In Re: Petition to Reapportion the Wyomissing Area SD ~ Appeal of: v. Rodriguez, Jr.
835 C.D. 2017
| Pa. Commw. Ct. | Jan 5, 2018Background
- Wyomissing Area School District (Berks County) elects its board at-large; Resident Electors (including Rodriguez) petitioned to reapportion to three regional districts.
- Resident Electors filed an amended plan proposing three regions electing three directors each; the plan split one of the District’s six voting precincts (i.e., would divide an election district).
- The trial court denied the original petition for lack of requisite signatures, later overruled preliminary objections, and then considered cross-motions for summary judgment on the amended petition.
- The trial court granted the District’s cross-motion and denied the Resident Electors’ motion; Rodriguez appealed arguing, inter alia, that the court could create new election districts under the Election Code (§502) to accommodate the plan.
- The Commonwealth Court affirmed, holding that School Code §303(b)’s requirement that regional boundaries be compatible with election district boundaries is mandatory and that §303(b) is not in pari materia with Election Code §502.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether trial court erred by denying reapportionment because the plan splits an election district | Rodriguez: court can rely on Election Code §502 power to form/create election districts so splitting a precinct should not bar approval | District: School Code §303(b) requires region boundaries be compatible with election district boundaries; noncompliance is fatal | Held: Affirmed trial court; incompatibility with election districts is dispositive and bars approval |
| Whether School Code §303(b) and Election Code §502 must be read in pari materia to permit court-created districts for school reapportionment | Rodriguez: statutes are in pari materia so court may form new election districts to validate the plan | District: statutes address different persons/things (plans by boards/electors v. court authority) and are not in pari materia | Held: Not in pari materia; court refused to read §303(b) and §502 together to override the absolute election-district boundary requirement |
| Whether the election-district-boundary requirement in §303(b) is mandatory or flexible | Resident Electors: population equality is primary; splitting a precinct could be tolerated to achieve near-equal populations | District: boundary compatibility is an absolute statutory requirement (contiguity and election-district lines are absolutes) | Held: Boundary compatibility is mandatory (absolute); population equality is flexible but cannot override boundary rule |
| Standard of review for the summary-judgment rulings | Rodriguez: (argued error of law) | District: summary judgment proper where no material fact disputes and law favors District | Held: Review de novo; summary judgment appropriate where no genuine issue of material fact — court concluded law required denying petition |
Key Cases Cited
- Pane v. Indian Rocks Prop. Owners Ass’n, Inc. of Ledgedale, 167 A.3d 266 (Pa. Cmwlth. 2017) (discussing statutory construction and related authorities)
- In re Petition to Reapportion the Sch. Dir. Regions of the Chichester Sch. Dist., 688 A.2d 1275 (Pa. Cmwlth. 1997) (both election-district compatibility and population equality must be satisfied)
- Petition of the Bd. of Dirs. of Hazleton Area Sch. Dist., 524 A.2d 1083 (Pa. Cmwlth. 1987) (contiguity and election-district boundary lines treated as absolute requirements)
- Spring-Ford Area Sch. Dist. v. (citation reflected in opinion), 234 A.2d 184 (Pa. Super. 1967) (population equality requirement discussed)
- Cameron County Sch. Bd., Resident Electors Appeal, 456 A.2d 226 (Pa. Cmwlth. 1983) (cases affirming multiple §303(b) requirements)
- Cherry v. Pa. Higher Educ. Assistance Agency, 642 A.2d 463 (Pa. 1994) (statutes in pari materia must relate to same persons or things to be construed together)
- Starling v. Lake Meade Prop. Owners Ass’n, Inc., 162 A.3d 327 (Pa. 2017) (standard for appellate review of summary judgment)
- Gilbert v. Synagro Cent., LLC, 131 A.3d 1 (Pa. 2015) (summary-judgment standard explained)