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Student barred from passing out religious flyers questioning evolution and promoting creationism to classmates at school files suit against California district

KXTV News 10 reports that Pacific Justice Institute (PJI), a legal advocacy group that defends individuals’ religious liberties, has filed suit against Loomis Union School District (LUSD) on behalf of a student at Loomis Basin Charter School who was prohibited from passing out flyers questioning the teaching of evolution in public schools to classmates during lunch. The flyers came from Genesis Apologetics, which offers seminars to parents and students on “Biblical Creation.”

The unidentified sixth grader asserts that the teaching of evolution in her science class is contrary to her religious beliefs. When she was discovered distributing the flyers, she claims that she was reprimanded by school officials and prohibited from passing out religious flyers without approval.

According to Kevin Snider, PJI’s chief counsel, “She’s not seeking the school to pass these out to everyone. She’s passing them out on her own to individuals.”  Snider added, “They want students to present literature to the school for preview and for the school to fix disclaimer. We say that’s not what the constitution provides for.”

In responding to the suit, LUSD’s superintendent issued a statement that reads in part: “Loomis Union School District respects and values freedom of speech among students, including their right to discuss their religious beliefs with classmates. What’s at issue in this case is whether the district’s policy regarding student-distribution of promotional materials is enforceable under state law.”

LUSD policy mandates  that all materials must be submitted to the school before being passed out by a student. If they meet the distribution standard, they must have a disclaimer making it clear that the materials are not endorsed by the district.

Source: KXTV News 10, 11/18/14, By Carlos Saucedo

[Editor's Note: On November 17, 2014, Valerie Strauss of the Washington Post reported that Orange County School Board (FL) is considering changing its materials distribution policy, which currently allows religious groups to distribute religious material, such as Bibles, at public high schools. The impetus for the change is that a group known as The Satanic Temple (ST), recently announced that they wanted to disseminate material on the “philosophy and practice of Satanism.”

ST's demand came after atheists had secured the right to counter the distribution of Bibles. The board will vote in the next few months on whether to alter or eliminate the policy. The Post article observes, "Perhaps ironically, the Satanic Temple will applaud if religious materials are banned because it believes strongly in the separation of church and state." 

Available on NSBA's website is a chart on distribution of religious materials that provides a compilation of federal court decisions regarding in-school distribution of religious materials and other materials from non-school entities.] 

New Jersey court hears arguments on district’s request to dismiss suit over daily recitation of Pledge of Allegiance in school

USA Today reports that Monmouth County Superior Court Judge David Bauman heard oral arguments on Matawan-Aberdeen Regional School District’s (MARSD) motion to dismiss a suit by the American Humanist Association (AHA) on behalf of a Monmouth County family challenging the inclusion of the phrase “under God” in the daily classroom recitation of the Pledge of Allegiance. AHA’s suit claims that the practice of acknowledging God in the Pledge of Allegiance discriminates against atheists, in violation of the New Jersey Constitution.

The Knights of Columbus, the American Legion, and the Becket Fund intervened in the suit in support of MARSD. Attorney David B. Rubin is representing the school district.

Rubin argued that the suit should be dismissed on several grounds, the first of which is that even though New Jersey law requires the daily recitation of the Pledge in all state schools, individual students are not required to participate. Because participation in the Pledge is voluntary, Rubin contends that the plaintiff’s claim of a civil rights violation is unfounded as there is no differential treatment of anyone by the government. “There’s not been a requirement or a prohibition from doing anything,”he said.

AHA’s attorney David Niose countered that even though students are not required to participate in the Pledge, inclusion of the words “under God” makes it divisive. “It paints one group as quintessential patriots and the other group as second-class citizens,” he said. Niose said that the Pledge differs from other school activities that some might find objectionable in that it is an exercise that is performed daily from pre-kindergarten through 12th grade.

Earlier this year, Massachusetts’ highest court ruled that daily recitation of the Pledge in school, including the phrase “under God,” did not violate that state’s laws or constitution. Niose insisted to Judge Bauman that the Massachusetts court was “simply wrong.”

Rubin, on the other hand, indicated that federal courts have not recognized the Pledge of Allegiance as a religious exercise, even though a reference to God is in it. “It’s simply a recognition of the undeniable, historical fact that religion played an important role in the formation of this country and the development of our government institutions,” Rubin said.

