Woodland Hills School District v. S.F. and His Parents

747 A.2d 433 (PA Cmwlth, 2000)

Facts of the Case

S.F. was a 20 year old student in the Woodland Hills School District who was diagnosed with Downs Syndrome and Mental Retardation and spent 67% of the school day in a learning support environment in accordance with an Individualized Educational Plan (IEP) that was developed by his IEP team and parents. Although S.F. had sufficient academic credits to graduate, he had not yet completed his special education program as set forth in his IEP.

In February of 1999, the parents requested to have S.F. participate in the graduation ceremonies held at the conclusion of the 1998-99 school year, even though he was not eligible to receive a diploma. The district denied the request and S.F.'s parents requested a special due process hearing in which they stated he was entitled to participate in the graduation ceremony and have his diploma "banked" until he earned it. On May 31, 1999, the Special Education Hearing Officer disagreed with the parents and upheld the district's policy that S.F. must meet all local and state requirements for graduation, including completion of his IEP, before he could participate in the commencement ceremony on June 7, 1999.

S.F.'s parents filed exceptions to the decisions and on June 28, 1999, the Special Education Appeals Panel issued an order that reversed the decision of the Special Education Hearing Officer and ordered that S.F. be permitted to participate in the commencement ceremonies at the conclusion of the 1999-2000 year.

Woodland Hills School District appealed the June 28, 1999 decision of the Special Education Appeals Panel in which the panel decided that a disabled student had the right to participate in a high school commencement ceremony, even though he had not completed the special education program and had not earned a diploma.

On July 26, 1999, the district, on appeal to the Commonwealth Court, argued that it was a valid exercise of its vested discretion to develop and apply its own commencement ceremony criteria for its students, and to adopt the policy of only allowing those students who have satisfied the requirements to receive a diploma to participate in the commencement ceremonies.

Decision of the Court

On March 1, 2000, the Commonwealth Court, No. 1947 C.D. 1999, affirmed that the school district's policy, conditioning the participation in the graduation ceremony upon the student's successful completion of the instructional program appropriate to his needs and on the student having earned a diploma, did not violate the Individuals with Disabilities Education Act, and reversed the decision of the Special Education Appeals Panel.

Basis of the Decision

The Commonwealth Court based its decision on the Public School Code which states "school boards are responsible for their administering the individual school systems and may adopt reasonable rules and regulations as are necessary and proper for the management of school affairs" (435). Commonwealth Court was without power to interfere with an action of a school board committed by law to its discretion unless it was apparent that the school board's conduct was arbitrary, capricious, and to the prejudice of public interest, in which it was not.

Furthermore, the court stated that the General Assembly vested the local school district with the authority to set up its own requirements for graduation from its schools and to confer academic degrees on those who successfully complete such requirement according to Sections 16-1605, 16-1611, and 16-1613 of the School Code The court concluded that there was no dispute on the issue of the completion of the IEP and not being eligible to receive a diploma. All requirements for both IDEA, 20 U.S.C. Section 1400-1484, and the IEP according to Section 14.32 of 22 PA Code were met.

Prepared by Dixie Barth and Lance Anderson, June 22, 2000.