BOE Special Meeting Minutes - 1.13.22

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COLCHESTER BOARD OF EDUCATION
                                 Colchester, CT


                                  BOARD OF EDUCATION

                                 Thursday, January 13, 2022
                                BOE Special Meeting 5:00pm
                                    Town Hall Room 1

                                          MINUTES

BOARD MEMBERS PRESENT: Chair Alex Oliphant, Vice Chair Mary Tomasi, Secretary
Jessica Morozowich, Donna Antonacci, Margo Gignac, Rosemary Gignac

ADMINISTRATION PRESENT: Superintendent Jeffrey Burt

OTHERS PRESENT: Board Attorney Anne Littlefield

1. CALL TO ORDER
   1.1 Call to Order
       Chair Oliphant called the meeting to order at 5:06PM

2. PUBLIC COMMENT
   2.1 Public Comment
       None.

3. *PRIORITY DISCUSSION/ACTION ITEMS
   3.1 Board Orientation with Attorney Anne Littlefield
       Attorney Littlefield provided an overview of Board member responsibilities and provided
       a handout for review. (see attached)

4. PUBLIC COMMENT
   4.1 Public Comment
       None.

5. ADJOURN
    The meeting adjourned at 7:05PM.
Board Member
Roles and Responsibilities
A Board Member’s Guide to Working With the
Superintendent and Stakeholders
Presented by: Anne H. Littlefield                     January 13, 2022


© Shipman & Goodwin LLP 2022.
                        2021. All rights reserved.   Connecticut
                                                      Connecticut| |New
                                                                     NewYork
                                                                         York| |www.shipmangoodwin.com
                                                                                 Washington, DC | www.shipmangoodwin.com
    Agenda
    Topics to be discussed
                             Board Roles, Rights and Responsibilities

                             Board vs. Superintendent Duties

                             Board Meeting Essentials

                             Freedom of Information – Meetings and Records
                             Electronic Communications

                             Personnel Matters

                             Student Issues


2                             © Shipman & Goodwin LLP 2022. All rights reserved.
Board Roles, Rights
and Responsibilities

© Shipman & Goodwin LLP 2022.
                        2021. All rights reserved.   Connecticut | New York | Washington, DC | www.shipmangoodwin.com
Responsibilities of the Board

               • Agent of the State
               • Policymaker for the district
               • Compare administration responsibility for day-
                 to-day district operations




4              © Shipman & Goodwin LLP 2022. All rights reserved.
Rights of Board Members


                       • Authority at meetings only
                       • Otherwise same rights
                         as other citizens
                       • Role of the committees
                       • Indemnification


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Duties of Board Members



                      • Confidentiality
                                  •      FERPA: Educational need to know




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Duties of Board Members (cont.)
               Impartial Judge
               1. Expulsion hearings
                  (Conn. Gen. Stat. § 10-233d)
               2. School accommodations hearings
                  (Conn. Gen. Stat. § 10-186)
               3. Teacher tenure hearings
                  (Conn. Gen. Stat. § 10-151)



7             © Shipman & Goodwin LLP 2022. All rights reserved.
Duties of Board Members (cont.)


                • Statutory duties, including:
                           • Budget
                           • Policies
                           • Negotiations




8             © Shipman & Goodwin LLP 2022. All rights reserved.
Duties of Board Members (cont.)



                • Conflict of Interest Issues




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Meeting Procedures



                       • Role of Chair
                       • Public Comment




10           © Shipman & Goodwin LLP 2022. All rights reserved.
Code of Conduct for Board Members

     Adhere to all Board policies, rules and regulations;


     Carry out responsibilities in a fair and impartial manner;

     Refrain from interfering with the implementation of a Board policy
     decision by the administration;