Source: USA Today, 11/19/14, By Kathleen Hopkins (Ashbury Park Press)

[Editor's Note: Mr.  Rubin is a member of the National School Boards Association's Council of School Attorneys (COSA). 

In August 2014, Legal Clips summarized an article in The Daily Journal reporting that a number of  patriotic and religious organizations had come to the defense of MARSD against AHA's lawsuit. The lawsuit was filed by AHA in March 2014 on behalf of  a family that wishes to remain unidentified. The suit claims that the practice of acknowledging God in the Pledge discriminates against atheists, in violation of the New Jersey Constitution.]


University Education Law Practicum files discrimination complaint against Tennessee school district with OCR

The University of Tennessee College of Law Education Law Practicum (UTCLELP) has filed a complaint with the U.S. Department of Education’s (ED) Office for Civil Rights (OCR), says WBIR.com. The complaint alleges discrimination against African American students and students with disabilities by Knox County Schools. The complaint cites data from 2012 showing that African American students are almost three times more likely to be suspended and more than 4.5 times more likely to be referred to law enforcement than their Caucasian peers.

The complaint also states that African American students with disabilities are more than six times more likely to be referred to law enforcement than Caucasian students with disabilities. In addition, it claims harsh discipline pushes students out of the educational system and often into the criminal justice system. The article notes that there have been similar complaints filed across the country, demanding that the federal government investigate school systems and enact change.

Source: WBIR.com, 11/18/14, By Staff

[Editor's Note: UTCLELP's OCR complaint form contains an attachment titled "Analyses of Disparate School Discipline and School-Based Arrests  Practices in Knox County, Tennessee." The attachment provides an analysis of ED's Civil Rights Data Collection (CRDC) and requests a comprehensive investigation by OCR into the practices described and appropriate relief to dismantle these practices.

In July 2014, Legal Clips summarized an article in The Advertiser reporting that OCR was looking into a complaint regarding discrimination against African-American students by Lafayette Parish School System (LPSS).  An OCR spokesman said, “The case focuses on whether the district discriminated against black students on the basis of race with respect to discipline practices.” ]

Fifth Circuit refuses to rehear suit over University of Texas’ use of race as a factor in its undergraduate admissions policy

According to The Texas Tribune, the full U.S. Court of Appeals for the Fifth Circuit has declined Abigail Fisher’s request to rehear her suit against the University of Texas at Austin (UT) over its use of race as a factor in the student admissions policy for applicants not admitted under the state’s top 10% law. The denial in effect upholds the July 2014 decision by a Fifth Circuit three-judge panel, which indicates that the policy passed constitutional muster. The case could now be headed back to the U.S. Supreme Court.  

Fisher, who is white, filed suit after her application for admission to UT was rejected in 2008. The case went all the way to the U.S. Supreme Court, which remanded it back to the Fifth Circuit on the grounds that the judges, in siding with the university, had not applied “strict scrutiny” and had been too inclined to take the university representatives at their word when they said that the consideration of race was a necessary component of the review process that helped the institution meet its diversity goals.

In July 2014, the Fifth Circuit, in a 2-1 decision, again upheld the use of race as a factor in UT’s admissions policy. Fisher then petitioned the Fifth Circuit to rehear the case en banc, which means with the entire court present as opposed to a three-judge panel. However, the full court, in a 10-5 vote, rejected the petition.

Fisher and her attorneys indicated that they intend to appeal to the U.S. Supreme Court. “Abby Fisher and her family are disappointed with the court’s denials for a rehearing, but remember that they have been in this posture before. This case will be appealed back to the U.S. Supreme Court,”  Edward Blum, director of the Project on Fair Representation, a legal defense foundation that has represented Fisher, said in a statement.

UT President Bill Powers said he was pleased with the ruling. The university, he said, “is committed to maintaining a student body that provides the educational benefits of diversity while respecting the rights of all students.”

