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RUNNING HEAD: CLASSIFICATION
EXAM CASE: STUDENT CLASSIFICATION
JOYCE H. FRAGALE
SCHOOL LAW, EDU 702
UNIVERSITY OF NEW ENGLAND
MARCH 1, 2014
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STUDENT CLASSIFICATION EXAM CASE:
Exam Case: Mississippi school district (amends its’ policy to include representation that reflects
the racial mix of the student body. A parent files suit since his child was eliminated from
becoming a class officer due to this quota system). drops policy of reserving class officer
positions based on race [9/1/2010]
Facts: Nettleton School District has dropped a 30-year-old policy that restricted student
eligibility for class offices based on race, reports Education Week. The policy was intended to
promote racial equality in a school district where the local population is approximately 66%
white and 32% African-American. However, a flurry of online criticism erupted after the parent
of a mixed-race student learned her daughter was ineligible to run for class reporter because of
the race restrictions. The Mississippi chapter of the NAACP called on the U.S. Department of
Justice (DOJ) to conduct an investigation. According to a statement posted by Superintendent
Russell Taylor, the practice had been in place for 30 years, dating back to a time when school
districts across Mississippi came under close scrutiny from DOJ over desegregation. "It is the
belief of the current administration that these procedures were implemented to help ensure
minority representation and involvement in the student body," the statement said. "It is our hope
and desire that these practices and procedures are no longer needed."
The parent, Brandy Springer, stressed that even if the rule is an attempt to ensure black and white
participation, diversity is no longer a black and white issue, with a growing number of mixedrace children, Hispanics and other ethnicities attending school together. The school agreed,
saying that it "acknowledges and embraces the fact that we are growing in ethnic diversity and
that the classifications of Caucasian and African-American no longer reflect our entire student
body." Charles Hampton, a vice president of the Mississippi NAACP, said, "That’s something
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that shouldn’t be happening anywhere in America, but we still have pockets of it happening at
certain schools." He added, "The local community needs to get involved and demand they
change the policy."
Let’s pretend that the school did not drop the policy, but amended it to now include
representation that reflects the racial mix of the student body. A parent files suit since his child
was eliminated from becoming a class officer due to this quota system.
CLASSIFICATION CASE ANALYSIS
Legal Basis for Student Classification
Several cases have led to current laws surrounding classification. In the 1857 Dred v.
Scott Case, Dred, an African American slave, was denied freedom by the courts. The courts
decision stated “because Scott was black, he was not a citizen and therefore had no right to sue.
The decision also declared the Missouri Compromise of 1820, legislation which restricted
slavery in certain territories, unconstitutional”.
(http://www.pbs.org/wgbh/aia/part4/4p2932.html).
De jure segregation was upheld in the United States Supreme Court case Plessy v.
Ferguson, 163 U.S. 537 (1896). The court interpreted the 14th amendment as meaning that racial
segregation was acceptable under the law, as long as separate facilities for each group were equal.
In 1954 the separate but equal interpretation of Plessy v. Ferguson, 163 U.S. 537 (1896),
was overturned by the landmark case of Brown v. Board of Education, 347 483 (1954). “The key
language in Brown regarding Plessy is: “We conclude that, in the field of public education, the
doctrine of "separate but equal" has no place. Separate educational facilities are inherently
unequal” (Hillman and Trevaskis, 2014, p. 4-7).
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In 1957 in Little Rock, Arkansas, the “Little Rock Nine”, nine African American students
recruited by the NAACP in an attempt to integrate Central High School, became the first African
Americans to attend the school. Ernest Green became the first African American to graduate
from the school (Hillman and Trevaskis, 2014).
Plans for desegregation were often ineffective. Schools who were under desegregation
orders often claimed de facto segregation. This was the case in Green v. County School Board
of New Kent County, VA, 391 U.S. 430 (1968). The district’s “freedom of choice plan” failed
to produce results since three years after its’ implementation “no Caucasian children had
enrolled in the historically all black school, and only a few African American children had
enrolled in the predominately white school” (Hillman and Trevaskis, 2014, p. 4-8). The district
claimed that this was due to individual choice. The court disagreed and developed six criteria
used to judge “ whether unitary status had been achieved”. The Green criteria are:
1. Composition of the student body;
2. Composition of the faculty;
3. Composition of the staff;
4. Transportation;
5. Extracurricular activities; and
6. Facilities
(Hillman and Trevaskis, 2014, p. 4-8)
Many other cases to guide desegregation followed:
Swann v. Charlotte-Mecklenburg Board of Education, 402 U.S. 1 (1971)
Keyes v. School District No. 1, Denver 413 U.S. 189 (1973)
Pasadena City Board of Education v. Spangler, 427 U.S. 424 (1976):
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Parents involved in Community Schools v. Seattle District No.1, 2007
Meredith v. Jefferson County Board of Education, 2007
David Trevaskis, Esquire (personal communication, February 22, 2014) lists five
principles to consider when determining how race may be used:
1.