     Refrain from interfering with the duties of any school district official; and

     Refrain from divulging to anyone any aspect of matters considered and
     discussed in executive session.
11                      © Shipman & Goodwin LLP 2022. All rights reserved.
Board vs. Superintendent General Duties
                                                                                               Board of
               Superintendent
                                                                                              Education
 • Handles the district’s day-today operations                             • Represents the residents of the Town in carrying
 • Serves as the “face” of the district                                      out legal mandates pertaining to education
 • Typically serves as the district’s spokesperson                         • Determines all questions of general policy to be
 • Supervises district staff                                                 employed in the conduct of the schools. In doing
                                                                             so, it:
                                                                             • Hears and considers facts and recommendations
                                                                             • Adopts plans, policies, and courses of action, and
                                                                             • Authorizes the Superintendent to carry out its
                                                                               policy
                                                                           • Sets the budget
                                                                           • Supervises the Superintendent


12                                      © Shipman & Goodwin LLP 2022. All rights reserved.
Board’s Specific Powers and Duties
A. Create, abolish, modify and maintain such positions, schools, divisions
   and classifications as may be necessary for the efficient administration of
   the educational enterprise
B. To elect a Superintendent of Schools in accordance with state statutes
C. To consider and adopt an annual budget, prepared by the
   Superintendent of Schools
D. To determine the number, classification, duties and remuneration of
   employees
E. To establish policies for employment, promotion and dismissal of
   personnel in accordance with the state statutes

13                        © Shipman & Goodwin LLP 2022. All rights reserved.
Board’s Specific Powers and Duties
F. To provide for the appraisal of the efficiency of personnel
G. To initiate and approve the acquisition and disposition of school
   sites, to initiate and approve plans for school buildings
H. To consider any specific recommendations made by the
   Superintendent of Schools
I. To keep the citizenry informed of purposes, values, conditions and
   needs of public education in the Town
J. To consider, revise and adopt any changes in the curriculum
K. To take any other actions required or permitted by law

14                     © Shipman & Goodwin LLP 2022. All rights reserved.
Board’s Specific Powers and Duties
L. To make reasonable provision to implement the educational interests of
   the State, as defined by law, so that:
     1.   Each child shall have for the period prescribed in the General Statutes equal
          opportunity to receive a suitable program of educational experiences;
     2.   The school district shall finance at a reasonable level an educational program
          designed to achieve this end;
     3.   The school district shall provide educational opportunities for its students to
          interact with students and teachers from other racial, ethnic and economic
          backgrounds;
     4.   The mandates in the General Statutes pertaining to education within the
          jurisdiction of the State Board of Education shall be implemented.


15                               © Shipman & Goodwin LLP 2022. All rights reserved.
Scenario 1
Board member, Mal Content, had been causing issues for the Nutmeg
Board. During meetings he would often verbally attack the motives of
other members and staff, and it was suspected that he leaked
information from an executive session. But the last straw was that he
recently went into each of the schools, during the day, demanding to
be able to visit classrooms to “check on underperforming teachers.” In
a special meeting, where Mal was not in attendance, they voted 8-0 to
oust him from the Nutmeg Board.

                           Is this legal?
16                     © Shipman & Goodwin LLP 2022. All rights reserved.
        Which statement is correct?

A. As an elected member of the Board, Mal was simply
   carrying out his role as a Board member.
B. The Board’s vote to remove the member from the Board
   was invalid since Mal was not in attendance
C. The Board had no authority to remove Mal from the Board.



                    © Shipman & Goodwin LLP 2022. All rights reserved.
  17
Scenario 2
Yesterday, the local newspaper reported that a teacher in the District was
recently arrested on charges of selling narcotics. The article identifies the
teacher by name and school. The article quotes the Superintendent as
confirming that the teacher is on administrative leave with pay, pending
investigation.
During public comment at the next Board meeting, numerous parents
demand that the Board fire the teacher immediately. During the meeting,
one Board member exchanges text messages with several of the parents who
have spoken: “No need to worry. We’ve got this. I can assure you the
teacher is history.”
             Should the Board be concerned
           about the Board member’s actions?
18                       © Shipman & Goodwin LLP 2022. All rights reserved.
Board Meeting Essentials