Source: The Texas Tribune, 11/12/14, By Reeve Hamilton

[Editor's Note: In July 2014, Legal Clips summarized the Fifth Circuit's panel decision in the remand of  Fisher v. UT. The panel ruled that the undergraduate admissions policy of UT does not violate the Fourteenth Amendment’s Equal Protection Clause. Following the U.S. Supreme Court’s instructions, it subjected UT’s admissions policy to a rigorous “strict scrutiny” analysis. It concluded that to “deny UT Austin its limited use of race in its search for holistic diversity would hobble the richness of the educational experience in contradiction of the plain teachings of Bakke and Grutter.” It found that UT’s “holistic review”, in which race is considered as one of a number of factors, “is a necessary complement to the Top Ten Percent Plan, enabling it to operate without reducing itself to a cover for a quota system; that in doing so, its limited use of race is narrowly tailored to this role — as small a part as possible for the Plan to succeed.” ]


Maryland district deletes names of religious holidays from next year’s school calendar

The Washington Post reports that the Montgomery County Board of Education (MCBOE) has voted to eliminate the names of all religious holidays, including Christmas, Easter, Yom Kippur, and Rosh Hashanah, from the school district’s published calendar for 2015-16. The MCBOE’s 7-1 vote to remove religious holidays came in the aftermath of a request from Muslim community leaders to give equal billing to the Muslim holy day of Eid al-Adha.

Montgomery County Schools will still be closed for the Christian and Jewish holidays, as in previous years, and students will still get the same days off. The new calendar will now just reflect days the state requires the system to be closed and other days where there has historically been a high rate of absenteeism for students and staff.

Even though those days happen to coincide with major Christian and Jewish holidays, board members noted that the days are not intended to be celebrations of religious holidays, which they acknowledged that they are not legally permitted to observe.

Source: The Washington Post,  11/11/14, By Donna St. George

[Editor's Note: In October 2013, Legal Clips summarized an article in The Washington Post reporting that Muslim families in Montgomery County, Maryland were pressing the school district to close in recognition of the Islamic holy day Eid al-Adha. They pointed out that schools in the district are closed for Christmas, Good Friday, Easter, Rosh Hashanah, and Yom Kippur.

County school officials said that, legally, granting a day off requires a secular rationale, such as an impact on instruction because of a high rate of absenteeism. In 2012, the school board asked staff to examine attendance patterns on the Muslim holiday. According to officials, figures from a three year period of time indicated that Muslim holidays had little impact on attendance.

School officials did note that the district provides excused absences to students who miss classes on religious holidays.]  


South Carolina Supreme Court rules that the state’s system for funding public schools fails to satisfy the constitutional obligation for the state to provide students with “the opportunity to receive a minimally adequate education”

Abbeville Cnty. Sch. Dist. v. State of South Carolina, No. 07-065159 (S.C. Nov. 12, 2014)

Summary of Majority Opinion: The South Carolina Supreme Court, in a 3-2 split, has ruled that the state’s funding scheme for public schools does not satisfy the South Carolina Constitution’s mandate that the state provide “a system of free public schools that affords each student the opportunity to receive a minimally adequate education.” Even though the majority conceded it could not “suggest methods of fixing” the problem of inadequate education, it “can recognize a constitutional violation when [it] see[s] one.”

One of the key factors for the majority in deciding the case is the effect of poverty on student achievement. Invoking the rationale of the U.S. Supreme Court in Brown v. Board. of Education 349 U.S. 294 (1955),  the majority said, “Students in [the plaintiffs'] districts are grouped by economic class into what amounts to no more than educational ghettos, rated by the Department of Education’s guidelines as substandard.”

The majority rejected the state’s argument that the case was moot because of substantial changes to relevant facts and the law since the supreme court heard arguments in the case. It also disagreed with the dissent’s contention that the case was not justiciable because it involves an apolitical question.

With regard to the remedy for the constitutional violation, the majority declined, based on the principle of separation of powers, to provide the state legislature with a specific solution. However, it pointed to decisions from a number of other jurisdictions, e.g., New York state and Wyoming. In conclusion, it ordered  the plaintiffs and defendants to work together and return to the court, within a reasonable period of time, with a plan to address the constitutional violation that the court found, with special emphasis on the statutory and administrative pieces necessary to aid the myriad troubles facing these districts at both state and local levels.

Summary of Dissenting Opinion: Although the dissent believed that the initial school funding suit, known as Abbeville I, should be disposed of on the ground that it raised a nonjusticiable political question, it acknowledged that the South Carolina Supreme Court was obliged to resolve the case on the issue of whether the state’s funding scheme provided a “minimally adequate education.” It concluded that the trial court should have ruled that there was no constitutional violation with regard to inadequate funding of pre-school and early childhood education programs.

