Slippery Rock Area School District v. Pennsylvania Cyber Charter School
31 A.3d 657
Pa.2011Background
- CSL requires districts to fund charter school students residing in the district; otherwise the secretary may deduct funds from state payments.
- Slippery Rock notified of deductions for Cyber School enrollments, including a four-year-old in kindergarten.
- Slippery Rock objected, arguing PSC age rules require kindergarten enrollment at age five and Cyber School’s age policy should not impose costs on the district.
- Secretary dismissed Slippery Rock’s objection, interpreting CSL and PSC combined with Chapter 11 to permit Cyber School to set its own kindergarten age.
- Commonwealth Court affirmed; it read ‘board of directors’ to include Cyber School’s board of trustees and upheld the deduction policy.
- Pennsylvania Supreme Court reversed, holding Cyber School may set its entry age, but district funding applies only to students eligible to attend the district’s public kindergarten (age five).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Authority to set kindergarten age | Slippery Rock: districts set age; CSL does not bind cyber school trustees. | Cyber School: CSL grants broad powers; trustees set age; Department supports this view. | Cyber School may set four-year-old admission age. |
| Funding obligation when district has no four-year-old kindergarten | District should not fund four-year-old Cyber School enrollment. | CSL requires funding regardless of district kindergarten availability. | District funds only five-year-olds; not obligated for four-year-old enrollments. |
| Double reading of 11.14 vs 5-503 | Plain reading of 11.14 should not be extended to include cyber schools’ trustees. | Secretary’s modified reading avoids absurd results and aligns with CSL intent. | No, 11.14 does not include cyber school trustees; strict reading controls. |
| Effect of incorporation by reference in CSL | General incorporation should not dilute district policy. | CSL’s incorporation supports cyber school authority to set age under its charter. | CSL grants cyber schools authority, but funding remains district-based per school age. |
| Interpretation of funding mechanics under CSL | Deduction mechanism is independent of district’s admissions policy. | Funding is tied to student eligibility and district policy. | When student is not eligible for district kindergarten, district need not fund. |
Key Cases Cited
- St. Elizabeth's C.C. v. Department of Public Welfare, 600 Pa. 131 (2009) (statutory construction framework guidance)
- Commonwealth v. Shiffler, 583 Pa. 478 (2005) (legislative intent and statutory interpretation principles)
- Street Road Bar & Grille, Inc. v. Pennsylvania Liquor Control Board, 583 Pa. 72 (2005) (absurd result and statutory construction considerations)
- O'Leary v. Wisecup, 26 Pa. Cmwlth. 538 (1976) (education entitlement concepts in public schooling)
- Slippery Rock Area School District v. Unemployment Compensation Board of Review, 603 Pa. 374 (2009) (binding guidance on administrative regulation interpretation)