Education Law Report
A Publication of Ancel, Glink,
Diamond, Bush, DiCianni & Krafthefer, P.C.
Number 1 -- November 1998
To view this edition in PDF format, click here.
Sexual Harassment in Schools:
Teacher/Student; Student/Student
Suspicionless Drug Testing—Testing
and Retesting Its Limits
Regulatory Developments:
An Update on the E-Rate
Case Law Update:
Reproduction Becomes "Major
Life Activity" Under ADA
Expulsion Hearings: A Student's Right
to Confront His Accusers
Attorney Profile: William C. Kling
Supreme Court
Reviews Sexual Harassment in Schools
Teacher/Student Harassment . . .
Sexual harassment in the nation’s schools has become a matter
of increasing urgency to educators. Gebser v. Lago Vista Independent
School District, 118 S.Ct. 1989 (1998), is significant for school districts
because it defines the standard for recovery of money damages under Title
IX in cases involving teacher-student sexual harassment.
Alida Star Gebser, a high school student
in Lago Vista Independent School District, had a sexual relationship with
one of her teachers. She did not report the relationship to district officials
even though she realized the teacher’s conduct was improper. According
to Gebser, she was uncertain how to react and she wanted to continue having
him as a teacher. Except for prior complaints from the parents of two other
students that the teacher made inappropriate remarks in the classroom, the
district was unaware of any other instances of misconduct.
After the district learned of the relationship, the teacher’s employment
was terminated and his teaching license was subsequently revoked. During
this time, the district did not have a formal grievance procedure for reporting
sexual harassment complaints, nor did it have an anti-harassment policy.
Gebser and her mother sued the school district, alleging sexual harassment
under Title IX.
Title IX of the Education Amendments of 1972 provides in pertinent part
that:
No person . . . shall, on the basis of sex, be excluded from participation
in, be denied the benefits of, or be subjected to discrimination under
any education program or activity receiving federal financial assistance.
20 U.S.C. §1681(a).
One of the principal objectives of Title IX is to ensure that federal
moneys are not used to support discriminatory practices in educational programs.
In Cannon v. University of Chicago, 441 U.S. 677 (1979), the Supreme
Court first recognized an implied private right of action under Title IX.
Later, Franklin v. Gwinnett County Public Schools, 503 U.S. 60 (1992),
established that under Title IX a school district can be liable for money
damages in cases involving gender-based discrimination. Franklin did not
go so far as to define the contours of that liability. Gebser goes
a long way toward resolving that issue.
In a 5 to 4 decision, the Court held that a school district is not liable
for money damages under Title IX unless a district official actually knows
of the teacher’s misconduct and does nothing about it. The Court concluded
that it would “frustrate the purposes” of Title IX to permit a
plaintiff to recover damages against a school district for a teacher’s
sexual harassment of a student unless a school official with authority to
institute corrective measures on the district’s behalf or the district
has actual notice of, and is deliberately indifferent to, the teacher’s
misconduct.
“The number of reported cases involving sexual harassment of students
confirms that harassment unfortunately is an all too common aspect of the
educational experience,” Justice Sandra Day O’Connor wrote for
the Court. But she added that the “independent misconduct” of
a teacher cannot be blamed on the school district that hired him absent
actual notice to district officials.
In ruling against Gebser, the court emphasized that Title IX is unlike
the 1964 Civil Rights Act, which flatly bans sex discrimination and harassment
in the workplace. Under Title IX, schools risk losing federal funding only
when district officials are told of some violation and fail to take corrective
measures. The court observed that Congress did not intend to make school
districts responsible in private lawsuits for sex discrimination without
a finding of actual knowledge and “deliberate indifference to discrimination.”
In Gebser, the high school principal was the only district official
alleged to have information about the teacher’s misconduct. However,
the only alleged “knowledge of misconduct” was limited to complaints
from the parents of other students that the teacher had made inappropriate
comments during class. That information alone was insufficient to alert
the principal of the existence of the sexual relationship involving Gebser.
The court also rejected the argument that the school district’s
failure to adopt an anti-harassment policy, contrary to regulations requiring
one, should subject it to monetary liability. The ruling does not affect
whether a teacher can be criminally prosecuted, or whether a student can
attempt to recover money damages under either state law or civil rights
statutes.
It is clear from Gebser that school districts are not liable for
money damages under Title IX unless a student can show that district officials
knew about the sexual harassment and did nothing to correct it. District
officials would include superintendents, Title IX officers, or other district
officials with authority to stop the harassment.