Always consider race-neutral approaches first to meet diversity goals;
2.
If these approaches are not workable, have a paper trail indicating why;
3.
A variety of “generalized” race-conscious policies, e.g., the overall racial composition of
a neighborhood can be considered, but all students in neighborhood regardless of race
must be treated the same;
4.
Provide student with an “individualized review” such that race is a narrowly tailored
plus factor along with other non-racial consideration;
5.
Race should not be a student’s defining factor for any decision.
Lawyers will use both specific laws and the Fourteenth Amendment when bringing
actions that deal with student classification (Hillman & Trevaskis, 2014).
The First Amendment of the United States Constitution
Congress shall make no law respecting an establishment of religion, or prohibiting
the free exercise thereof; or abridging the freedom of speech, or of the press; or the right
of the people peaceably to assemble, and to petition the government for a redress of
grievances (http://www.law.cornell.edu/constitution/first_amendment ).
Section 1 of The 14th Amendment of the United States Constitution
All persons born or naturalized in the United States, and subject to the jurisdiction
thereof, are citizens of the United States and of the State wherein they reside. No State
shall make or enforce any law which shall abridge the privileges or immunities of citizens
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of the United States; nor shall any State deprive any person of life, liberty, or property,
without due process of law; nor deny to any person within its jurisdiction the equal
protection of the laws (http://www.law.cornell.edu/constitution/amendmentxiv ).
This ensures equal treatment for all students regardless of their classification.
Many federal laws also protect groups of individuals:
Title VI of the Civil Rights Act of 1964
No person in the United States shall, on the ground of race, color, or national
origin, be excluded from participation in, be denied the benefits of, or be subjected to
discrimination under any program or activity receiving Federal financial assistance
(http://www2.ed.gov/about/offices/list/ocr/docs/hq43e4.html).
Title VII of the Civil Rights Act of 1964
Title VII of the Civil Rights Act of 1964 is a federal law that prohibits
discrimination in employment on the basis of sex, race, color, national origin, and
religion… (http://www.aauw.org/resource/title-vii-of-the-civil-rights-act-of-1964/).
Equal Educational Opportunities Act of 1974
The Equal Educational Opportunities Act (EEOA) of 1974 is a federal law of the
United States of America. It prohibits discrimination against faculty, staff, and students,
including racial segregation of students, and requires school districts to take action to
overcome barriers to students' equal participation.
(http://en.wikipedia.org/wiki/Equal_Educational_Opportunities_Act_of_1974).
Title IX of the Education Amendments of 1972
No person in the United States shall, on the basis of sex, be excluded from
participation in, be denied the benefits of, or be subjected to discrimination under any
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education program or activity receiving federal financial assistance...
(http://en.wikipedia.org/wiki/Title_IX).
Several Federal laws protect individuals with disabilities. They are as follows.
Section 504 of the Rehabilitation Act of 1973
Education for all Handicapped Children Act, Public Law 94-142 of 1975, later renamed
Individuals with Disabilities Education Act (IDEA) of 1990
Americans with Disabilities Act (ADA) of 1990
Legal Tests for “Classification” Cases
Three levels of scrutiny are applied to classification cases. The level of scrutiny depends
on how our society has historically treated a class of individuals. The levels of scrutiny
are: Strict, Intermediate, and Rational. A fourth level of scrutiny “Disparate Impact” may be
implemented if the classification is not specified (Hillman and Trevaskis, 2014).
Strict Scrutiny
Strict Scrutiny is the highest form of scrutiny. If a fundamental right has been violated,
and there has been a history of this group’s rights being violated, they are deemed a “suspect”
class. In order for the government to overcome a case concerning the separation of a “suspect”
class, it must prove a “compelling interest”, and it needs to be “narrowly tailored”. Suspect
classes currently acknowledged by the government are: race, national origin and alienage.
