Loading...

Follow NJ School Law Blog on Feedspot

Continue with Google
Continue with Facebook
or

Valid

The Ridgefield Park Education Association (“Association”) filed an appeal with the New Jersey Appellate Division challenging a ruling by the Public Employment Relations Commission (“PERC”) in favor of the Ridgefield Park Board of Education (“Board”), which held that Chapter 78 preempted the terms of the parties’ collective negotiations agreement (“CNA”) for the period July 1, 2014 to June 30, 2018. On May 3, 2019, the Appellate Division reversed PERC’s determination in In the Matter of Ridgefield Park Board of Education and Ridgefield Park Education Association and remanded the matter to PERC to implement a remedial mechanism to refund the excess health insurance contributions to the Association members.

Chapter 78 gradually increased the health insurance contribution rates for public employees over a four-year period beginning July 1, 2011. The increasing rates are designated as Tier 1, Tier 2, Tier 3, and Tier 4. The parties’ CNA covering July 1, 2011 to June 30, 2014 and the subsequent CNA covering July 1, 2014 to June 30, 2018 stated that the Association members contribute 1.5% of their salary or the minimum set forth by statute, regulation, or code towards health insurance.

During the first and second years of the 2011-2014 CNA, the Association members contributed at the Tier 1 and 2 levels, respectively. During the last year of the 2011-2014 CNA, the Association members contributed at the Tier 3 level. Thereafter, in the first year of the 2014-2018 CNA, the Association members contributed at the Tier 4 level. At the start of the second year of the 2014-2018 CNA on July 1, 2015, the Association members initially contributed 1.5% of their salary. However, in December 2015, the Board unilaterally altered the contribution rate to the Tier 4 level for the duration of the 2014-2018 CNA, relying upon Chapter 78 and PERC’s August 13, 2015 decision in Clementon Bd. of Educ. v. Clementon Educ. Ass’n. In short, the Board argued that Chapter 78 preempted the terms of the 2014-2018 CNA regarding a 1.5% contribution level.

Based on the facts above, the Appellate Division determined that the parties did not contemplate that Chapter 78 would preempt the 1.5% contribution rate for the last three years of the 2014-2018 CNA. Rather, the Appellate Division found that the parties believed that Chapter 78 had been fully implemented at the end of the first year of the 2014-2018 CNA because the Association members completed all of their Tier 1 through 4 contributions at that point and at the beginning of the second year of the 2014-2018 CNA, the contribution level was 1.5%. 

Unlike PERC, the Appellate Division did not find it dispositive that full implementation of Chapter 78 occurred over two CNAs. The Appellate Division rejected PERC’s interpretation that Chapter 78 preempts any other contribution level in a multi-year successor agreement, such as the 2014-2018 CNA, for the first year as well as any additional years of the CNA until the “next” agreement when employee contribution levels would become negotiable.

Instead, the Appellate Division reasoned that interpreting Chapter 78 to require the Tier 4 contribution level for the remaining three years of the 2014-2018 CNA after the Association members contributed at the Tier 4 level in the first year of that CNA would create an “absurd result.”

The post Appellate Division Rules Chapter 78 Does Not Preempt Terms of CNA appeared first on NJ School Law Blog.

Read Full Article
  • Show original
  • .
  • Share
  • .
  • Favorite
  • .
  • Email
  • .
  • Add Tags 

By: Cameron R. Morgan, Esq. and Nicole Crincoli, Law Clerk

The Individuals with Disabilities Education Act (“IDEA”) requires informed parental consent to be provided prior to a child study team performing any number of different actions in the course of the special education process.  Whether a school district needs to obtain written parental consent prior to administering postsecondary transition assessments had been a question of some debate.  In a recent guidance letter from the Office of Special Education Programs (“OSEP”), Letter to Olex, 119 L.R.P. 8445, 74 I.D.E.L.R. 22 (Feb. 22, 2019), OSEP indicated that individualized education program (“IEP”) teams generally do not need a greenlight from a parent before assessing a student’s postsecondary transition needs.

Under federal and state regulations, beginning with the IEP in place for the school year in which a special education student turns 16, the IEP team will focus its discussion to include planning for needed post-secondary transition services.  34 C.F.R. 300.320(b); N.J.A.C. 6A:14-3.7(e)12.  The IEP must begin to include: (1) appropriate measurable postsecondary goals based on age appropriate transition assessments related to training, education, employment, and where appropriate, independent living skills; and (2) the transition services, including courses of study, needed to assist the child in reaching those goals.  Ibid.

