Purcell v. Reading School District
167 A.3d 216
Pa. Commw. Ct.2017Background
- Purcell was hired as Reading School District superintendent on a five-year contract beginning July 1, 2012; performance concerns arose in 2013 leading to a series of letters, reprimands, suspensions, and formal charges.
- The Board issued Loudermill notices and ultimately terminated Purcell after hearings; the trial court affirmed the termination.
- The Board’s charges (consolidated into multiple numbered counts) alleged violations of the School Code and her contract, focusing largely on budget mishandling (Charges 7 and 8) and several administrative deficiencies (Charges 1(a), 1(b), 2–6, 10–12).
- Purcell argued she was denied due process because Board members acted as accusers, witnesses, and adjudicators; she also argued the charges did not meet statutory grounds for removal under 24 P.S. § 10-1080.
- The Commonwealth Court found the Board impermissibly commingled prosecutorial and adjudicative functions (Lyness line of authority) and concluded many charges lacked competent evidentiary support; it reversed or vacated the board’s termination as to most charges and remanded only Charges 7 and 8 for a constitutionally adequate hearing limited to budget-related issues.
Issues
| Issue | Plaintiff's Argument (Purcell) | Defendant's Argument (District) | Held |
|---|---|---|---|
| Whether Purcell was denied due process by commingling investigative/prosecutorial and adjudicative functions | Board members acted as complainants, witnesses, prosecutors and adjudicators; appearance of bias unconstitutional under Lyness | Process was "sufficient" (notice and appeal), school boards necessarily perform multiple functions; Lyness inapplicable | Court held due process violated: Board commingled functions without required "walls of division," reversing many terminations |
| Whether charges met statutory standard for removal under 24 P.S. §10-1080 (neglect, incompetence, immorality) | Charges were minor or unsupported and thus did not constitute statutory grounds for removal | Charges (esp. budget-related ones) showed incompetence/neglect and potential immorality for false reimbursements | Court found most charges lacked competent evidence to justify termination; only budget charges warranted further factfinding |
| Whether factual findings were supported by substantial competent evidence and not in capricious disregard of material evidence | Board findings were unsupported, relied on hearsay and conflicted testimony | Board relied on member testimony and documentary record; budget process failures were serious | Court found insufficient evidence on charges 1(a),1(b),2,3,4,5,6,10,11,12; vacated findings on 7 and 8 and remanded those for a proper hearing |
| Scope/remedy: What remedial proceedings are required | Purcell sought reversal of termination and vindication of rights | District sought affirmation or remand for general proceedings | Court reversed/vacated in part and remanded to trial court with direction to send Charges 7 and 8 back to Board for a due-process-compliant hearing limited to budget issues |
Key Cases Cited
- Lyness v. State Department of Medicine, 605 A.2d 1204 (Pa. 1992) (requires "walls of division" where a single body performs prosecutorial and adjudicative functions to avoid appearance of bias)
- Burger v. School Board of McGuffey School District, 923 A.2d 1155 (Pa. 2007) (upholds statutory removal procedure for superintendents and recognizes legislative authority to set removal rules)
- Office of Disciplinary Counsel v. Duffield, 644 A.2d 1186 (Pa. 1994) (approves procedures that avoid commingling by using separate charging and hearing bodies)
- Antonini v. Western Beaver School District, 874 A.2d 679 (Pa. Cmwlth. 2005) (charges must be "serious" to permit suspension/termination without compliance with statutory protections)
- Horosko v. School District of Mt. Pleasant Township, 6 A.2d 866 (Pa. 1939) (school employment discipline can be upheld where conduct at issue undermines trust and public confidence)