Chester Community Charter School v. Commonwealth, Department of Education
2012 Pa. Commw. LEXIS 155
| Pa. Commw. Ct. | 2012Background
- Chester Community Charter School seeks to recover $7,490,171.75 in underpayments dating from 1998–2007 due to alleged improper funding deductions by Chester-Upland School District.
- Chester School alleges the District applied deductions from total special education expenditures and failed to apply the statutory funding formula for special education under Section 1725-A(a)(3).
- The Department of Education was named for failing to deduct funds as documented and to withhold subsidies under Section 1725-A(a)(5).
- Chester School sought mandamus, declaratory judgment, and injunction to compel withholding/remittance and to compel adherence to the Charter School Law’s funding requirements.
- The issue centered on whether the Department must withhold funds and whether Chester’s filing triggered the exclusive administrative remedy under the Charter School Law, with a hearing to follow if challenged.
- The court denied the application for summary relief and ordered a hearing to proceed, noting bias/conflict issues must be addressed first.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Secretary must withhold funds under 1725-A(a)(5) | Chester asserts mandatory withholding based on charter-school documentation. | The Department argues discretion or timing limitations limit withholding to funds for the current year. | Denial of summary relief; hearing required; withholding to be addressed in agency process. |
| Whether the administrative remedy is exclusive for funding disputes | Chester argues the statute provides complete administrative path and that Secretary failed to withhold. | Secretary contends procedures under 1725-A(a)(5)-(a)(6) govern disputes but not merits. | Administrative remedy exclusive; hearing to address merits; prior Chester I guidance emphasized the process. |
| Whether the Secretary must address past underfunding claims despite no current funds | Chester demands immediate withholding for long-past underfunding. | Withholding applies per current-year appropriations and procedures; past years are handled via hearing. | Not addressed on merits; hearing required; the process governs all disputes. |
Key Cases Cited
- Chester Community Charter School v. Department of Education, 44 A.3d 715 (Pa.Cmwlth.2012) (denies summary relief; holds hearing necessary; bias issues noted)
- Chester I, 996 A.2d 68 (Pa.Cmwlth.2010) (establishes mandatory, non-discretionary withholding and exclusive remedy)
- School District of Philadelphia v. Department of Education, 41 A.3d 222 (Pa.Cmwlth.2012) (en banc; Department’s withholding actions discussed in Palmer Charter context)
- GTECH Corp. v. Commonwealth, Dept. of Revenue, 965 A.2d 1276 (Pa.Cmwlth.2009) (original jurisdiction overview for summary relief)