The IDEA requires that a district obtain informed, written parental consent before conducting an assessment as part of an initial evaluation or reevaluation for special education and related services.  34 C.F.R. 300.000.  In order to be informed, the consent must be: (1) given in the parent’s native language, or another mode of communication; (2) the parent must understand and agree in writing to the carrying out of the activity for which his or her consent is sought, and the consent describes that activity and lists the records that will be released and to whom; and (3) the parent understands that the granting of consent is voluntary on the part of the parent and the parent can revoke that consent at any time.  34 C.F.R. 300.9. 

In Letter to Olex, the assessment at issue was a competency-based transition assessment being administered to all transition-aged students on a yearly basis, in order to develop postsecondary goals.  In its interpretation, OSEP observed the language and requirements of the IDEA in the context of these informal post-secondary assessments, which are conducted not as part of an initial evaluation or reevaluation, but simply to carry out the regulatory directive to assess post-secondary transition services for the IEPs of students approaching the last several years of secondary schooling. 

OSEP has now advised that postsecondary transition assessments are not considered evaluations or reevaluations requiring formal written, informed consent from the parent.  The term “evaluation,” as defined under IDEA, means procedures used in accordance with 34 C.F.R. 300.304 through 300.311 to determine whether a child has a disability and the nature and extent of the special education and related services that the child needs.  In Letter to Olex, OSEP wrote:

[W]e believe that generally, parental consent is not required prior to conducting an age appropriate transition assessment because the purpose of the assessment is to develop appropriate postsecondary IEP goals and not to determine whether a child has or continues to have a disability, and the nature and extent of the special education and related services that the child needs.

OSEP added that, if the IEP team determines that a reevaluation is warranted in order to obtain additional data based on the student’s educational or related service needs, then the school district would be required to obtain written parental consent consistent with 34 C.F.R. § 300.300(c).  Yet, absent a need to conduct additional formal assessments, or absent one of the other circumstances for which informed consent is necessary under state and federal regulations, this guidance provides helpful clarification to child study teams who may be unsure whether the team is at liberty to informally assess post-secondary goals and services without first obtaining written parental consent to do so.

The post OSEP Clarifies: Parental Consent Not Required to Conduct Post-Secondary Transition Assessments if Child Study Team not Reevaluating appeared first on NJ School Law Blog.

Read Full Article
  • Show original
  • .
  • Share
  • .
  • Favorite
  • .
  • Email
  • .
  • Add Tags 

When boards of education resolve disputes with parents of special education students, they often enter into settlement agreements with the parents which are approved by an Administrative Law Judge (“ALJ”) of the New Jersey Office of Administrative Law (“OAL”). On February 27, 2019, the New Jersey Appellate Division in L.A. v. South Orange-Maplewood Board of Education issued a decision affirming that parties to a settlement agreement approved by the OAL are subject to a six-year statute of limitations to enforce that agreement.

In 2000, the parent of a special education student initiated litigation against the South Orange-Maplewood Board of Education (“Board”) seeking reimbursement for her son’s education and transportation costs. In 2002, the parent and Board resolved the dispute by way of a settlement agreement, which was approved by an ALJ of the OAL. The ALJ questioned the parent regarding her understanding of the agreement and concluded that the parent accepted the terms of the agreement voluntarily. Shortly after both parties approved the agreement, the parent sought to set aside the settlement agreement. The ALJ denied the parent’s request and ordered the parties to comply with the agreement.

In 2016, the parent filed a complaint in the Superior Court of New Jersey alleging that the Board failed to make required payments in 2003 and 2008 under the settlement agreement. The Board filed a motion to dismiss the complaint arguing that the parent’s claims were barred by a six-year statute of limitations governing contract actions. The trial judge agreed with the Board and dismissed the parent’s complaint.

In her appeal before the Appellate Division, she asserted that the statute of limitations is twenty years, not six years, pursuant to N.J.S.A. 2A:14-5, which governs enforcement of a judgment entered by a court. The Appellate Division summarily rejected the parent’s argument, reasoning that the OAL is not a “court” within the State’s judicial branch of government since it is overseen by the Department of State as part of the executive branch. According to the Appellate Division, since the OAL is not a court, N.J.S.A. 2A:14-5 governing judgments by a court does not apply. Furthermore, the Appellate Division determined the ALJ or the OAL did not issue a judgment.