According to the dissent, “The proper question before the Court in Abbeville I was which branch of government is constitutionally assigned responsibility for funding and making policy decisions concerning public education. It responded, based on its reading of the relevant state constitutional provision, that the South Carolina Supreme Court’s “construction of the Education Clause in Abbeville I to require a minimally adequate education, while well intentioned, does not give rise to a legal issue that this Court is capable of resolving.”

Abbeville Cnty. Sch. Dist. v. State of South Carolina, No. 07-065159 (S.C. Nov. 12, 2014)

[Editor's Note: On November 13, 2014, Sarah Freishtat and Kirk Brown of The State reported on the decision in Abbeville County School District, which they pointed out had been litigated for 21 years. According to the article, several Republican lawmakers said they were disappointed in the ruling, while the state Democratic Party issued a statement applauding the ruling.

State Sen. Larry Martin, the Republican chairman of the Senate Judiciary Committee, said the case is "clearly a public policy issue," not a constitutional issue. He said legislators have created kindergarten programs for 4-year-olds in about two-thirds of the state's school districts. 

The South Carolina School Boards Association is finalizing a proposed school funding plan, said Scott Price, who will be the next executive director of the South Carolina School Boards Association, in a statement. He said the plan allocates funding for students based on their needs, rather than where they live.

In September 2012, Legal Clips summarized an article in The State reporting that  the five justices of the South Carolina Supreme Court had recently heard oral arguments addressing several issues, including teacher quality, school district sizes, school bus numbers, the percentage of a district’s budget that goes to administrators’ salaries, and contemplated whether the court should set its own standards for the state’s public education system. The oral arguments were the latest chapter in a 20-year lawsuit brought by some of the state’s poorest school districts.  The Editor's Note to the article indicated that the case was back on track after a four year silence by the South Carolina Supreme Court after hearing oral arguments in 2008.

The National School Boards Association, along with a number of other education groups, filed an amicus brief in support of the school districts.] 


Suit charges Pennsylvania’s system of funding schools is unconstitutional

The Philadelphia Magazine reports that a coalition of six school districts, the Pennsylvania chapter of the NAACP, the Pennsylvania Association of Rural and Small Schools and parents have filed suit alleging that the state has “adopted an irrational and inequitable school financing arrangement that drastically underfunds school districts across the Commonwealth and discriminates against children on the basis of the taxable property and household incomes in their districts.” The suit seeks to equalize the wide disparities in per pupil spending between affluent and lower-income districts by increasing state funding to financially strapped districts.

The suit is premised on the state’s constitutional duty to “provide for the maintenance and support of a thorough and efficient system of public education.” It makes the following arguments:

1. The state has the ultimate responsibility for providing an education, and it cannot completely delegate that duty to local school districts.

2. Low income school districts lack the resources to enable their students to meet state mandated standards, such as the Keystone Exams, which are slated to become a graduation requirement for all students beginning in 2017.

3.  By delegating so much of the funding burden to local districts, the state has preordained funding disparities.

4. The difference in funding levels is not tied to the gap in student needs.

5. Low-income communities cannot close the funding disparity on their own.

The coalition believes its suit will succeed, where a similar 1999 suit by the Philadelphia School District failed, because the state has developed a comprehensive school assessment system and a graduation exam. They argue that these new requirements “define precisely what an adequate education entails.”

The coalition also contends that they now know about how much an “adequate” education would cost as the of result of a 2007 costing-out study and that such a study was not available when they filed suit in 1999.

It should be noted that Pennsylvania courts have consistently considered education funding to be the province of the legislature, not the judiciary.

Source: Philadelphia Magazine, 11/10/14, By Patrick Kerkstra

[Editor's Note: The Public Interest Law Center of Philadelphia (PILCP)and the Education Law Center-PA are representing the coalition. The legal complaint, which can be found on PILCP's website, contends that the judicial branch "has the duty to determine whether or not the legislature is supporting a 'thorough and efficient system of public education,'as mandated by the state constitution based on the legislature’s own standards. "

In February 2014, Legal Clips summarized an article in USA Today reporting that litigation is currently pending against 11 states over inadequate or inequitable school funding.  School finance suits are not new, but the plaintiffs’ arguments are changing. Higher state standards lie at the heart of the arguments in many of the recent cases.]

