Haas v. West Shore School District

DISSENTING OPINION BY

Judge SMITH-RIBNER.

I respectfully dissent from the majority’s determination that the West Shore School District Policy 235 does not apply to this case, involving the School District’s investigation and evaluation of circumstances surrounding accusations of alcohol consumption by 15-year old Justin Haas (Student) while in school. Policy 235 states:

No student shall be required, without prior written parental consent for students under eighteen (18) years of age or prior written consent of emancipated students or those over eighteen (18) years, to submit to a survey, analysis, or evaluation that reveals information concerning:
4. Illegal, anti-social, self-incriminating, and demeaning behavior.
However, such survey, analysis, or evaluation may be conducted on a wholly voluntary basis, provided that the student and/or his/her parent have been notified of their rights and of their right to inspect all related materials.

Reproduced Record (R.R.) at 106a.

The Student provided a written statement after being called into the office of the Principal, Mr. Novosel, and questioned *1261about his involvement in the illegal consumption of alcohol. The Student’s written statement, given October 13, 2005, was admitted into the evidence at the School Board’s hearing, and it reads:

At lunch [T.C.-full name omitted] had alcohol in an ice tea bottle. I didn’t believe him so he gave it to me so I took a sip. I know Nicole had drank some prior to lunch.

Board Exhibit 2, Supplemental R.R. at 115a.

Upon questioning by counsel for the Student, the Principal admitted that at some point in his investigation he may have said to the Student that he had to write a statement; the Principal also testified that the purpose of his questioning was to investigate or to evaluate further the circumstances to make his decision. The Principal contacted the Student’s parents once he ascertained that the Student consumed alcohol in school and acknowledged that he had no written consent from the parents to interview or evaluate the Student’s behavior. Once the Principal learned of accusations against the Student, the school began what was potentially a criminal investigation rather than a mere disciplinary investigation. R.R. at 44a-47a. The Principal recognized that his investigation and evaluation focused on whether the Student illegally consumed alcohol. Therefore, the School District was required under its policy to have the consent of the Student’s parents before questioning him and requiring his written statement. Its failure to do so warrants reversal of the decision made to discipline the Student.

Even if the Student’s statement was admissible and Policy 235 does not apply to this case, the evidence relied upon by the Board and the trial court is clearly insufficient to support any findings that the Student consumed alcohol on October 6, 2005. Counsel allowed admission of the Student’s written statement into the record so that he could argue to the Board that the Student clearly did not believe that the ice tea bottle contained alcohol. The only other evidence relied upon by the Board included the result of a positive breathalyzer test given the same day to T.C., the student who brought the bottle to school, and T.C.’s testimony that another student put alcohol in the bottle although he was not certain whether the Student knew this. The other student who purportedly put the alcohol in the bottle did not testify.

This Court must also review this case to determine whether substantial evidence exists in the record to support the Board’s findings. D.O.F. v. Lewisburg Area School District Board of School Directors, 868 A.2d 28 (Pa.Cmwlth.2004). Substantial evidence is more than a mere scintilla — rather it is such relevant evidence that a reasonable mind might accept as adequate to support a conclusion. Pennsylvania Labor Relations Board v. Kaufmann Department Stores, Inc., 345 Pa. 398, 29 A.2d 90 (1942). The Student’s written statement, the hearsay testimony of T.C. about what other students did or said in school, T.C.’s testimony that he was uncertain whether the Student had actual knowledge of the alcohol and T.C.’s breathalyzer test results form the basis for the Board’s finding that the Student knowingly consumed alcohol in school on October 6, 2005. That evidence does not rise to the level of substantial evidence required to support the Board’s finding. I therefore would reverse the trial court.