For these reasons, the Appellate Division agreed with the Board that the settlement agreement between the parties is a contract subject to a six-year statute of limitations and upheld the dismissal of the parent’s case.

The post Special Education Settlement Subject to 6-Year Statute of Limitations appeared first on NJ School Law Blog.

Read Full Article
  • Show original
  • .
  • Share
  • .
  • Favorite
  • .
  • Email
  • .
  • Add Tags 

Statutes are to be read sensibly rather than literally. This was the message sent by the New Jersey Appellate Division on March 14, 2019 in Wall Township Education Association v. Board of Education of the Wall Township School District when it reversed the Commissioner of Education’s decision and held that a superintendent and school district may not avoid the requirements for public comment and public hearing under N.J.S.A. 18A:11-11 simply by rescinding an existing superintendent employment contract.

The Superintendent had a contract which was to expire on June 30, 2019. After new salary caps were put in place, the Superintendent and the Wall Township Board of Education (“Board”) agreed in principle to rescind the Superintendent’s five-year contract and approve a three year contract in its place that provided for increased compensation in accordance with the new caps. The Executive County Superintendent approved the new contract, and the Board, following direction from the Executive County Superintendent, voted to approve the contract without public notice and a public hearing. N.J.S.A. 18A:11-11 requires notice and a public hearing when a board renegotiates, extends, amends, or otherwise alters the terms of a contract with a superintendent and certain other school administrators.

Trouble came quickly. The Wall Township Education Association (“Association”), certain members of the Association, and a taxpayer in the school district challenged the Board’s action through a petition of appeal. The Commissioner dismissed the petition. The Commissioner adopted the administrative law judge’s recommended decision which concluded that the Board’s action constituted a rescission of the contract and that there was no amending, extending, or altering of the terms which would trigger the statute’s notice and hearing requirements.

The Appellate Division reversed the Commissioner on appeal. It directed the Board to vote on a new employment contract for the Superintendent subject to satisfying the public notice and public hearing requirements of N.J.S.A. 18A:11-11. In reaching its decision, the Court primarily relied upon a rule of statutory construction which provides that where a literal rendering will lead to a result not in accord with the essential purpose of the act, the spirit of the law will control. The Court found that the purpose of N.J.S.A. 18A:11-11 is to provide greater transparency between the public and boards of education with respect to employment contracts of certain administrators by requiring public notice and a public hearing when the board renegotiates, extends, amends, or alters an existing contract with its superintendent. The Court concluded that renegotiation and alteration were exactly what occurred in the case, and that a mutual rescission cannot be used to circumvent the statute’s requirements. Otherwise the result would be absurd since boards could routinely avoid the requirements by executing a contract rescission. The Court also relied upon the fact that the original contract had not “expired” thus pulling the exception to the notice and hearing requirements in an instance where the contract is a replacement for an expired contract.

Boards that have followed the same path taken by the Wall Township Board of Education should consult with their solicitor about whether corrective action is necessary.

The post Contract Rescission Does Not Avoid Need for Public Notice and Hearing appeared first on NJ School Law Blog.

Read Full Article
  • Show original
  • .
  • Share
  • .
  • Favorite
  • .
  • Email
  • .
  • Add Tags 

Parents of special education students have the right to request an independent educational evaluation (“IEE”) at the expense of the school district if they disagree with any assessment conducted as part of an initial evaluation or a reevaluation conducted by the school district. However, that right is not unfettered. On January 31, 2019, the United States District Court for the District of New Jersey in S.S. and M.S., o/b/o H.S. v. Hillsborough Township Public School District overturned an Administrative Law Judge’s decision and determined (1) parents are only entitled to an IEE at the district’s expense when they disagree with an evaluation or reevaluation that has been completed and (2) parents are not entitled to an IEE if they refuse consent to an evaluation or reevaluation by the district.

In 2011, the Hillsborough Township Public School District (“District”) conducted various assessments of the student as part of a triennial reevaluation, which included social, educational, and psychological evaluations. In 2014, the District determined that no additional information was required to determine the student’s eligibility for special education benefits. The parents did not request additional assessments until June 2017, approximately two and a half years after the last reevaluation planning meeting.