Sua Sponte: OCR issues guidance on ADA Title II “effective communication” regulation’s interplay with IDEA’s FAPE requirement

The U.S. Department of Education’s Office for Civil Rights (OCR) has issued guidance in the form of a “Dear Colleague Letter” (DCL) and attached to it a FAQ sheet on school districts’ legal obligation “to apply both the IDEA analysis and the Title II effective communication analysis in determining how to meet the communication needs of an IDEA‐eligible student with a hearing, vision, or speech disability.” The two page DCL provides a brief overview of the Title II “effective communication” regulation and the FAQs.

The FAQ sheet is a 30 page document that provides OCR’s responses to 20 questions regarding “Effective Communication for Students with Hearing, Vision, or Speech  Disabilities in Public Elementary and Secondary Schools.” The introduction to the FAQs states that the focus of the document is “on the different approaches used by the IDEA on the one hand, and Title II on the other, to determine what a school must do for a student with a hearing, vision, or speech disability.”

Following are a few of the questions asked and the answers provided:

Under Title II, what must public school districts do to provide effective communication to students with hearing, vision, or speech disabilities?

Answer: Title II and its implementing regulations require public school districts to ensure that communication with students with hearing, vision, or speech disabilities is as effective as communication with students without disabilities.

What does it mean for a public school district to give “primary consideration” to the request of the student with a disability when making the decision to provide a particular auxiliary aid or service?

Answer: The Title II regulations require that when a public school is deciding what types of auxiliary aids and services are necessary to ensure effective communication, it must give “primary consideration” to the particular auxiliary aid or service requested by the person with the disability.

What happens if the public school district thinks that providing a particular auxiliary aid or service would result in a fundamental alteration in the nature of a service, program, or activity, or an undue financial and administrative burden?

Answer: A school district must provide a particular auxiliary aid or service that is otherwise required unless the district can prove that such an auxiliary aid or service would result in a fundamental alteration in the nature of the service, program, or activity or in undue financial and administrative burdens.

Although neither the DCL nor FAQ sheet recites the Title II “effective communication” regulation in the text of the documents, the DCL and FAQs cite the regulation, 28 C.F.R. § 35.160, in a footnote. Both documents cite K.M. v. Tustin Unified School District, 725 F.3d 1088 (9th Cir. 2013), cert. denied, 134 S. Ct. 1493 (2014), a Ninth Circuit three-judge panel decision in which the panel held that compliance with the Individuals with Disabilities Education Act (IDEA) does not satisfy all claims under Section 504 of the Rehabilitation Act or under the Americans with Disability Act (ADA).  

Based on that holding, the panel concluded a school district’s provision of an IEP valid under the IDEA does not automatically preclude liability under Section 504 or the ADA. OCR bases it legal conclusion on the holding in Tustin.

The National School Boards Association joined with the California School Boards Association to file an amicus brief in support of the school district’s petition to the U.S. Supreme Court asking it to review the Ninth Circuit panel decision. The CSBA/NSBA’s brief argued that “courts have consistently held that educational decisions for students with disabilities are governed by the provisions of the IDEA and its IEP team process.”

The brief urged the Supreme Court to review the Ninth Circuit panel’s ruling because the panel’s “interpretation of the ADA’s ‘effective communication’ regulation per se fundamentally alters the IDEA’s individualized education program (IEP) process.” However, the Supreme Court rejected the school district’s petition for review.

Colorado district hit with lawsuit over prohibiting student prayer activities during “open periods” in the school day

According to The Gazette, Alliance Defending Freedom (ADF) has filed a federal lawsuit against  Academy School District 20 (ASD20) on behalf of Chase Windebank, a student at Pine Creek High School (PCHS), alleging that PCHS officials are violating the constitutionally guaranteed right to engage in religious speech. Windebank claims that he was told by school officials that he and other students may no longer get together to pray and discuss religious topics during a time known as “seminar.”

The suit states that for the past three years, Windebank has led a group of students who have been praying together during parts of seminar. On September 29, 2014, Assistant Principal Jim Lucas told Windebank that he could no longer hold the prayer meeting. School district officials assert that “the separation of church and state” require a ban on religious speech during open periods when students are free to spend time together.

