Ream v. Centennial School District
765 A.2d 1195 (Cmwlth, 2001)

Facts of the Case

Kristin Ream was a twelfth grader at William Tennent High School in the Centennial School Disctrict. On May 19, 1999 the Warminster police were conducting a sweep of the school grounds for drugs when they noticed a portion of a beer container inside of Ms. Ream's car. They then summoned her to the vehicle where she gave consent for the police to search the car. The police then found a ring-box inside of the car that contained 45 pills, which Ms. Ream then identified as "ecstasy". She was placed under arrest and taken to the police station. Ms. Ream was on probation for underage drinking and possession of marijuana at the time of her arrest, and the school then immediately suspended her.

On May 27, 1999, an informal hearing was held and the recommendation reached was that Ms. Ream continue her suspension until an expulsion hearing could be held. While on suspension Ms. Ream continued her education with a home-tutoring program. Ms. Ream completed her course work and took final exams. The expulsion hearing took place on June 15, 1999. Ms. Ream asserted that she had completed her course work and completed final exams. Ms. Ream also told the district that she had enrolled in and been accepted to Penn State University, but that her admission was contingent upon her receiving a diploma. Ms. Ream then received notification by a letter dated June 23, 1999, that her diploma had been denied. Following her expulsion Ms. Ream earned her GED and was admitted to Penn State University.

She then appealed the decision to Court of Common Pleas of Bucks County, which then determined that Ms. Ream had completed her work and the district was wrong in its decision and ordered that Ms. Ream receive her degree. The district then appealed the case to Commonwealth Court stating that Shuman v. Cumberland Valley School District Board of Directors, 63, 536 A.2d 490, 492 (1988), petition for allowance of appeal denied, 527 Pa. 658, 593 A.2d 428 (1991), was too narrow.

Decision of the Court

The court declined to overturn the ruling, stating that Shuman in no way contradicts Section 510 of the school code, 24 PS 5-510, giving the district the power to promulgate rules and regulations, and Section 1318 of the School Code, 24 PS 13-1318, giving the district the authority to suspend and/or expel students for disobedience.

The court stated that it was not Shuman that limited the district's authority to withhold the diploma, but rather the General Assembly, which stated that any student who completes "the prescribed course of instruction in high school" is entitled to a diploma.

Basis for Decision

The court stated that the General Assembly decreed in 24 P.S. Section 16-1613 that any student who finishes "the prescribed course of instruction in high school" is entitled to a diploma. Since Ms. Ream completed her course work before she was expelled the statute of the General Assembly would apply.

Abstract prepared by Andrew Kolak, July 17 2001