In the case of Ricci v. DeStefano, 557 U.S. (2009) the United States Supreme Court
applied strict scrutiny. This case involved race (white firefighters) who claimed discrimination
because test results used to guide promotion decisions were thrown out due to a disproportionate
number of white firefighters passing the test compared to those of color. The Supreme Court
ruled that this action was in violation of Title VII. The legal test requires that the government
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show a “compelling governmental interest to use such a classification system, and it needs to be
narrowly defined” (Hillman and Trevaskis, 2014, p. 4-2). Because the test used to guide
promotion decisions was otherwise valid, the government failed the legal test.
If a class does not hold the designation of being “suspect” there are six rules used to
determine if Strict Scrutiny should be applied. The first five are required:
1.
represents a discrete and insular minority;
2.
evokes stereotypes that carry the stigma of inferiority;
3.
has conditions that are immutable;
4.
has been subjected to a history of purposefully unequal treatment;
5.
is in a position of political powerlessness; and
6.
is saddled with physical, mental or emotional disabilities
(Hillman and Trevaskis, p. 4-3)
Although members of the LGBTQ group have asked to be labeled as a “suspect” class,
giving them the right to have discrimination cases considered under “strict Scrutiny”, thus far
the only groups considered to be “suspect” by the Supreme Court are: race, alienage and
national origin (Hillman and Trevaskis, 2014).
Intermediate Scrutiny
Intermediate Scrutiny is called for when the most rigorous (Strict Scrutiny) is too
stringent, and the least rigorous (Rational Scrutiny) is not stringent enough. “This test is
generally applied in cases where a whole group is being totally excluded or where illegitimacy or
gender issues are present. The test here is that the governmental action must be substantially
related to advancing significant governmental objectives and the classification must be necessary,
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not merely convenient, for the government to win its’ case and maintain whatever it is doing.”
(Hillman and Trevaskis, 2014, p. 4-4).
Rational Scrutiny
Rational Scrutiny is the least rigorous type of scrutiny involving class. This is the level of
scrutiny used if a classification does not meet strict scrutiny. It dictates that the government show
a rational purpose for its’ actions, related to the goals of those actions. The government will be
allowed to discriminate but only if it has a legitimate and fair reason for doing so. This is usually
easy for the government to pass.
Disparate Impact
A fourth type of scrutiny may be used if a classification is not designated. This type of
scrutiny is used if the government action is seemingly neutral, however due to the government
action, there is a disparate impact on a group. The plaintiff must prove that there was intent to
discriminate. Because intent to discriminate is difficult to prove, few cases are won based on this
level of scrutiny.
Mark which type of case this is:
XXX Strict Scrutiny
 Intermediate Scrutiny
 Rational Basis
 Disparate Impact
Criteria Analysis for Strict Scrutiny
As stated above, Strict Scrutiny is the highest form of scrutiny. If a fundamental right
has been violated, and there has been a history of this group’s rights being violated, they are
deemed a “suspect” class. In order for the government to overcome a case concerning the
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separation of a “suspect” class, it must prove a “compelling interest”, and it needs to be
“narrowly tailored”. Suspect classes currently acknowledged by the government are: race,
national origin and alienage.
This case involves race, specifically the assignment of school officers by percentages
matching those of the racial make up of the school population. It also involves the potential
violation of a fundamental right, the right to hold office. Due to the fact that this case involves a
“suspect class” of which a fundamental right may be violated, it meets the qualifications needed
to be reviewed under “strict scrutiny”.
“Lawyers will use both specific laws and the Fourteenth Amendment when bringing
actions that deal with student classification” (Hillman and Trevaskis, 2014, p. 4-2).
Lawyer for the Parent on Behalf of the Nettleton School District Student (Plaintiffs)
Strict Scrutiny
The lawyer for the plaintiff would argue that this case should be reviewed under strict
scrutiny due the fact that it violates a fundamental right of a student of a mixed race.
The lawyer for the plaintiff would cite The United States Supreme Court decision in
Fisher v. University of Texas at Austin, 570 U.S.
(2013). The Court ruled 7-1 that race
could be considered in undergraduate admissions but that strict scrutiny must be applied.
The lawyer for the plaintiff will cite the case of Lewis v. Ascension Parish School Board
in which the Fifth Circuit Court of Appeals found that with a race-neutral plan for student
assignment, if that action has a “disproportionately adverse effect” that “can be traced to a
discriminatory purpose” then strict scrutiny should be applied (Hillman and Trevaskis, 2014).
