Reflections on Public Service
School Board Workshop:
13 Ways to Improve Board Meetings
Case Notes:
School Buses and Tort Immunity: Private v. Common
Carriers
To Award or Not to Award: That Is the
Question
Attorney Profiles: Tim Guare and Dean
Krone
Looking Back,
Looking Forward...
Reflections on Public Service
The Joint Annual Conference is often the first official function attended
by newly-elected board members, other than their installation meeting. Recently,
Mr. Guare, a partner with our firm, came to the end of his six-year tenure
as a member of the Riverside Brookfield High School District 208 Board of
Education, when he moved out of the district. We thought wed share
a few glimpses of his experience.
Be careful what you ask for...
Part of R|Bs charm
is that its made up of relatively small villages where citizens
opinions can have tremendous impact. Prior to moving to the District, I
had spent 10 years as a teacher before becoming a labor attorney representing
school districts which typically devote 70% of their budgets to personnel
costs. Needless to say, I had a bit different perspective on the state of
local educational affairs.
I was flattered, and even more surprised, when friends and acquaintances
suggested that I run for the Board. I considered all the usual reasons for
running for public office: money (none), luxury junkets (even less), and
prestige, power and the esteem of your constituency (the least yet). I focused
on the two reasons which, for me, seemed to be the strongest motivation:
by serving on the Board, I would not only have the opportunity to make a
difference, but also I would be earning my perpetually-vested right to gripe.
The lawyer who represents himself...
All Illinois local school
boards are comprised of citizens of the community, with their own unique
talents and interests. I was privileged to serve on a Board that included,
among others, a former federal prosecutor, an IRS appeals officer, a CPA
and people with prior board experience with other organizations. This group
of diverse and talented people blended quite well into a cohesive policy-making
body. Not that the group was without dissent. Often the debate was spirited,
perhaps even heated, but always sincere and in good faith. Some Board members
were natural leaders. Others were skillful consensus builders. All my fellow
Board members did an excellent job of filling their individual niches.
For my part, my colleagues seemed to feel that
it was only logical that a member/public sector labor attorney should represent
them at the bargaining table (honestly, not my decision). My day
job as labor counsel is to advise clients about their available options
and the consequences that may flow from them, and then stay out of the way
as the client makes the policy choice. Now I was put in the extraordinary
(and scary) position of wearing two hatspolicy maker and
advocate. It was not enough that my day-in, day-out professional tools had
to be used to reach the goals sought by the client. Now I was the client
and had partial ownership of the objectives of the process. Some of my colleagues
had similar opportunities to use their skills and backgrounds by helping
the Board develop litigation strategies, long-term financial plans and taxation
strategies. Even though these tasks meant extra work, Board members had
a stronger proprietary interest in these processes as a result of contributing
the skills they knew best.
Our experience taught me that board members should
not hesitate to bring their own special talents to the position. Drawing
on your personal strengths to help your district attain its goals can increase
your effectiveness as well as your enjoyment in the process.
If its not broken, fix it anyway.
When I was first elected,
the major problems facing the District included declining enrollment, deficit
budgets and unreasonably high debt service. If our agenda had remained limited
to these few but very serious issues, our work would have been over some
time ago. Instead, navigating the District into the 21st Century required
facing a host of new challenges such as technological changes, tax caps,
increased enrollment in the face of a relatively flat EAV, physical plant
adaptation for ADA compliance, standardized testing issues, and new needs
created by demographic changes in the community, just to name a few. The
only constant in life is change, and every school district, including R|B,
is as dynamic as the community within its boundaries.
To help us cope with these tides of change, R|Bs
administrative team, led by a superb superintendent and principal, provided
detailed information and cogent recommendations to assist the Boards
policy-making. The administration constantly pressed us to consider and
address forward-thinking issues, rather than merely confronting the current
crises. However, they always understood that their role in the partnership
was to recommend, implement and execute policy, rather than to make it.
This working relationship proved to be a key ingredient in the development
of a highly successful agenda for the Districts continued growth.
Assuming that our situation was not unique, I
think its fair to suggest that, if a board member ever feels satisfied
that all the work in the district is done, its probably the appropriate
time for that board member to step down. When an elected official believes
that all goals are met and there are no new ones, its time to make
way for someone with new thoughts, new energies, and a sense of direction
which reflects the community, and identifies and serves its future needs.