In June 2017, the District and parents participated in a reevaluation planning meeting, at which time the District agreed to conduct various assessments, including psychological and educational evaluations, of the student. The parents provided written consent allowing the District to complete the assessments. The next day, the parents requested an IEE and neuropsychological assessment at the District’s expense. Ultimately, the parties met to discuss the parents’ request, at which time the District did not agree to conduct the neuropsychological assessment and the parents revoked their consent for the psychological and educational assessments that they had previously agreed the District could conduct.

The parents filed suit challenging the district’s denial of the IEE request. In ruling in favor of the District, the District Court found that at the time the parents made the request for an IEE, the District had not completed an evaluation of the student. Therefore, there was no evaluation or reevaluation with which the parents could disagree. Accordingly, the parents were not entitled to an IEE at the District’s expense. Moreover, the District Court ruled that the parents had no right to a publicly funded IEE when they revoked and refused consent for the District to complete an evaluation of the student, thereby making it impossible for the District to assess the student.

The post District Court Denies Parents’ Request for IEE appeared first on NJ School Law Blog.

Read Full Article
  • Show original
  • .
  • Share
  • .
  • Favorite
  • .
  • Email
  • .
  • Add Tags 

On January 28, 2019, the Appellate Division affirmed an arbitrator’s decision to limit the withholding of a teacher’s increment to one year. In Trenton Board of Education v. Trenton Education Association, Trenton Board of Education (“Board”) approved the withholding of a teacher’s increment for an indefinite period of time. The Trenton Education Association (“Association”) challenged that decision.

During the 2015-2016 school year, the Trenton Board employed Carmel Gabriel as a middle school teacher. The principal, who was Gabriel’s direct supervisor, and vice principal cited him for various deficiencies, such as problems with his teaching practices, failure to attend mandatory meetings, and failure to submit required reports. The administration also cited him for including vulgar, expletive filled quotations of students’ alleged comments to Gabriel in his students’ progress reports. Gabriel also allegedly slammed a door when he left a scheduled meeting after the vice principal was delayed and asked Gabriel to wait for him. After receiving warnings, Gabriel corrected his behavior.

Ultimately, the Board approved the withholding of Gabriel’s increment “effective September 1, 2016.” However, the Board did not set a termination date for that action.

In response, on behalf of Gabriel, the Trenton Education Association filed a grievance pursuant to the parties collective bargaining agreement. After the increment withholding was upheld at each stage of the grievance procedure, the Association demanded arbitration through the Public Employment Relations Commission (“PERC”).

The PERC arbitrator assigned was tasked to decide whether the Board had just cause to withhold Gabriel’s salary increment effective September 1, 2016. The arbitrator found just cause for discipline but limited the period of salary increment withholding to one year. The arbitrator found the indefinite salary increment withholding to be too harsh, explaining that the Board failed to use progressive discipline and Gabriel mitigated his conduct.

The Board filed a complaint to vacate or modify the arbitration award and the Association filed a counterclaim to confirm the award. The trial court vacated the award concluding that because the arbitrator found just cause for a salary increment withholding, the Board had the prerogative to decide whether to restore it or keep it permanent.

On Appeal, the Appellate Division analyzed the arbitrator’s decision under N.J.S.A. 2A:24-8(d) – whether the arbitrator decided a legal question not placed before him or her. In short, the Appellate Division reasoned that even though the question before the arbitrator did not include the word “permanent,” she did not exceed her authority. The Appellate Division concluded that once she determined Gabriel’s conduct was “unbecoming,” the arbitrator was within her authority to determine whether there was just cause to impose an indefinite salary increment withholding or some other remedy.

The post Appellate Division Upholds Arbitrator’s Decision to Limit Increment Withholding appeared first on NJ School Law Blog.

Read Full Article
  • Show original
  • .
  • Share
  • .
  • Favorite
  • .
  • Email
  • .
  • Add Tags 

On December 17, 2018, the New Jersey Appellate Division in Melnyk v. Board of Education of the Delsea Regional High School District upheld the Commissioner of Education’s decision that a teacher who already has attained tenure based upon his or her years of service in a particular position cannot also acquire separate tenure in an extracurricular assignment if the teacher is not required to possess a different certificate other than the one he or she already possesses in the tenured position and the teacher receives a stipend for the additional assignment that is not an integral part of the teacher’s contractual salary.