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The lawyer will further argue the appropriateness of the application of strict scrutiny
based on the fact that the government had no “compelling” reason to institute an amendment to
their policy to include representation that reflects the racial mix of the student body.
The recent percentages reflecting the racial mix of the student body represent segregation
that has been established by de facto and thus not unconstitutional. No remedy is required.
Therefore selection for school offices should now be based on criteria that are primarily other
than race related. The 30-year-old school policy should instead have been dropped. As
Superintendent Russell Taylor stated when referring to the policy "It is our hope and desire that
these practices and procedures are no longer needed."
The lawyer for the plaintiff would cite the case of Pasadena City Board of Education v.
Spangler, 427 U.S. 424 (1976): “Once unitary status is achieved in a former de jure district, and
no continuing constitutional violation exists, the district is not responsible for correcting any
future racial imbalance that it did not intentionally cause” (Hillman and Trevaskis, 2014, p. 4-8).
This is further evidence that the school did not have a “compelling” purpose for maintaining a
school policy based on race.
14th Amendment
The lawyer for the plaintiff would argue that the Mississippi School district’s policy is
unconstitutional due to the fact that it violates the student’s 14th amendment rights. As Section 1
of the 14th Amendment states
“…No State shall make or enforce any law which shall abridge the privileges or
immunities of citizens of the United States… nor deny to any person within its
jurisdiction the equal protection of the laws”
(http://www.law.cornell.edu/constitution/amendmentxiv).
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This ensures equal treatment for all students regardless of their classification.
The Nettleton school policy addresses the African American populations, as well as the
White populations of the school. It does not however address students of mixed race, which
results in discrimination against the plaintiff by negating the possibility of her holding a school
office. The court would question where a student of mixed race would be placed when filling the
quota for school officers, since there is no category for a student of mixed race within the school
district’s quota system.
“The parent, Brandy Springer, stressed that even if the rule is an attempt to ensure black
and white participation, diversity is no longer a black and white issue, with a growing number of
mixed-race children, Hispanics and other ethnicities attending school together. The school
agreed, saying that it "acknowledges and embraces the fact that we are growing in ethnic
diversity and that the classifications of Caucasian and African-American no longer reflect our
entire student body."”
The lawyer for the plaintiff would cite cases whereby “quota” systems such as the
directive in the Nettleton school district policy, were deemed unlawful. In the case of Regents of
Univ. of California v. Bakke, 438 U.S. 265 (1978), Justice Lewis Powell stated that although race
could be considered because diversity in the student body represented a compelling government
interest, the quota system was unlawful (Hillman and Trevaskis, 2014). In the case of Gratz v.
Bollinger, 539 U.S. 244 (2003), the University of Michigan’s undergraduate admissions plan was
“struck down” because it mirrored a quota system. This is in contrary to the case of Grutter v.
Bollinger, 539 U.S. 306 (2003) where “the University of Michigan Law School’s admissions
program that used race to achieve a critical mass of underrepresented groups was upheld since the
review was an individualized, holistic review of student applications and was narrowly tailored to
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meet a compelling governmental interest of promoting a diverse student body” (Hillman and
Trevaskis, 2014). However, this is not the case in the Nettleton school district. There is no
evidence of a “holistic” review of students. There is simply a stated policy of admittance by
percentage based on race.
Title VI
The lawyer for the plaintiff would argue that the school district is also in violation of
Title VI.
“No person in the United States shall, on the ground of race, color, or national
origin, be excluded from participation in, be denied the benefits of, or be subjected to
discrimination under any program or activity receiving Federal financial assistance”
(http://www2.ed.gov/about/offices/list/ocr/docs/hq43e4.html).
Rare is the school that does receive federal assistance. Therefore Title VI would apply to the
Nettleton School District. The quota system that the school district has developed discriminates
based on race, as it is apparently using race as a major factor in filling the positions of school
officers. Even if “mixed races” were addressed in the quota system, the fact that the student
body is primarily white, and race is a primary consideration for holding an office, students who
are not white, but who may be more qualified to hold an office, will be disqualified in favor of
fulfilling the higher white percentage of students. This results in exclusion from participation, as
well as the subjection of discrimination for the plaintiff.