No good deed goes unpunished.
Anyone who seeks election
to a school board for the accolades and appreciation of the community is
in for some major disappointment. More often than not, public service is
a thankless job. You will undoubtedly hear from senior citizens who dont
want their taxes raised by a school district from which they receive no
immediate benefit. You will be confronted by parents who want special programs
that serve their childs unique needs. You will receive more than enough
unsolicited advice on the appropriate starting lineup for this weeks
basketball game (i.e., their kid). At each and every point of diverging
views, there is the potential for conflict. The loudest critical voices
will frequently base their opinions on a very selective review of the relevant
facts. And always, no matter what decision you make, you can plan on hearing
from the persons whose ox was gored, but rarely
a gesture of gratitude from the beneficiaries of the same decision. Ah,
the glory of public service!
Does it feel good when it stops?
The end of my tenure as
board member did not come by choice, but rather by legislative fiat when
I moved out of the district. If I had it to do all over again, and knowing
now about public service what I did not know then, would I make the same
decision to serve?
I now have my Tuesday nights back, and my Wednesday
mornings are relatively Visine-free. I know my telephone rings far less
frequently, and that I have much less to read on a weekly basis. Ive
lost the constant feeling of the Dutch boy with his finger in the dike.
It always seemed that we just couldnt respond to problems fast enough
to outrun them or to find a time of relative repose for the District.
However, like most other school board members,
I served because I wanted to give back to my community and because I hoped
I could make a difference. Looking back, I can see that District 208 is
a different place. The crises that faced the District in 1991 no longer
hang over the schools head like a sword of Damocles. True, new problems
have arisen, but somehow they seem less serious than those that lay on the
Districts horizon six years ago.
All in all, the changes in the District have been
consistent with the boards policy-making efforts, and the administrations
tireless efforts to implement those decisions. If we had a magic wand, other
goals would have been met as well. Nevertheless, once I got past the frustration
of those tasks that couldnt get done before my departure, I found
the overall experience to be satisfying, rewarding and even exhilarating.
For that reason, I heartily endorsed the recent successful effort of my
partner, Dean Krone, to run for a seat on his Districts board (see
Profiles, page 8).
So, yes, even knowing now what I didnt know
then, I believe I would choose to do it again. To those of you who are just
starting your term of service, how good you feel when it stops
will no doubt be measured by the energy and care you invest in your tenure.
Good luck, and I hope you all will be able to say you got good returns on
your investment!
Return to Table of Contents
School Board
Workshop:
13 Ways to Improve Board Meetings
Do your districts meetings currently end after the date has
changed on your watch? Is public commentary out of hand? Are you weary of
talking and talking about issues and taking no action? Here are excerpts
from suggestions by Stewart H. Diamond on how to help make your meetings
more efficient and effective.
1. Prepare an Agenda for All Meetings
Since January 1, 1995, both regular and special meetings of governmental
bodies are required to have agendas. Prior to that time, only special meetings
were required to have agendas. One person should be designated in advance
to prepare agendas. At regular meetings, items can be added to an agenda
under whatever rules of procedure the board has adopted. For special meetings
(as opposed to regular meetings), the convening authority establishes the
agenda, and only those items set forth in the notice of the meeting can
be discussed.
2. Dont Clutter up an Agenda with Items
That Are Not Ready to Be Discussed or That Have Been Discussed to Death
Matters which have appeared on an agenda which are not ready to be discussed
because some item of information is missing should be tabled until the date
when that report is ready or that piece of information is available. Since
the public has a right to follow that particular matter from date-to-date,
any motion to table should be to a specific date. If all the needed material
is not ready when that date arrives, the matter should be continued again
to a definite date. If a matter of controversy has been finally decided,
and there is a desire to prevent the issue from being raised again in its
same form, a motion can be made to reconsider the matter by someone on the
prevailing side. If the motion to reconsider fails, then under most rules
of order, that item cannot come before the legislative body again in its
same form or without any change of circumstances. Democratic principles
can be followed and minority rights protected without turning every matter
of controversy into a never-ending story.
