Anderson Union High Sch. Dist. v. Shasta Secondary Home Sch.
C078491M
| Cal. Ct. App. | Nov 18, 2016Background
- Shasta Secondary Home School (SSHS) is a nonclassroom-based charter authorized by Shasta Union High School District (SUHSD); it operates resource centers in Redding and opened a third (Cottonwood) in 2013 located inside Shasta County but outside SUHSD — within Anderson Union High School District (AUHSD).
- The Cottonwood center offers computer workstations, tutoring, materials checkout, and facilitator meetings; it is not used principally for classroom instruction and offers no optional classes.
- AUHSD sued seeking injunctive and declaratory relief, alleging the Cottonwood center violated the Charter Schools Act geographic/site limits and SSHS’s charter because it lies outside the authorizing district.
- The trial court ruled for SSHS, finding sections limiting satellite sites apply only to classroom-based charter schools and do not restrict resource centers located elsewhere in the same county.
- The Court of Appeal reversed, holding the statutory geographic restrictions apply to all charter schools and that the Cottonwood center does not fall within the statutory exceptions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether sections 47605 and 47605.1 geographic/site limits apply to nonclassroom-based charters | Geographic limits apply to all charter schools; Cottonwood is outside authorizing district so unlawful | Limits apply only to classroom-based charters; nonclassroom resource centers are not constrained | Applies to all charters; limits govern SSHS and Cottonwood unless an exception applies |
| Whether § 47605.1(c) or (d) permits a resource center located outside the authorizing district but within the same county | § 47605.1 exceptions do not cover this Cottonwood location | Subdivision (c) or the structure of the Act allows in-county resource centers for nonclassroom programs | Neither (c) nor (d) covers Cottonwood; (c) is an adjacent-county exception and (d) is a narrow in-county exception with specific conditions |
| Whether a resource center is a “schoolsite” (§ 47612.5(e)(3)) so site limitations don't apply | Cottonwood is not a schoolsite (not principally for classroom instruction), so site/site-identification rules don’t apply | Even if not a “schoolsite,” a resource center is part of the charter’s operations and subject to geographic limits | “Site” (location) and “schoolsite” (use) differ; resource centers have sites and are subject to geographic limits despite not being a classroom-based schoolsite |
| Weight of agency interpretation and policy arguments | Department of Education guidance and policy considerations (access, oversight, competition) support SSHS | Plain statutory language and legislative purpose support AUHSD | Agency memoranda not binding; statutory text governs. Policy cannot override clear statutory language |
Key Cases Cited
- Today's Fresh Start, Inc. v. Los Angeles County Office of Education, 57 Cal.4th 197 (discusses charter-school nature and public funding)
- Wells v. One2One Learning Foundation, 39 Cal.4th 1164 (background on public education structure and independent study)
- Wilson v. State Bd. of Education, 75 Cal.App.4th 1125 (context on charter-law revisions and petition procedure)
- California School Bd. Ass'n v. State Bd. of Education, 186 Cal.App.4th 1298 (discusses 2002 geographic restrictions and legislative intent)
- People v. Superior Court (Romero), 13 Cal.4th 497 (rule against reading out necessary statutory provisions)
- Yamaha Corp. of America v. State Bd. of Equalization, 19 Cal.4th 1 (agency interpretations are persuasive but not binding)
- Dyna-Med, Inc. v. Fair Employment & Housing Com., 43 Cal.3d 1379 (final statutory meaning rests with the courts)