The Delsea Regional High School District Board of Education (“Board”) hired Paula Melnyk in 1991 as a full-time special education teacher. She held an Instructional Certificate with Teacher of the Handicapped and Elementary School Teacher endorsements. It is undisputed that Melnyk was tenured in this position.

Beginning in 2002, the Board assigned Melnyk to teach special education classes after her regular school day in an alternative education program (“AEP”). Her assignment to the AEP was voluntary. Melnyk was not required to hold any additional certification – the Instructional Certificate with Teacher of the Handicapped endorsements were sufficient. She received $20 per hour for the time she worked in the AEP.  Except for the 2009-2010 school year, Melnyk worked in the AEP until the end of the 2014-2015 school year. At that time, the Board assigned another teacher to Melnyk’s position, and this litigation ensued.

Melnyk appealed the Board’s decision to the Commissioner, which assigned the matter to an Administrative Law Judge (“ALJ”). Relying upon a series of previous cases, the ALJ determined that a board of education retains the authority to assign and reassign teachers to extracurricular duties as it deems fit. This discretion, coupled with the facts that Melnyk was not required to hold any additional certification and she voluntarily sought the AEP position, led the ALJ to determine that Melnyk was not entitled to tenure in the AEP position.

Melnyk then sought review of the ALJ’s decision by filing exceptions with the Commissioner, who affirmed the ALJ. Melnyk further appealed to the Appellate Division, which upheld the Commissioner, as it found that the decision was not arbitrary, capricious, or unreasonable.

The post Appellate Division Rules Teacher Not Entitled to Tenure in Extracurricular Assignment appeared first on NJ School Law Blog.

Read Full Article
  • Show original
  • .
  • Share
  • .
  • Favorite
  • .
  • Email
  • .
  • Add Tags 

By: Robert A. Muccilli, Esq.
Editor: Sanmathi (Sanu) Dev, Esq.

The question of whether a school district with a collective bargaining agreement of less than five years in duration is required to pay the increment for teaching staff members at the expiration of the agreement has existed since the amendment of N.J.S.A. 18:29-4.1.  The amendment permits school districts to adopt a salary policy schedule for a period of up to five years.

In In the Matter of Englewood Board of Education and Englewood Teachers’ Association (decided October 29, 2018) and In the Matter of Cliffside Park Board of Education and Cliffside Park Education Association (decided October 16, 2018), the teachers unions requested payment of the increment at the expiration of three year agreements.  The Boards refused and the unions filed for interim relief with the Public Employment Relations Commission (“PERC”) seeking an order that the Boards pay the increment.

The Designee of PERC granted the application in each case.  The Designees reasoned that the increments must be paid after the expiration of the three year contracts because contract language expressed the parties’ intent to maintain all terms and conditions of employment after expiration. Accordingly, the Designees ordered the immediate payment of the increment to all eligible unit employees.

The Designees relied heavily, but not exclusively, on contract language in reaching the conclusion that the unions had demonstrated a likelihood of prevailing on the merits of their respective unfair labor practice charges. The New Jersey Supreme Court’s decision in In re County of Atlantic, 230 N.J. 237 (2017) provided guidance. The Court’s decision focused on analysis of contract language pertaining to continuation of salary and benefits upon expiration of the contract term, albeit in the context of county employees. The critical contract provision in In the Matter of Englewood Board of Education and Englewood Teachers’ Association read:

This Agreement shall be effective as of July 1, 2015, and continue in effect until June 30, 20 {sic}.  If this Agreement expires, it is expressly understood that all provisions and benefits contained herein shall remain in force until a new agreement is agreed upon and signed by the parties.

Two similarly worded contract provisions were important to PERC’s decision in In the Matter of Cliffside Park Board of Education and Cliffside Park Education Association.

This Agreement shall continue in full force and effect with all attendant benefits and obligations until a successor Agreement is ratified by the Board and Association.

This Agreement shall continue in full force and effect, with all attendant benefits and responsibilities to the Board and Association, until a successor agreement is ratified by the Board and Association.

Of particular interest, the Respondent Boards argued that their situations were distinguishable from the situation addressed by the Court in In re Atlantic County because school districts cannot recoup payments to tenured teaching staff members once made.  Without much analysis, the argument was dismissed as being “of no moment.”

The unions were found to have demonstrated irreparable harm.  PERC precedent was relied upon to hold that a failure to pay an increment amounted to repudiation of the exercise of employees’ statutory right to have such issues negotiated on their behalf by their majority representative.  The notion that ordering payment of the increment would effectively limit the ability of the Boards to negotiate compensation did not hold sway.