3. Make Substantial Use of a Consent (Omnibus)
Agenda
Illinois law contains a wonderful parliamentary device known as the
consent agenda. By using that device, a group of diverse items,
including simple motions, motions to authorize the expenditure of funds,
motions to pass ordinances or resolutions, motions to receive or accept
documents, and all other varieties of governmental actions, can be approved
through a single action which has two parts. First, by unanimous action,
the governmental body must agree what items are to be acted upon under the
consent agenda. A single vote is then taken on the acceptance or rejection
of all items on the consent agenda. A board member may agree on a list of
consent agenda items and then vote no on the passage of the
entire consent agenda. The establishment of the consent agenda can be accomplished
without debate or with debate, provided elected officials are given an opportunity
to ask questions about motions prior to the vote. Sometimes, a simple answer
or two from a colleague or an administrator may permit the item to be placed
on the consent agenda. The use of this device avoids the need for meaningless
or pro forma debate on matters which require no debate, or where enough
debate has taken place on previous occasions. All items which are placed
on the consent agenda must, by law, be briefly explained to the public or
press in attendance. The explanation can be short and straight forward.
4. Limit Meeting Length
Governmental business debates late into the evening are probably not
in the best interests of the public or board members unless the board is
composed of lounge singers or insomniacs. It is also probably unfair to
the public to take up matters of importance at a time when most citizens
are asleep. School boards which consistently meet beyond 11:00 p.m. should
consider starting meetings earlier or establishing a curfew.
If there is an important and unique matter before the board, a curfew can
be waived by an extraordinary majority vote. Absent such a vote, which should
come infrequently, a curfew should, over time, teach the board discipline
and allow elected officials to occasionally see their families.
5. Consider the Use of Intergovernmental Agreements
Many times, school boards spend much time discussing the goals and intentions
of other governmental bodies. What are the thoughts of a municipality which
is considering a tax increment financing district? Accordingly, time can
be wasted attempting to predict the actions of other governmental bodies.
Sometimes boards are tempted to go into an improper closed session to evaluate
rumors about the action of another governmental body. Often the only way
to determine the actual views of another governmental body is to hold a
joint meeting at which a quorum of both governments are in attendance. Portions
of such meetings may be held in closed session if, for example, they involve
litigation by a third party or the acquisition of property. Such meetings
are perfectly legal under Illinois law, provided that adequate public notice
is given. If common views are reached at these meetings, the parties can
enter into an intergovernmental agreement. Such agreements allow for an
expansion of powers because governmental bodies can agree to anything that
is not prohibited by State law or by local ordinance.
6. Limit or Control Public Comment
Under Illinois law, most meetings must be open. Open meetings, however,
are not the same thing as free for alls between the board and
its opponents. Meetings must be open to the public, but the public has no
specific right to participate other than in those situations in which a
public hearing is required. Therefore, the board may limit the role of the
public to that of observers.
Most school districts allow the public to speak at their meetings. The
time and manner in which such public participation is allowed is entirely
within the discretion of the board. No single member of the legislative
body has the right, absent some rule to that effect, to authorize audience
involvement in a board meeting. Even the board president cannot do so if
there is a procedural rule, passed by the board, which forbids or restricts
that practice.
In many districts, public comment at specific times, or even in the
middle of board meetings is not disruptive and does not unduly extend those
meetings. Unfortunately, in some districts, the experience is different.
In those districts, the board should take action to prevent the disruption
or undue extension of meetings as a result of public participation.
7. Use Consultants Wisely
Consultants are not performers and should not be encouraged to protract
meetings through the presentation of lengthy and erudite reports. Your lawyer
or engineer should be told that he or she is not paid by the word or the
drawing. The submission of written reports in advance of board meetings
should be encouraged. Further, board members should always be encouraged
to ask questions of the consultants before board meetings. Consultants or
staff members should not be allowed to muse over a problem at length at
a meeting when a correct and short answer, perhaps even in writing, could
have been submitted prior to the meeting. Matters on a consent agenda, especially
those which have previously been fully discussed at a board meeting, should
not be presented to the board anew by a consultant or a staff member. Succinct
answers and reports should be encouraged.
8. Limit Board Debate
Every board president has a different style. Some run their meetings
like drill sergeants, while others run their meetings like psychiatrists.
