School District of Philadelphia v. Department of Education
625 Pa. 418
| Pa. | 2014Background
- Palmer Leadership Learning Partners Charter School received a five-year charter (2000–2005) and sought renewal in 2004.
- In 2005, the SRC granted renewal upon signing a new Charter Agreement and limited enrollment to 675 students.
- The 2005 Charter incorporated the SRC Resolution by reference, binding the cap and requiring compliance with the Resolution.
- From 2007–2010, the Charter School enrolled about 729–782 students, while the District funded 675 slots.
- In 2010 the Charter School sought payment for students beyond the cap; the Department withheld funds per § 17-1725-A(a)(5).
- Secretary and Commonwealth Court held the cap valid only if re-agreed post‑2008 amendment; the Supreme Court reversed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a cap in a pre‑2008 charter can remain valid after § 1723-A(d). | School District: cap remains valid under written charter; no need for new agreement. | Palmer: post‑2008 amendment requires a new agreement to enforce cap. | Cap valid if agreed in written charter. |
| Whether the 2005 Charter’s enrollment cap was agreed to as part of a written charter. | District: cap included via incorporated SRC Resolution; binding written agreement. | Palmer: cap was unilaterally imposed term, not expressly agreed. | Yes; cap was agreed as part of the written charter. |
| Whether incorporation by reference of the SRC Resolution suffices to bind the cap. | District: SRC Resolution attached and incorporated; charter requires compliance. | Palmer: incorporation cannot create express agreement to a cap. | Incorporation by reference satisfied written‑charter agreement requirement. |
| What is the scope of § 17-1723-A(d) concerning caps in written charters? | Cap allowed if agreed in the written charter, regardless of enactment date. | Cap invalid post‑amendment unless re‑agreed. | Cap is permissible if agreed in the written charter, irrespective of date. |
| What standard of review applies to interpretation of the Charter School Law here? | Statutory interpretation is de novo; plain text controls. | Court should defer to agency findings where applicable. | Plain statutory text governs; de novo review affirmed. |
Key Cases Cited
- School District of Philadelphia v. Department of Education, 620 Pa. 443 (Pa. 2013) (central authority on 1723-A(d) construction and deference to text)
- Slippery Rock Area School District v. Pennsylvania Cyber Charter School, 612 Pa. 486 (Pa. 2011) (de novo review on statutory interpretation; scope of review)
- Knox v. Board of School Directors of Susquenita School District, 585 Pa. 171 (Pa. 2005) (interpretation of legislative intent and plain language governs)