In October 2014, ADF sent a letter to school district officials asserting the students had earned the privilege of leaving the class during the latter half of seminar on some days. The letter said, “Students use this time for a whole slew of non-school-related purposes … associate with friends outside, in the cafeteria or in other open rooms to discuss virtually unlimited topics, i.e., TV shows, sports teams, upcoming tests, politics.”

The letter pointed out that Windebank’s group had been meeting since his freshman year to sing religious songs and pray until PCHS ended the activity. According to the ADF letter, “At no time during the over three years that Chase has been holding this prayer meeting has there ever been any allegations that the meeting disrupted school activities.”

ASD20′s attorney Patricia Richardson responded to ADF’s assertions via letter. She stated that students can meet at school during “noninstructional time,” meaning time before classroom instruction starts or after it ends and “may include specific activity periods set aside for this purpose.” Her letter also noted that based on ASD20′s administrative policy defining “non-instructional time,” seminar at PCHS “is class time and it is considered instructional time.” The letter emphasized that”[n]o non-curricular clubs are permitted to meet during that time period.”

Richardson’s letter said Windebank can hold prayer meetings before classes begin (7:45 a.m.) and after classes end (2:45 p.m.). Responding to the filing of the lawsuit, ASD20 spokeswoman Nanette Anderson said that despite what the lawsuit claims about the district implementing an “open time” policy, the district has no written or unwritten “open time” policy. “The period of time referenced by the complaint is seminar time, during which students report to an assigned seminar class where attendance is taken,” she said. “This time is counted as academic time toward the minimum hours of instruction that schools are required to provide by state law, and therefore, must be used for academic purposes.”

ADF’s take on seminar strongly diverges from the school district’s view. According to the suit, students use the time to “engage in a virtually unlimited variety of activities, including hanging out in the cafeteria and other open areas with friends, playing on their phones, meeting together for expressive activities (including both formally recognized clubs and unofficial groups) and going outside to hang out together.” ADF’ contends, “The open time is akin to recess or lunch period, where students have long been recognized to have the right to engage in expressive activities.”

ADF’s suit seeks the restoration of praying, singing and discussing topics from a religious perspective during seminar. It also seeks a judgment declaring the prohibition of those activities as unconstitutional, legal fees and $1 for the violation of Windebank’s constitutional rights.

Source: The Gazette, 11/11/14, By Debbie Kelley

[Editor's Note: In ADF's press release announcing filing of the lawsuitADF Senior Legal Counsel Jeremy Tedesco said, “Public schools should encourage the free exchange of ideas. Instead, this school implemented an ill-conceived ban that singles out religious speech for censorship during free time.”  ADF's legal complaint contains six counts: (1) violation of  Windebank's First Amendment free speech rights; (2) violation of his First Amendment right to free association; (3) violation of his First Amendment right to free exercise of religion; (4) violation of his Fourteenth Amendment equal protection rights; (5) violation of his Fourteenth Amendment due process rights; and (6) violation of the First Amendment's Establishment Clause.]






New Jersey district sues copier company claiming it mispresented savings in service contract

The Courier-Post reports that the Monroe Township Board of Education (MTBOE) has filed suit in Gloucester County Superior Court, against Konica Minolta Business Solution, alleging that the company’s misrepresentation of a service contract cost it $50,000.

The suit alleges that a Konica Minolta Business Solution salesman gave a false sales pitch to the school board in July of 2013, claiming that his company could save the district $11,056 a month for the same services provided by Xerox.  Relying on the sales pitch, MTBOE approved a contract with Konica Minolta in a unanimous vote.

According to the suit, despite salesman assurances, the school district discovered it had paid an additional $10,630 a month to Konica “for the same or less copying services” than what was provided by Xerox. The suit states that, “As a result of the defendant’s misrepresentation, the MTBOE has suffered damages in excess of $50,000.”

MTBOE is seeking monetary damages, alleging that Konica engaged in common law fraud, breached its contract with the school district and violated the New Jersey Consumer Fraud Act. The board asserts that the company engaged in an “unconscionable business practice, deception, fraud, falsity and misrepresentation.”

Source: Courier-Post, 11/10/14, By Carly Q. Romalino

[Editor's Note:  For guidance on contracting for goods and services, COSA members can access Forrest Jack Lance's April 2014 School Law Seminar article "Procuring and Contracting for Paper Clips to School Buildings: Lessons Learned."]


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