Each approach is valid as long as it does not interfere with the full discussion
of public issues or turn such discussion into epic poems. A president who
allows unlimited discussion of all matters should re-think that philosophy
if meeting lengths extend beyond the boards endurance level. Where
a board president is unwilling to limit debate, a board majority may do
so. A rule can also prevent a board member from retaking the floor until
all other board members who wish to speak have had an opportunity to do
so. In addition, a board member can be limited in the total number of times
that he or she is permitted to speak on a particular matter. As long as
rules of this nature are applied fairly and uniformly, the process of debate
should not suffer.
9. Observe Timeliness
Public meetings should start on time. Meetings should begin at the appointed
hour if a quorum is present. Except in unusual circumstances, matters should
not be deferred until a full board is present. Where a matter
is to be put over until all members interested in this crucial item can
be present, everyone interested in discussing this matter should be informed
in advance of the meeting. This will not only prevent double discussion,
but will discourage members of the public from appearing to discuss a matter
which will not be acted upon at that meeting. It will also save parties
with hired consultants from the cost of bringing them to meetings only to
discover that the matter will be continued to a later date.
10. Utilize Legally Noticed Pre-meeting
Sessions
Some boards have found that the formalities of board meetings prevent
members from asking questions and stating views in a more informal setting.
Prior to the passage of the Open Meetings Act, some districts held pre-board
meetings at which discussions took place about agenda items. Such
meetings are still possible under Illinois law, so long as they are advertised
as either committee of the whole meetings or reflect a starting time earlier
than the normal school board meeting. For example, a board which normally
meets at 8:00 p.m. can give public notice of an open pre-meeting
session at 7:30 p.m.
At that pre-board meeting, the president may go over the
agenda and answer any questions which board members feel more comfortable
raising in this informal setting. Sometimes at that meeting, board members
can agree that certain items should be deferred to a later time, or that
additional specific reports should be submitted before the board is ready
to act. If one combines this process with the use of a consent agenda,
the board meeting can principally address only those matters which need
to be actively debated in a full public forum. Members of the press should
be encouraged to attend this pre-board meeting. They can be
invited to address questions to the board at that time. Even if they are
not allowed to participate, the information which the members of the press
learn can help them to better understand and interpret the matters which
are discussed at the board meeting.
11. Hold Retreats
Board retreats are effective both for districts which are experiencing
strife and for those which are not. The retreats must be noticed as special
board meetings under the Open Meetings Act. However, if the meeting is noticed
for purposes of board self-assessment and a facilitator such as a representative
of the IASB is present, the meeting can be held in executive session. Such
meetings can be relatively informal, or they can be highly organized. There
are persons trained in industrial psychology who can provide great help
to a district in such sessions. Such individuals normally keep the discussion
on constructive matters and force troublesome issues to be raised when the
parties may be too polite to do so. Districts in which the elected officials
hold similar views can use these sessions for strategic planning and to
raise issues which do not immediately arise out of day-to-day governmental
operations. These sessions are equally or more useful for districts in which
trust has broken down between parties or where definite factions exist.
Although not all problems can be solved in those situations, the warring
parties may be able to establish a relative truce so that not every issue
becomes highly politicized. It is, however, asking too much from such sessions
if they take place under the shadow of a political campaign.
12. Prepare Full Agenda Packets
One of the great advantages of the employment of superintendents is
their commitment to submitting a full packet of materials explaining the
agenda items to the board well in advance of the board meetings. Such a
packet of material should include the following:
a. Copies of all resolutions on which the board will be asked to act
at the meeting. Although it may sometimes be difficult to get all the material
to the board in the packet, great efforts should be taken to do so.
b. Copies of any reports which recommend that the board take specific
action.
c. Copies of letters or correspondence. The advent of the Xerox machine
should make it unnecessary to read any of these letters at board meetings.
d. Tabulations of bid openings and any recommendations regarding the
lowest responsible bidder.
e. Copies of any significant contracts the board will be asked to approve.
There is no clear rule as to the period of time during which elected
officials need to review these documents. Certainly, if a meeting is to
take place early in the week, the elected board members should have the
great bulk of the materials by Friday of the prior week. Some districts
have a rule that no matter will be placed upon the agenda for which the
requisite materials are not submitted to board members at least four or
five days in advance of the meeting.
13. Conduct Training Sessions for Elected Officials
Often, long and less effective board meetings are caused by the actions
of newly-elected officials who lack knowledge about the job they have undertaken.