. . . and Student/Student Harassment
In August 1997, the Eleventh Circuit Court of Appeals decided Davis
v. Monroe County Bd. of Educ., ruling that a Georgia school district
was not liable for student/student sexual harassment under Title IX of the
Education Amendments of 1972. The Supreme Court has agreed to review Davis,
and its decision is likely to resolve many questions concerning student/student
harassment claims.
In Davis, a fifth grade student (LaShonda) was repeatedly subjected to
abhorrent behavior by another student, G.F., including repeated inappropriate
touching, reviling statements and other offensive conduct. LaShonda allegedly
reported the incidents to her teacher, who also allegedly reported the incidents
to the principal. In all, the complaint described eight separate incidents
of sexual misconduct during a six month period.
The court drew several important conclusions in holding that Title IX
does not allow a claim against a school board based on school officials’
failure to remedy a hostile sexual environment under a claim of sexual harassment
of one student to another. First, while the court acknowledged “G.F.’s
speech or conduct created an atmosphere that was sufficiently hostile or
abusive to alter the conditions of LaShonda’s learning environment,”
the court held that the standards of liability applicable to employment
contexts under Title VII of the Civil Rights Act of 1964 do not control
student/student sexual harassment claims.
The crux of the court’s analysis looked to the underlying statutory
framework giving rise to Title IX as distinguished from Title VII. Title
VII creates general prohibitions against discrimination in the employment
context. Title IX applies to educational institutions receiving federal
funding. Through Title IX, Congress “in effect offers to form a contract
with potential recipients of federal funding [and] a prospective recipient
is free to decline a grant of federal funding” if it is not satisfied
with the obligations thereunder.
The court held the school board was not sufficiently “on notice”
of any contractual obligation that would cause it to be held liable for
student/student harassment under Title IX. The court noted the Office for
Civil Rights (“OCR”) issued a document entitled “Sexual Harassment
Guidance: Peer Sexual Harassment,” in 1996, and final policy guidance
on student sexual harassment on March 13, 1997. Since there was no such
guidance at the time of the alleged harassment of LaShonda, the court held
the Monroe County School Board was not “on official notice” of
potential liability for student/student harassment by virtue of its acceptance
of federal funds. (Note: This part of the decision leaves open the question
of whether the court would find liability for alleged harassment occurring
after March 13, 1997.)
The court concluded by stating:
We condemn the harm that has befallen LaShonda, a harm for which Georgia
tort law may indeed provide redress. The present complaint, however, fails
to state a claim under Title IX because Congress gave no clear notice to
schools and teachers that they, rather than society as a whole, would accept
responsibility for remedying student/student sexual harassment when they
chose to accept federal financial assistance under Title IX.
The dissent took exception to the majority’s rationale that, because
the legislative history did not discuss student/student harassment, Congress
did not intend to create such a cause of action. The dissenters countered
that, if the majority’s analysis was correct, the teacher/student harassment
found actionable in Franklin v. Gwinnett County Public Schools would not
be actionable, either because there is no discussion of teacher/student
sexual harassment in the legislative history. In arguing that Title IX should
provide a cause of action for student/student harassment, the dissent turned
to the principles of the law of “agency” relationship used in
Title VII cases to analyze potential liability. In applying the Title VII
“elements” to this case, the dissent concluded “there is
no question that the allegations satisfy” those requirements.
The Gebser decision (see page 1 article) may have already determined
the outcome of the Davis appeal. The Davis case will be decided by
the Supreme Court this term. We note that in March, 1998, the Seventh Circuit
Court of Appeals adopted standards similar to those set forth in Gebser
in the case of Doe v. University of Illinois, which held that a school district
may be liable for peer harassment if it has actual knowledge that such harassment
was taking place. In the decision, the court rejected the reasoning in Davis
as inconsistent with the ruling in Gwinnett.
At the very least, we would recommend that school districts familiarize
themselves with the OCR peer harassment guidance. Further, school districts
should not rely too strenuously on the non-liability result in Davis; allegations
of peer sexual harassment should be taken seriously, fully investigated,
and effectively dealt with in accordance with board policies.
Nine Steps to Prevent Sexual Harassment
Adoption of strong preventive measures is
often the best way to confront the serious problem of sexual harassment
and to protect school districts from liability for this high profile claim.
The U.S. Department of Education, Office of Civil Rights, suggests a school
may take the following steps to prevent harassment:
1.Develop
and publish a sexual harassment policy that clearly states sexual harassment
will not be tolerated and that explains what types of conduct will be considered
sexual harassment.
