite terms required)
- Reed v. Pittsburgh Board of Public Education, 862 A.2d 131 (Pa.Cmwlth. 2004) (contract formation—defining offer and acceptance)