American Indian Model Schools v. Oakland Unified School District
227 Cal. App. 4th 258
| Cal. Ct. App. | 2014Background
- American Indian Model Schools (AIMS) operates three Oakland charter schools with historically high API scores; an extraordinary audit (2012) found conflict-of-interest, fiscal mismanagement, and improper use of public funds.
- Oakland Unified School District issued a Notice of Violation, then a Notice of Intent to Revoke, and the Board adopted a resolution revoking all three charters effective June 30, 2013.
- AIMS pursued administrative appeals (county board and then State Board of Education) and filed a petition for writ of mandate and a motion for a preliminary injunction in superior court to maintain funding and operations during appeal.
- The superior court granted a preliminary injunction, finding (1) irreparable harm to students and the schools if funding and operations were halted and (2) a reasonable probability AIMS would prevail because the record lacked substantial evidence that the District complied with Education Code § 47607(c)(2) (considering increases in academic achievement for all pupil subgroups as the most important factor).
- District and other defendants appealed the injunction, arguing the court misinterpreted § 47607(c)(2), failed to defer properly to the District, lacked jurisdiction while administrative appeals were pending, and that the California Department of Education (CDE) was an indispensable party.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether § 47607(c)(2) requires the chartering authority to produce written findings supported by substantial evidence that it considered increases in pupil academic achievement for all groups as "the most important factor." | AIMS: § 47607(c)(2) requires weighing "increases" for all numerically significant subgroups and that revocation decisions be supported by substantial evidence showing compliance. | District: § 47607(c)(2) only requires the authority to "consider" academic achievement procedurally; no separate substantial-evidence/findings requirement beyond § 47607(c)(1)/(e). | Court: § 47607 must be read as a whole; because revocation decisions must be supported by written factual findings supported by substantial evidence (§ 47607(e)), compliance with (c)(2) likewise must be shown with substantial evidence. |
| Whether the administrative record showed the District considered increases over time for all numerically significant subgroups as the most important factor. | AIMS: the Record and Resolution contain only conclusory references to academic performance and API scores; no subgroup or growth analysis; therefore no substantial evidence of compliance. | District: API and renewal materials (historical data) demonstrate subgroup and growth information was available and considered. | Court: The record lacked specific evidence that the District considered "increases" for numerically significant subgroups as the most important factor; preliminary finding that AIMS had a reasonable probability of prevailing was proper. |
| Whether superior court abused discretion by granting injunctive relief continuing funding during appeals (interaction with § 47607(i), (j)). | AIMS: equity and irreparable harm justified maintaining status quo; court has discretion to enjoin enforcement pending final review, even where revocation rests on fiscal/legal misconduct. | District/Education Legal Alliance: statute requires continued funding only when revocation is based on (c)(1)(A) or (B); funding must cease for fiscal mismanagement or legal violations—court lacked power to order continued funding. | Court: § 47607(i) mandates funding when revocation is based on (A) or (B) but is silent as to (C)/(D); silence permits judicial discretion. Public policy and irreparable-harm balancing support injunctive power to preserve status quo while appeals proceed. |
| Whether the superior court improperly usurped administrative jurisdiction / failed to require exhaustion of administrative remedies. | AIMS: irreparable-harm exception to exhaustion applies (closure would dissipate students/staff and cause irreparable injury), so prompt judicial relief was proper. | District: AIMS had pending administrative remedies; court should have deferred to County Board/State Board and not interfere. | Court: Irreparable-harm exception applied; preliminary injunction preserved status quo and did not amount to final adjudication or divest the SBE of jurisdiction; SBE later chose not to act. |
| Whether the CDE was an indispensable party whose absence required dismissal or remand. | District: CDE is indispensable because of its role in funding and because the injunction affects administrative review. | AIMS: CDE was not necessary for the relief sought (stay of revocation/funding) and the order did not impair CDE rights. | Court: CDE was not indispensable; superior court did not abuse discretion by proceeding without joinder. |
Key Cases Cited
- Today’s Fresh Start, Inc. v. Los Angeles County Office of Education, 57 Cal.4th 197 (Cal. 2013) (scope of judicial review and administrative mandamus under Education Code revocation procedures)
- Wilson v. State Board of Education, 75 Cal.App.4th 1125 (Cal. Ct. App. 1999) (charter schools are creatures of statute and local boards act under plenary legislative authority)
- Topanga Assn. for a Scenic Community v. County of Los Angeles, 11 Cal.3d 506 (Cal. 1974) (requirement that administrative decisions include findings to bridge analytic gaps and permit meaningful review)
- Runyon v. Board of Trustees of California State University, 48 Cal.4th 760 (Cal. 2010) (degree of deference for agency statutory interpretation in mandamus review)
- Coachella Valley Mosquito & Vector Control Dist. v. California Public Employment Relations Bd., 35 Cal.4th 1072 (Cal. 2005) (exhaustion doctrine and its exceptions)
- Sequoia Union High School Dist. v. Aurora Charter High School, 112 Cal.App.4th 185 (Cal. Ct. App. 2003) (administrative revocation review; courts may not reweigh evidence but can set aside agency actions lacking evidentiary support)