2.Develop
and publish a specific grievance procedure for resolving complaints of
sexual harassment.
3.Develop
methods to inform new administrators, teachers, guidance counselors, staff,
and students of the school’s sexual harassment policy and grievance
procedure.
4.Conduct
periodic sexual harassment awareness training for all school staff, including
administrators, teachers, and guidance counselors.
5. Conduct
periodic age-appropriate sexual harassment awareness training for students.
6. Establish
discussion groups for both male and female students where students can
talk about what sexual harassment is and how to respond to it in the school
setting.
7. Survey
students to find out whether any sexual harassment is occurring at the
school.
8.Conduct
periodic sexual harassment awareness training for parents of elementary
and secondary students.
9.Work
together with parents and students to develop and implement appropriate,
effective measures for addressing sexual harassment.
Return to Table of Contents
Suspicionless
Drug Testing—
Testing and Retesting Its Limits
It is safe to assume that the personnel in most Deans’ offices
are not working overtime on investigations of students in extracurricular
activities for drug abuse. Yet, as a result of two recent decisions of the
United States Court of Appeals for the Seventh Circuit, members of the glee
and chess clubs could be subject to suspicionless drug testing while a student
returning to school after a suspension might not. Understanding the legal
and rational basis for this seemingly counterintuitive result is, however,
crucial to any District considering any form of suspicionless drug testing.
The road to the Seventh Circuit’s
recent pronouncements begins with the Supreme Court’s opinion in Vernonia
School District v. Acton, 515 U.S. 646 (1995). In Vernonia, the
Court found that a school policy requiring random urinalysis testing for
participants in interscholastic athletics did not violate a student’s
Fourth Amendment right to be free from unreasonable searches. The Supreme
Court supported its decision with a variety of rationale, including:
1. the government’s responsibilities as a guardian and tutor of
children entrusted to its care;
2. the severe physical, psychological, and addictive effect of drugs
on children and the disruption of the educational process caused by drug
infested schools;
3. the risk of immediate physical harm to drug users participating in
physical activities;
4. the fact that students voluntarily engaging in extracurricular athletic
activities have reason to expect intrusions upon their privacy. For example,
student athletes must shower and change in communal school locker rooms.
Participation in extracurricular activities also often involves minimum
grade point standards, rules of conduct, training and other rules which
subject students to a degree of regulation higher than that imposed on
nonparticipants;
5. the documented state of rebellion in a large segment of the Vernonia
School District’s student body, characterized by epidemic disciplinary
actions which particularly involved interscholastic athletics; and
6. the fact that the drug testing results were only disclosed to necessary
school personnel and not used for any law enforcement or internal disciplinary
function.
Following Vernonia, it was difficult to assess the limits on
suspicionless drug testing. The Court’s opinion could be read narrowly
or broadly, depending on which of the above factors are viewed as being
outcome-determinative. Two new appellate decisions in our own Circuit have
helped to clarify what suspicionless testing of students is permissible
and what is not.
Testing of Extracurricular Participants
The Seventh Circuit first had the opportunity to directly address the
scope of the Vernonia opinion in Todd v. Rush County Schools,
133 F.3d 984 (1998). In Todd, the random drug testing program went beyond
interscholastic athletics to encompass all extracurricular activities. As
in Vernonia, a positive test result only barred the student from
participating in extracurricular activities and was not used in school disciplinary
proceedings. The student in Todd was barred from videotaping the
football team because his parents refused to sign a consent form authorizing
drug testing. Other students barred from extracurricular activities also
included members of the Library Club and the Future Farmer’s of America.
However, unlike Vernonia, the Rush County School District was unable to
document a “state of rebellion” involving epidemic drug use. A
survey of the school’s students disclosed that cigarette use was higher
than the state average, but that marijuana usage was lower than the state
average.
In Todd, the Seventh Circuit upheld a drug testing program applicable
to students who wished to engage in any extracurricular activity, even though
all the factors relied on by the Supreme Court in Vernonia were not present.
In support of its decision, the Court focused on the responsibilities a
public school system has as a guardian of the children entrusted to its
care, and noted that successful extracurricular activities required healthy
students. The Court also focused on the fact that a student’s decision
to engage in extracurricular activities was a voluntary one. Since participation
in interscholastic athletics is a benefit carrying with it enhanced prestige
and status in the student community, the court reasoned that it was not
unreasonable to couple these benefits with an obligation to undergo suspicionless
drug testing.
