David Archer v. York City School District
710 F. App'x 94
| 3rd Cir. | 2017Background
- New Hope Academy, a charter school in York, PA, sought a five-year charter renewal in 2011; the School District Board voted not to renew after hearings and document review.
- Board relied on PSSA scores and Annual Yearly Progress (AYP) to assess academic performance; New Hope had substantially lower PSSA proficiency rates than a comparable charter (Thackston) and district schools.
- Evidence showed conflicts of interest: New Hope contracted with companies owned by its operator, Isiah Anderson, without public bidding or disclosed financial-interest filings, implicating Pennsylvania’s Ethics Act and Nonprofit Corporation Law.
- The Pennsylvania State Charter School Appeal Board and the Pennsylvania Commonwealth Court upheld the District’s nonrenewal, finding failures in academic performance and violations of ethics/nonprofit law.
- Plaintiffs (students and parents) sued in federal court under the Fourteenth Amendment (class-of-one equal protection) and alleged a conspiracy; the District Court granted summary judgment for defendants, and the Third Circuit affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Equal Protection — class-of-one | New Hope treated differently than Thackston without rational basis | Thackston not similarly situated; New Hope’s poor test scores and governance justified different treatment | Affirmed: schools not similarly situated; test-score disparity provides rational basis |
| Conspiracy to violate civil rights | Board members and administrators conspired to deny New Hope’s rights | Conspiracy claim depends on underlying equal protection violation; none exists | Affirmed: conspiracy claim fails without underlying constitutional violation |
| Alleged inconsistencies/false testimony | Discrepancies in defendants’ evidence create material factual disputes | Discrepancies are immaterial to the rational-basis conclusion | Affirmed: inconsistencies not material to outcome |
| Spoliation (deleted email account) | Deletion of assistant superintendent’s email was intentional suppression of evidence | Deletion followed routine policy before litigation; no showing of relevance or intent to destroy evidence | Affirmed: no abuse of discretion in denying spoliation sanctions; duty to preserve not established |
Key Cases Cited
- Phillips v. Cty. of Allegheny, 515 F.3d 224 (3d Cir.) (standard for class-of-one equal protection)
- Vill. of Willowbrook v. Olech, 528 U.S. 562 (U.S.) (articulation of class-of-one Equal Protection theory)
- Bray v. Alexandria Women’s Health Clinic, 506 U.S. 263 (U.S.) (conspiracy claim fails absent protected-rights violation)
- Anderson v. Liberty Lobby, 477 U.S. 242 (U.S.) (summary judgment/materiality standard)
- Bull v. United Parcel Serv., Inc., 665 F.3d 68 (3d Cir.) (spoliation elements and appellate review)
- Charlton v. Paramus Bd. of Educ., 25 F.3d 194 (3d Cir.) (materiality of facts at summary judgment)
- New Hope Acad. Charter Sch. v. Sch. Dist. of City of York, 89 A.3d 731 (Pa. Commw. Ct.) (state law upholding denial of renewal based on academic performance and ethics violations)