In recent years, a growing percentage of public officials are elected to
the board without prior service on boards or committees. These people are
frequently elected on a platform of mistrust for government and a pledge
to shake things up. Sometimes, while trying to shake things
up, they unnecessarily slow things down. Newly-elected
officials should be given help in overcoming their difficulties. The district
should be prepared to pay the tuition, and, if necessary, travel costs,
for newly-elected officials to attend conferences of the Illinois Association
of School Boards and regional associations. The officials should be encouraged
to attend and be provided with other aids which discuss the way in which
school board meetings can work most effectively.
Return to Table of Contents
Case Notes:
School Buses
and Tort Immunity:
Private v. Common Carriers
Since the tragic bus/train accident involving Fox River Grove
School District 155, in which several students were killed, school bus safety
has gained heightened attention. Our law firm is currently defending several
governmental entities in litigation that has resulted from school bus accidents,
including the Fox River Grove case. An important factor that often comes
into play when defending these cases is whether the school bus was being
operated as a common carrier or a private carrier.
If the school bus is operating as a common carrier, the standard of
care owed is the highest degree of care. The application of
this standard would make it very difficult for school districts to escape
liability because this common law standard makes common carriers virtual
insurers for their commercial passengers. In addition, the immunities and
defenses contained in the Tort Immunity Act are not available to common
carriers. On the other hand, if a school bus is operating as a private carrier,
the applicable standard of care would be ordinary and reasonable care,
which is the same standard that applies to private passenger vehicles. Tort
Immunity Act defenses are available when the districts actions meet
this lower burden.
Recently, the Appellate Court addressed this issue in the case of Doe
v. Rockdale School District No. 84, 679 N.E.2d 771 (3rd Dist. 1997).
The court found that the school bus in question was not a common carrier,
allowing the school district to assert immunities under the Tort Immunity
Act. By implication, the court found that the standard of care applicable
was that of reasonable care.
In its opinion, the Rockdale court defined common carrier
as one who undertakes for the public to transport from place to place
such persons or goods of such as choose to employ him for hire. The
court concluded that the definitive test was whether the carrier serves
all the public alike. In Rockdale, school bus transportation was available
only to students who attended schools within the District. Therefore, the
court ruled that the school bus was operating as a private carrier. The
fact that the School District contracted with a private company to provide
school bus transportation services had no impact on the ruling.
Darcy L. Proctor of our office was recently successful in getting
a case dismissed for one of our firms school district clients, relying
on Rockdale. The primary issue involved what standard of care was owed by
the district to a student who was injured when she stepped into a pothole
while boarding a school bus. The district employed the bus driver and provided
transportation for its students to and from school. Darcy argued that the
districts conduct should be governed by the standard of reasonable
care instead of the highest degree of care because the district was not
a common carrier. The court agreed and ruled that the school bus was being
operated as a private carrier, and that the standard of reasonable care
applied. The case was ultimately dismissed because the evidence showed that
the district had not violated this standard. We will be sure to keep our
clients and friends informed as the state of the law clarifies this very
important issue.
Return to Table of Contents
To Award or Not
to Award: That Is the Question
Public officials often ask
whether there is any flexibility in awarding a public works contract to
a company that is not the lowest responsible bidder. Occasionally, this
question is answered by the courts. The Fourth District Appellate Court
recently concluded that the Quincy Public School District No. 172 School
Board violated the competitive bidding statute by selecting as its contractor
for a school boiler replacement project a company that was not the lowest
responsible bidder. Despite the Districts disappointment, something
useful can be learned from this unfavorable ruling.
The controversy began when the Quincy School Board prepared bid specifications
for its project to replace boilers in the Quincy Junior High School and
advertised for bids in the local paper. Five firms submitted bids. Doyle
Plumbing was the lowest of the five, followed closely by Wand. Although
the Board did not question the quality of the product to be supplied by
Doyle or Doyles competence to complete the tasks required in the bid
specifications, the Board members did express concern about the travel time
between Doyles company in Jacksonville and Quincy. Based upon this
concern, the Board selected Wand, a local company, assuming Wand could provide
faster maintenance and repair service to the boiler. While this may seem
like a reasonable basis for the contract award, it made Doyles blood
boil and Doyle drove to the nearest courthouse to file suit against the
School District.