Post-Suspension Testing
Following Todd, the Seventh Circuit again considered suspicionless
drug testing of students in Willis v. Anderson Community School Corporation,
1998 WL 569114 (1998). In Willis, the Court invalidated a school
district policy which required drug and alcohol testing of students returning
to school after a suspension of three or more days. The court again noted
the District’s custodial responsibility for children, but recognized
that the consideration of only this factor could lead to broad based testing
well beyond that ever envisioned by the Supreme Court in Vernonia.
The court also expressed its fear of allowing testing to be authorized for
so many different categories of students that essentially all but the most
withdrawn and uninvolved students would be subject to testing.
In order to avoid sanctioning wide-ranging suspicionless drug testing,
the Willis court found it had a duty to examine closely both the
nature of the District’s concern and the efficacy of the policy to
ensure that the District’s action fit within the closely guarded category
of constitutionally-permissible searches. In so doing, the court recognized
that the Todd opinion’s extension of suspicionless drug searches
from athletics to all extracurricular activities did not find the “locker
room atmosphere” used in Veronia to support suspicionless drug
testing as being a significant distinction between athletics and other extracurricular
activities. The court also found that the documented “state of rebellion”
which was used to support suspicionless drug testing in Vernonia
would not always be required. Instead, the Willis court determined
that the District’s perceived need to address an increasing drug and
alcohol problem was a sufficient interest.
In Willis, however, the court found it very important that the
policies at issue in Vernonia and Todd only applied to students
who voluntarily chose to participate in an activity. The Willis court
recognized that the drug testing allowed in the Vernonia and Todd
cases could be construed as part of the bargain a student strikes in exchange
for the privilege of participating in extracurricular activities. In contrast,
the policy at issue in Willis applied to all students returning to
school after a suspension. Unlike the policies at issue in Vernonia
and Todd (which excluded students only from extracurricular activities),
the drug testing rejected in Willis could exclude students from attending
school. Under the Willis policy, students who refused to submit to
drug testing after returning from suspension were considered to have admitted
unlawful substance abuse, suspended again, and further advised that a second
refusal to submit to testing would result in a third suspension and expulsion
proceedings.
In Willis, the Court also found it important to analyze suspicionless
drug testing policies in light of the feasibility of a suspicion-based search.
The court noted that in Vernonia and Todd it would have been difficult for
school authorities to meet individually with all students participating
in extracurricular activities and that a suspicion-based policy could pin
a “badge of shame” on the individual students suspected. In contrast,
the policy in Willis was subject to a state law which required that
suspended students be given a meeting with a school official. Because a
meeting was already required, the court reasoned that this meeting would
allow a disciplinary authority to evaluate a student’s conduct for
drug use without difficulty. Although the Willis court admitted that
the nature and immediacy of the District’s concern was analogous to
that in Vernonia and Todd, it found that the efficacy of the
policy and the privacy interest of the individual were different and accordingly
found that the policy at issue in Willis violated the Fourth Amendment.
Conclusion
Although comparison of the Todd and Willis opinions leads
to a result which would allow suspicionless drug testing of Glee Club members,
while protecting students returning from suspensions, these cases are not
without a rational basis. The brevity and cursory nature of the opinion
in Todd speaks to the court’s willingness to permit suspicionless
drug testing where a student could only be banned from extracurricular activities.
On the other hand, the Willis opinion shows that the Seventh Circuit
will closely analyze any drug testing policy that may deprive a student
of the opportunity to attend school.
In light of the number and variety of different rationale set forth in
the Supreme Court’s decision in Vernonia, it is likely that
the Court will be forced to revisit this issue in order to better identify
those specific factors which differentiate between constitutional and unconstitutional
suspicionless drug testing policies in public schools. In the interim, school
policies should be carefully reviewed for compliance with the suspicionless
drug testing policy validated in the Todd opinion. Districts should
keep abreast of the latest Supreme Court and Seventh Circuit precedents
involving these issues and be prepared to amend their policies to conform
with further developments in the law.
Return to Table of Contents
Regulatory Developments:
An Update on
the E-Rate
The Telecommunications
Act of 1996 significantly reformed and deregulated the television, telephone
and cable industries by lifting regulatory barriers which had prevented
these industries from offering services or competing in other segments of
the telecommunications marketplace. One exception to the “free market”
concept is in the area of education. Section 254(h)(1)(B) provides:
All telecommunications carriers serving a geographic area shall, upon
a bona fide request for any of its services...provide such services
to elementary schools, secondary schools, and libraries for educational
purposes at rates less than the amounts charged for similar services to
other parties. The discount shall be an amount...to ensure affordable access
to and use of such services by such entities.
