Boyertown Area School District v. Department of Education

DISSENTING OPINION BY

Judge LEAVITT.

Respectfully, I dissent. I disagree that the Department of Education (Department) failed to comply with this Court’s remand order in Boyertown Area School District v. Department of Education, 797 A.2d 421 (Pa.Cmwlth.2002) (Boyertown I).

In Boyertown I, this Court established that withholding subsidy payments pursuant to Section 1725-A of the Charter School Law, Act of June 19,1997, P.L. 225, 24 P.S. § 17-1725-A,1 required the Department to give affected school districts an opportunity for an administrative hearing conducted in accordance with the Administrative Agency Law, 2 Pa.C.S. §§ 501-508, 701-704. Accordingly, we vacated the deductions that had been challenged by the petitioners in Boyertown 12 and ordered the Department to

provide an expedited opportunity for the school districts to be heard to challenge the deductions in a manner consistent with the foregoing opinion.

Boyertown I, 797 A.2d at 428. I believe the Department’s reconciliation guidelines are consistent with our order in Boyertown I.

First, Boyertown I established the principle that the Department was required to give each school district in Pennsylvania the opportunity to challenge deductions made from its subsidy payments by reason of the district’s failure to make a payment to a charter school. The principle of law articulated in Boyertown I applies with equal force to all school districts, not just the petitioners in Boyertown I. The Department’s reconciliation guidelines gave notice to all districts of their newly recognized right to voice objections to their subsidy reductions in a formal administrative hearing. They also established procedures designed to narrow the issues in dispute and, ideally, to dispose of those issues by agreement rather than by litigation. In the event issues remained outstanding, then the objecting districts would proceed to a formal hearing on their objections. By adopting these guidelines, the Department implemented the new law announced in Boyertown I in a responsive and responsible manner.

Second, formal administrative hearings before the Department are governed by the General Rules of Administrative Practice and Procedure, 1 Pa.Code §§ 31.1— 35-251. (General Rules). They authorize the agency head, ie., the Secretary of Education, to establish pre-hearing procedures that will identify, narrow and, finally, resolve the issues between the parties. 1 Pa.Code §§ 35.111-35.113.3 These pre-*423hearing procedures advance the orderly and expedited “disposition of the proceeding.” 1 Pa. § 85.111.

The Department’s reconciliation guidelines track these pre-hearing rules precisely. The guidelines require pre-hearing exchange of data and reports; preparation of objections; mediation with the Department’s counsel; responses by affected charter schools; and, finally, an evidentia-ry hearing on outstanding factual issues. Each of these items is specifically authorized by the General Rules of Administrative Practice and Procedure. 1 Pa.Code §§ 35.111-35.113. A fact-finding tribunal, whether it is an administrative agency or a court of law, is entitled to broad discretion in how it will conduct a hearing. The Department’s guidelines are an exercise of this discretion. Had the Secretary issued the reconciliation guidelines in a pre-hear-ing order issued to Petitioners alone, I do not believe this Court would have interfered.

Petitioners’ real objective in Boyertown II is not to resolve the question of whether the amount of their subsidy withheld was accurate, but, rather to obtain repayment of their subsidy reductions during the pen-dency of their litigation. Ironically, had Petitioners simply followed the guidelines, as did the majority of the petitioners in Boyertown I, their dispute with the Department would likely be now resolved.

*424For these reasons, I would affirm the Secretary’s adjudication.

. This Act amended the Public School Code of 1949, Act of March 10, 1949, P.L. 30, as amended, 24 P.S. §§ 1-101 — 27-2702.

. This group included the Petitioners in the case sub judice.

.They provide as follows:

§ 35.111. Conferences to adjust, settle or expedite proceedings.
In order to provide opportunity for the submission and consideration of facts, arguments, offers of settlement, or proposals of *423adjustment, for settlement of a proceeding, or any of the issues therein, or consideration of means by which the conduct of the hearing may be facilitated and the disposition of the proceeding expedited, conferences between the participants for such purposes may be held at any time prior to or during hearings before the agency head or the presiding officer as time, the nature of the proceeding, and the public interest may permit.
§ 35.112. Conferences to expedite hearings.
At a prehearing or other conferences which may be held to expedite the orderly conduct and disposition of a hearing, there may be considered, in addition to offers of settlement or proposals of adjustment, the possibility of the following:
(1) The simplification of the issues.
(2) The exchange and acceptance of service of exhibits proposed to be offered in evidence.
(3) The obtaining of admission as to, or stipulations of, facts not remaining in dispute, or the authenticity of documents which might properly shorten the hearing.
(4) The limitation of the number of witnesses.
(5) The discovery of production of data.
(6) Other matters as may properly be dealt with to aid in expediting the orderly conduct and disposition of the proceeding.
§ 35.113. Initiation of conferences.
a) The agency head or the presiding officer, with or without motion, and after consideration of the probability of beneficial results to be derived therefrom, may direct that a conference be held, and direct the parties to the proceeding, the staff of the agency and staff counsel to appear thereat to consider the matters enumerated in § 35.112 (relating to conferences to expedite hearings). Due notice of the time and place of the conference shall be given to all parties to the proceeding, the staff of the agency and staff counsel.
(b) Parties will be expected to come to the conference fully prepared for a useful discussion of problems involved in the proceeding, both procedural and substantive, and fully authorized to make commitments with respect thereto. The preparation should include, among other things, advance study of relevant material, and advance informal communication between the participants, including requests for additional data and information, to the extent it appears feasible and desirable. Failure of a participant to attend the conference, after being served with due notice of the time and place thereof, shall constitute a waiver of all objections to the agreements reached, if any, and any order or ruling with respect thereto.

(Emphasis added).