The Equal Educational Opportunities Act (EEOA) of 1974
The lawyer for the plaintiff would argue that the school district is in violation of The
Equal Educational Opportunities Act (EEOA) of 1974. This act “prohibits discrimination
against…students, including racial segregation of students, and requires school districts to take
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action to overcome barriers to students' equal participation.”
(http://en.wikipedia.org/wiki/Equal_Educational_Opportunities_Act_of_1974). By using the
school policy quota system as part of the selection process for school officers, the Nettleton
school district is not only in violation of The Equal Educational Opportunities Act through
discrimination, but is also racially segregating students by implementing policy that requires
admission to school government be decided by race, and not by race neutral criteria. The lawyer
would cite the cases of: Parents Involved in Community Schools v. Seattle School District No. 1,
551 U.S. 701 (2007) and Meredith v. Jefferson County Board of Education, 551 U.S.
(2007): whereby the districts’ use of race was used as the primary factor in placing students and
deemed unconstitutional since a segregation order did not exist.
Lawyer for Nettleton School District (Defendants)
Strict Scrutiny
The lawyer for the Nettleton School District would agree that this case fits the criteria
required to be tried under strict scrutiny. This case involves race and discrimination. The
Supreme Court holds that “all racial classification imposed by the government must be analyzed
by a reviewing court under strict scrutiny (Grutter v Bolinger, 539 U.S. 306, 326, 123S. Ct. 2325,
2337 (2003)).
However the lawyer for the defendant would further argue that in this case the
government has a “compelling governmental reason for using their classification system”
(Hillman and Trevaskis, 2014, p. 4-2). Nettleton school district amended their policy for
reserving class officer positions to reflect the racial mix of the student body in order to protect the
rights of students such as the plaintiff. As Superintendent Russell Taylor stated, "It is the belief
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of the current administration that these procedures were implemented to help ensure minority
representation and involvement in the student body,"
The lawyer for the defendant would, as did the lawyer for the plaintiff, acknowledge the
case of Pasadena City Board of Education v. Spangler, 427 U.S. 424 (1976): “Once unitary
status is achieved in a former de jure district, and no continuing constitutional violation exists, the
district is not responsible for correcting any future racial imbalance that it did not intentionally
cause” (Hillman and Trevaskis, 2014, p. 4-8). Because the school district is not by law
responsible for correcting a racial imbalance that it did not intentionally cause, it is obvious that
the district is going above and beyond its’ obligation to its’ student body in protecting their
rights, and has a “compelling interest” in doing so. In the case of Regents of Univ. of California
v. Bakke, 438 U.S. 265 (1978), Justice Lewis Powell stated that race could be considered because
diversity in the student body represented a compelling government interest. (Hillman and
Trevaskis, 2014).
14th Amendment
The Lawyer for the Nettleton District would deny violation of the plaintiff’s 14th
Amendment rights. By maintaining policy that requires race be considered as a criteria for
student selection for class offices, the district is ensuring that the students’ rights are upheld, and
that the student is receiving equal protection under the law. The lawyer would again cite the case
of Regents of Univ. of California v. Bakke, 438 U.S. 265 (1978), which allowed that race could be
considered because diversity in the student body represented a compelling government interest
(Hillman and Trevaskis, 2014). The lawyer would also address the plaintiff’s acknowledgement
of Gratz v. Bollinger, 539 U.S. 244 (2003), where the University of Michigan’s undergraduate
admissions plan was “struck down” because it mirrored a quota system. The lawyer for the
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defendant would claim that the process used by Nettleton School district ensures equality by
reflecting the racial make up of the student body in the enrollment for class offices. This is very
different from setting a quota for a number of students admitted by race. The defendant would
also work to clarify how a student of mixed race would “fit” into the school’s classification
system.
Title VI
The Lawyer for the Nettleton District would deny violation of the plaintiff’s rights
according to Title VI. The school district, through their policy, is in fact working to alleviate
discrimination by ensuring that students have equal rights for participation in school government.
Although the school district is not required by law to maintain a system that provides ongoing
assurance of equality, it goes above and beyond the call of duty in doing so, in order to protect
the rights of all students. The actions of the school system ensure rather than deny inclusion in
school government.
The Equal Education Opportunities Act (EEOA) of 1974
The Lawyer for the Nettleton District would deny violation of the plaintiff’s rights
according to the Equal Education Opportunities Act (EEOA) of 1974. The lawyer for the
defendant would instead argue that the school is complying with this act by purposefully
implementing policy that prohibits discrimination, including the segregation of students.