The National Center for Education Statistics recently reported that wealthy
schools are twice as likely to have Internet access in classrooms than poor
schools. Currently, only around 30% of classrooms are linked to the Internet,
while 74% of Americans agree that computers improve the quality of education.
In response, on May 7, 1997, the FCC adopted regulations to provide all
K-12 schools and public libraries up to $2.25 billion a year in discounts
for telecommunication services, ranging from 20% to 90% on a sliding-scale
formula, commonly referred to as the “E-Rate.” The average discount
is about 60%, with the poorest schools receiving discounts of 80% to 90%.
The discount applies to Internet access and internal connections necessary
for connecting classrooms and libraries; the E-Rate does not cover computers,
software, or other unrelated services. By April 15, 1998, more than 30,000
applications were submitted, requesting total discounts worth $2.02 billion.
Illinois accounted for approximately 6% of the total requests.
Under the Telecommunications Act, the Schools and Libraries Corporation
(SLC) is charged with reviewing and granting requests for discounted rates.
Schools and libraries must certify they have a technology assessment plan
demonstrating how discounts will enhance education. The plan must be approved
by the Illinois State Board of Education.
The 1999-2000 funding period will begin July 1, 1999, and run through
June 30, 2000. The SLC recently announced that the application cycle for
the 1999-2000 E-rate funding period will begin with an 80-day window during
which all completed applications received will be considered simultaneous
filings. The application window will open on December 1, 1998, and will
close on February 19, 1999. However, applications should be filed no later
than by January 21, 1999, to provide for the requisite waiting periods.
According to the SLC, changing the opening date from October 1, 1998
to December 1, 1998, provides a period for schools and libraries who received
funding under the first round to assess their future technology needs prior
to filing applications for the second funding period. The additional time
will also give new applicants the opportunity to benefit from “lessons
learned by the SLC in the first year of the program.” The SLC plans
to make available guidance based on those “lessons learned” after
funding commitment decisions letters for the first funding period have been
released, which, we have been told, will be by the end of October or soon
thereafter.
While the application process may be cumbersome, the benefits of receiving
discounted rates for your school district could be substantial.
Return to Table of Contents
Reproduction
Becomes "Major Life Activity" Under ADA
In Bragdon v. Abbott, 118 S.Ct. 2196, decided June 25, 1998, the
U.S. Supreme Court was called upon to clarify the reach of the Americans
With Disabilities Act of 1990 (“ADA”). The extent of that reach
is vast and may surprise and disturb public and private employers.
In Bragdon, Sidney Abbott was infected with the Human Immunodeficiency
Virus (“HIV”), but her condition had not yet developed into AIDS.
Abbott went for a dental examination, and advised the dentist of her HIV
infection. When the dentist discovered a cavity in her tooth, he informed
her of his office’s policy against filling cavities of HIV-infected
patients in the office. He proposed to perform the work at a hospital, which
could provide additional precautionary measures, without charging an extra
fee; however, she would have to pay for hospital costs. The woman sued under
the ADA, alleging that she had been discriminated against on the basis of
her “disability” (HIV infection).
In order to articulate an ADA claim, a plaintiff is required to show
that:
1. she had a physical impairment;
2. which substantially limits a major life
activity.
With regard to Abbott, the Court recognized that HIV infection
was indeed a “physical impairment” at all stages of the disease.
The next step in the analysis was whether plaintiff’s impairment affected
any “major life activity” of hers. Here the Court crafted a new
legal theory by identifying reproduction and child bearing as the “major
life activity” that was substantially limited by plaintiff’s HIV.
Applicable federal regulations provide guidance as to what constitutes
a “major life activity” by listing functions such as caring for
oneself, performing manual tasks, walking, seeing, hearing, speaking, breathing,
learning, and working. Some courts had previously ruled that “reproduction”
does not qualify as a “major life activity” because it is neither
on this list nor sufficiently similar to the items on the list. For example,
in Krauel v. Iowa Methodist Medical Center, 95 F.3d 674 (8th Cir.
1996), the court specifically found that the items on the federal guidelines
illustrative list were everyday activities which were fundamental to just
about every aspect of normal everyday existence, while reproduction was
substantively different.