In the lawsuit, Doyle claimed that it should have received the contract
because it was the lowest bidder and demonstrated its ability to meet the
specifications. In its defense, the Quincy School Board relied upon Section
10-20.21 of the School Code which allows school districts to consider conformity
with specifications, terms of delivery, quality and serviceability
in reviewing bid submittals and awarding contracts. The School District
argued that serviceability means the ability of the bidder to
provide repair service to the product and that the companys availability
was therefore a relevant factor. The court rejected this interpretation,
looking instead to the dictionary definitions of serviceability
as well as how this term has been construed by other courts.
According to the court, the ordinary meaning of serviceability
is fitness to give service: usefulness for a purpose: wearing quality:
durability, serviceableness. Consistent with other statutory references
and the underlying purpose of Section 10-20.21, serviceability is intended
to refer to the product itself or the supplies, materials or work rather
than the bidder. Interpreting serviceability in this manner
will promote the purpose of the statute, which is to encourage competition,
whereas relating the term to the bidders ability to provide maintenance
on the supplies, materials or work when the contract makes no reference
to service would allow the shield of serviceability to be raised
in defense of any contract awarded to a local bidder who is obviously closer
geographically to the project than a non-local company.
The School Districts downfall may have been caused by the absence
of any reference in the bid specifications to the desired response time
for repairing and maintaining the boiler. It is possible that the decision
may have been different or the lawsuit might never have occurred if those
documents stated that the bidder would have to demonstrate its capacity
to respond in a timely manner in the event of an emergency affecting the
operation of the boiler. Because a boiler must heat an entire school filled
with students and faculty, it makes good sense to expect the company that
installed the boiler to be able to get to the site quickly to render emergency
service in the event of a failure or malfunction. Unfortunately, the bid
documents were silent in this regard.
The court found that the Board members acted in good faith and not on
the basis of favoritism in awarding the bid to the second lowest bidder.
Again unfortunately, their fine intentions did not prevent the court from
ruling that the Board violated the statutory mandate to award the contract
to the lowest responsible bidder.
A lesson to be learned or possibly reiterated is that all important
qualifications and factors germane to the particular project being advertised
must be clearly spelled out in the bid documents. In this way, the government
entity can reject the lowest responsible bidder if that company fails to
demonstrate its ability to comply with the stated specifications. (Doyle
Plumbing and Heating Company v. Board of Education, Quincy Public School
District No. 172, 225 Ill.Dec. 362 (4th Dist. 1997).)
Return to Table of Contents
Attorney Profiles
We at Ancel, Glink are proud to have attorneys in our ranks who have
served as elected officials for various units of local government, including
school districts. Several of the firms partners have served on school
boards and bring their practical experience to our representation of school
districts. In addition to those profiled below, partner Robert W. Rolek
has served as a member and President of the Board of Lake Bluff School District
65.
Tim Guare
Timothy E. Guare recently concluded six years of service
as a school board member in Riverside Brookfield High School District 208,
when he moved out of the District. Tim concentrates his practice in labor
and employment matters for all types of units of local government, including
school districts. Tims experiences as a school board member and a
former teacher allow him to bring a unique perspective to the bargaining
table. Tim serves as the labor and personnel counsel for a number of our
school district clients. Tim frequently speaks on employment and personnel
issues before several state public employer organizations, including the
IASB. In addition, Tim has served as an author of chapters on labor law
in IICLEs Practice Handbooks on School Law and Municipal Law. Tim
and his wife, Cami, live in Grayslake, Illinois. In his spare time, Tim
enjoys biking and golfing and continues to be active with high school bands
and related competitive youth activities as a judge and program consultant.
Dean Krone
Dean W. Krone concentrates his practice with Ancel Glink
in the corporate representation of governmental clients, including school
districts. Dean has represented school districts in daily administration
matters, as well as issues involving special education, disconnection and
annexation, and tort defense. Having served as a math teacher for several
years before practicing law, Dean brings first-hand knowledge to school
law problem solving. He has spoken to school district organizations on a
variety of topics. This November, the voters of Park Ridge-Niles Consolidated
Community School District 64 elected Dean to serve as a member of the Board
of Education. Dean and his wife, Sharon, live in Park Ridge, where they
spend their free time enjoying activities with their nine-year old son,
David, and their four-year old twins, Lauren and Daniel.
Return to Table of Contents
School Law Briefing 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, P.C. School
Law Briefing.
Editor: Timothy E. Guare; Design: Douglas
M. Doty

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