Through the implementation of policy which ensures equal participation as part of the selection
process for school officers, the Nettleton school district is working to “overcome the barriers” as
stated in the law. The policy can be seen as being “race-neutral” as it impacts everyone in the
student body in the same way. The lawyer for the defendant would address, as did the plaintiffs,
the cases of: Parents Involved in Community Schools v. Seattle School District No. 1, 551 U.S.
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701 (2007) and Meredith v. Jefferson County Board of Education, 551 U.S.
(2007): by
stating that race was a consideration only in so much as assurance that representation in student
government reflected the make up of the student body.
Your overall assessment—Who will win the case, do you believe?
I believe that the plaintiff will win the case. Two factors are predominant in my thinking. First
the school policy addresses African Americans and Whites, and does not seem to include
students of a mixed race. Second no other criteria for admission appears to be present. I may
live in a naïve world of color blindness, and admittedly the part of the world that I live in is not
racially diverse, however I respectfully and humbly disagree with Justice Sonia Sotomayor’s
response to Chief Justice John Roberts’ statement (Hillman and Trevaskis, p. 4-9). I think that the
world needs a colorblind approach. I would like to think (and as I stated maybe naively) that we
have somewhat moved forward as an educated society beyond anything but criteria that includes
character and education among other non-racially, non-sexually associated attributes.
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REFERENCES
Brown v. Board of Education of Topeka - 347 U.S. 483 (1954).
http://supreme.justia.com/cases/federal/us/347/483/case.html
Dred Scott's fight for freedom. Retrieved from http://www.pbs.org/wgbh/aia/part4/4p2932.html
Education and Title VI. Retrieved from
http://www2.ed.gov/about/offices/list/ocr/docs/hq43e4.html
Equal Educational Opportunities Act of 1974. Retrieved from
http://en.wikipedia.org/wiki/Equal_Educational_Opportunities_Act_of_1974
First Amendment. Retrieved from http://www.law.cornell.edu/constitution/first_amendment
Fisher v. Univ. of Tex. at Austin, 133 S. Ct. 2411, 186 L. Ed. 2d 4, 118 FEP Cases
1459 (2013) [2013 BL 167358]. Retrieved from
http://www2.bloomberglaw.com/public/desktop/document/Fisher_v_Univ_of_Tex
_at_Austin_No_11345_2013_BL_167358_118_FEP_Ca
Fourteenth Amendment. Retrieved from http://www.law.cornell.edu/constitution/amendmentxiv
Gratz v. Bollinger - 539 U.S. 244 (2003). Retrieved from
http://supreme.justia.com/cases/federal/us/539/244/case.html
Grutter v. Bollinger, 539 U.S. 306 (2003). Retrieved from
http://supreme.justia.com/cases/federal/us/539/306/case.html
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Lewis v. Ascension Parish School Board. Retrieved from
http://www.ca5.uscourts.gov/opinions/pub/09/09-30971-CV0.wpd.pdf
Overview of Title VII of the Civil Rights Act of 1964. Retrieved from
http://www.aauw.org/resource/title-vii-of-the-civil-rights-act-of-1964/
Parents Involved In Community Schools v. Seattle School District NO. 1. Retrieved from
http://www.law.cornell.edu/supct/html/05-908.ZS.html
Pasadena City Bd. of Educ. v. Spangler - 427 U.S. 424 (1976). Retrieved from
http://supreme.justia.com/cases/federal/us/427/424/case.html
Plessy v. Ferguson - 163 U.S. 537 (1896). Retrieved from
http://supreme.justia.com/cases/federal/us/163/537/case.html
Regents of Univ. of California v. Bakke - 438 U.S. 265 (1978). Retrieved from
http://supreme.justia.com/cases/federal/us/438/265/case.html
Title IX. Retrieved from http://en.wikipedia.org/wiki/Title_IX
Hillman, S., & Trevaskis, D. (2014). school law: Legal framework, guiding principles, and
litigated areas. Pennsylvania Council for the Social Studies. Retrieved from
http://pcssonline.org/products-page/textbooks/digital-book
Statement of Academic Honesty: I have read and understand that plagiarism policy as
outlined in the “Student Plagiarism and Academic Misconduct” document relating to
the Honesty/Cheating Policy. By attaching this statement to the title page of my paper, I
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and to the MSED program. If it is found that cheating and/or plagiarism did take place
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