The Bragdon decision rejects the Krauel rationale, and holds that
reproduction and child bearing are central to the life process itself; thus
reproduction is a major life activity. Because HIV infection inhibits conception
by posing a risk of an infection to the sexual partner as well as in utero
transmission to the fetus, the Court found that the major life activity
of reproduction was indeed substantially limited by the virus.
What is the significance of this conclusion to school districts as public
employers? The Court’s definition of reproduction as a major life activity
under the ADA has potentially profound consequences. Most ADA claims state
a connection between the employment/public accommodation sought and the
major life activity which was impaired. In Bragdon, “reproduction”
had no bearing on, and was an absolute non sequitur to, the dental services
sought by Abbott. This decision raises the spectre of increasingly exotic
claims and theories of liability by plaintiffs in the future.
Return to Table of Contents
Expulsion Hearings:
A Student's Right to Confront His Accusers
The Illinois Appellate Court
for the First District (which covers Cook County) recently issued a decision
that runs counter to most school districts’ practices regarding the
use of student-hearsay in expulsion proceedings. In Colquitt v. Rich
Township High School District No. 227, 699 N.E.2d 1109, the court held
that a student’s due process rights may be violated when a school administrator
testified about information he received from students who did not testify
at the hearing.
Colquitt (the student) was alleged to have threatened other students,
both verbally and with a gun. The District’s witnesses testified about
the parts of the incident they had observed. However, none of the witnesses
were present during the beginning of the incident, and no District witness
saw Colquitt with a gun. In addition to the witnesses who testified, the
District produced written statements from four students who stated that
Colquitt had a gun during the confrontation. Those statements were introduced
into the record through an administrator, but the students did not testify.
Colquitt produced witnesses, including himself, who stated he did not have
a gun at the incident and that he did not make a threat to anybody; rather,
it was the other students in the incident who threatened him. Following
the hearing, Colquitt was expelled for gross misconduct and for making threats,
but not for possession of a weapon.
Colquitt challenged the District’s action, claiming that he had
been denied adequate due process. On appeal, the court found that the ability
to cross-examine witnesses is a fundamental component of a fair hearing.
The court reviewed the conflicting versions of the incident between Colquitt’s
witnesses and the District’s witnesses and held that in cases like
this, where if the outcome of an expulsion hearing is dependent upon the
credibility of the witnesses, the witnesses must actually testify so that
they may be subject to cross-examination, and the hearing officer can assess
the credibility of their testimony.
The court’s decision also suggested an exception to this general
rule. According to the court, use of students’ written statements in
lieu of testimony may be justified where there is a showing of a significant
risk of harm to the student witnesses. In this case, there was no evidence
that any of the student witnesses were threatened or endangered if they
testified, other than an assistant principal’s testimony that one unnamed
student feared reprisals. In fact, the other three students were identified
in their statements and Colquitt knew who they were. Accordingly, there
was no confidentiality interest served by the District’s failure to
produce the students to testify.
It is important to emphasize that the Colquitt decision is based
on a fact pattern in which there was no showing that students would be at
risk if they testified at the hearing. In those instances, Colquitt
requires Districts in Cook County to present student witnesses to testify
and be cross-examined. Districts outside of Cook County are not strictly
bound by the Colquitt decision. Nevertheless, just to be sure, they
may wish to protect themselves from potential liability by conducting their
expulsion hearings under the Colquitt standards.
Return to Table of Contents
Attorney Profile:
William C. Kling
Ancel, Glink is pleased to welcome William C. Kling
to our firm. Bill received his B.A. degree in Economics from the University
of Colorado and his J.D. degree from the Illinois Institute of Technology-Chicago
Kent College of Law. He has provided advice and counsel to educational institutions
in both the board room and the courtroom for over 10 years, as a private
practitioner and as in-house counsel at a community college. He has extensive
experience in all aspects of school governance. Bill also co-authored numerous
publications and, in his “spare time” is an adjunct professor
of law at IIT-Chicago Kent Law School.
Education Law Report is published periodically by Ancel,
Glink, Diamond, Bush, DiCianni & Krafthefer, P.C., as a service to our public
education clients and friends. It is intended to provide timely information
of interest, but it is not a substitute for legal advice. Be sure to consult
with an attorney before taking action based on the contents. We welcome
comments and questions. Permission to reproduce is granted provided credit
is given to Ancel, Glink, Diamond, Bush, DiCianni & Krafthefer Education
Law Report.
|