It is anticipated that these decisions will be appealed.  In the interim, these developments are significant because (1) most school districts have three year collective bargaining agreements, (2) the requirement to pay the increment upon expiration of the agreement amounts to an automatic salary increase, and (3) a district’s negotiations position may be impacted.  A district should evaluate past practice and the language in its agreement to determine whether it has a similar exposure.

The post Districts Ordered to Pay Increments Upon Expiration of Contract appeared first on NJ School Law Blog.

Read Full Article
  • Show original
  • .
  • Share
  • .
  • Favorite
  • .
  • Email
  • .
  • Add Tags 

On November 9, 2018, the New Jersey Commissioner of Education (“Commissioner”) concurred with an Administrative Law Judge’s finding in Mirda v. Board of Education of the Union County Educational Services Commission that the position of Bedside Tutor fell within the substitute teacher exception and is not eligible for tenure accrual. The Union County Educational Services Commission Board of Education (“Commission”) provides various services to school districts in Union County, including one-to-one bedside instruction at hospitals to students enrolled in Union County schools. Bedside Tutors are paid at an hourly rate, do not receive benefits or paid holidays, and are not guaranteed a certain number of work hours/days or yearly salary.

Gail Mirda, the Petitioner in this matter, was employed by the Commission as a Bedside Tutor for fifteen years. While her work hours varied, she worked about six to eight hours per day for the last seven years. Petitioner argued that because she worked more than three full-time years in the Bedside Tutor position, which required a teacher certification, she is entitled to tenure pursuant to N.J.S.A. 18A:28-5. She also argued that the substitute teacher exception under  N.J.S.A. 18A:16-1.1 did not apply because she was not replacing a specific employee of the Commission.

The Administrative Law Judge (“ALJ”) summarily rejected Petitioner’s arguments. In short, the ALJ analogized the Bedside Tutor position to that of a Home Instructor and followed a series of cases in which Home Instructors were determined not to be tenure-eligible because their positions and responsibilities fell within the substitute exception to the Tenure Act. Bedside Tutors, like Home Instructors, substitute for a regular classroom teacher due to a student’s inability to attend school and are not regular teaching staff members. The ALJ reasoned that Petitioner was not required to substitute for a specific employee of the Commissioner in order to escape the substitute teacher exception. As such, Petitioner was not entitled to tenure accrual in the position of Bedside Teacher.

The post Commissioner of Education Rules Bedside Tutor Position Not Eligible for Tenure Accrual appeared first on NJ School Law Blog.

Read Full Article
  • Show original
  • .
  • Share
  • .
  • Favorite
  • .
  • Email
  • .
  • Add Tags 

An individual served as a board of education member for an initial term. During his candidacy for reelection, the local education association and statewide education association decided to endorse the individual. The individual was reelected. Is this a conflict of interest and a violation of the School Ethics Act? Not necessarily, said the School Ethics Commission (“SEC”) in Advisory Opinion A10-18 issued on June 26, 2018.

The local education association (“LEA”) offered financial support to the individual, which he did not accept. On its own accord, the New Jersey Education Association (“NJEA”) circulated printed material endorsing the individual’s candidacy. The individual serves on the board of education’s negotiations team. He also received notice that the LEA President may file a lawsuit against him.

In its advisory opinion, the SEC explained that a local and/or statewide union’s endorsement of a candidate does not automatically create a future conflict unless  financial contribution is given and is intended to influence the individual in the discharge of his duties as a board member. Legitimate political activity by itself does not violate the School Ethics Act and does not per se create a conflict.

Based on the individual’s circumstances, the SEC found that the board member in question did not have an automatic conflict. The SEC cautioned the board member to not surrender his independent judgment to any special interest group. The SEC also advised that if the LEA President initiates a lawsuit against him, he should recuse himself from any matter related to the LEA.

The post Union Endorsement of BOE Candidate Not an Automatic Conflict appeared first on NJ School Law Blog.

Read Full Article

Read for later

Articles marked as Favorite are saved for later viewing.
close
  • Show original
  • .
  • Share
  • .
  • Favorite
  • .
  • Email
  • .
  • Add Tags 

Separate tags by commas
To access this feature, please upgrade your account.
Start your free month
Free Preview