© Shipman & Goodwin LLP 2022.
                        2021. All rights reserved.   Connecticut | New York | Washington, DC | www.shipmangoodwin.com
FOIA
               •      The Freedom of Information Act (the "FOIA"),
                      (Conn. Gen. Stat. §§ 1-200 through 1-241
                      inclusive),
                      represents Connecticut's commitment to open
                      government and a strong policy in favor of
                      public access to meetings and records.
               •      Subject to narrow exceptions, which are strictly
                      construed, the FOIA mandates that the public
                      has access to:
                                 •      Meetings of public agencies
                                 •      Records that are developed and/or maintained
                                        by public agencies


20     © Shipman & Goodwin LLP 2022. All rights reserved.
“Public Agency” or “Agency”


“    • …Any executive, administrative or legislative office of the state or any
       political subdivision of the state and any state or town agency, any
       department, institution, bureau, board, commission, authority or official of
       the state or of any city,  town, borough, municipal corporation, school
                             Increased
                             Flexibility
       district, regional district  or other district or other political subdivision of
       the state, including any committee of, or created by, any such office,
       subdivision, agency, department, institution, bureau, board, commission,
       authority or official. . . Conn. Gen. Stat. § 1-200.
                                                                                     “
21                             © Shipman & Goodwin LLP 2022. All rights reserved.
“Meeting”
What exactly is a meeting as defined by Freedom of Information Act (FOIA)?




“    • …Any hearing or other proceeding of a public agency, any
       convening or assembly of a quorum of a multimember public
       agency, and any communication
                       Increased
                                         by or to a quorum of a
       multimember public     agency whether in person or by means of
                       Flexibility
       electronic equipment, to discuss or act upon a matter over
       which the public agency has supervision, control jurisdiction
       or advisory power.
                                                                               “
22                        © Shipman & Goodwin LLP 2022. All rights reserved.
Meeting Does NOT Include:
     A meeting of a personnel search committee for an executive level candidate search
     (Board may appoint itself)


     Any chance meeting, or a social meeting neither planned nor intended for the purpose
     of discussing matters relating to official business

     Strategy or negotiations with respect to collective bargaining


     A caucus of members of a single political party notwithstanding that such members
     also constitute a quorum of a public agency


     An administrative or staff meeting of a single-member public agency; and
     communication limited to notice of meetings of any public agency or the agendas thereof

23                            © Shipman & Goodwin LLP 2022. All rights reserved.
Meetings
• In general, there is a meeting anytime a quorum of a public agency
  convenes or engages in interactive communication to discuss or act
  upon a matter for which it has responsibility. There can even be a
  statutory FOIA meeting where it is "anticipated" that a quorum will
  be present.

Note: A quorum of the members of a public agency who are present at any event
which has been noticed and conducted as a meeting of another public agency
under the provisions of the Freedom of Information Act shall not be deemed to be
holding a meeting of the public agency of which they are members as a result of
their presence at such event. Conn. Gen. Stat. § 1-200(2)

24                       © Shipman & Goodwin LLP 2022. All rights reserved.
Meetings
                  • A conference call or other
                    communication by means of
                    electronic equipment may constitute
                    a meeting
                  • Agencies are cautioned to be
                    particularly careful that email
                    exchanges may constitute a meeting
                    for FOIA purposes



25         © Shipman & Goodwin LLP 2022. All rights reserved.
Types of Meetings

                                                            Regular

     All meetings must be
     noticed in advance                                      Special


                                                        Emergency


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Regular Meetings
      Contained on the annual schedule
       of meetings with the Town Clerk                            Agenda must be posted at
     by January 31, for the ensuing year                          least 24 hours in advance
           (Conn. Gen Stat. §1-225(b))



        Minutes must be available
       for public inspection within                            New business may be added to
         seven days of the meeting                             the agenda by a two-thirds vote



27                           © Shipman & Goodwin LLP 2022. All rights reserved.
Special Meetings

      Those meeting not included on                            Notice of a special meeting
         the list of regular meetings                          must be filed at least 24 hours
          filed with the Town Clerk                            before the meeting convenes



      Minutes must be available                             Business limited to items on
     for public inspection within                           posted agenda
       seven days of the meeting                            Items cannot be added to the
                                                            agenda

28                        © Shipman & Goodwin LLP 2022. All rights reserved.
Emergency Meetings
          Emergency special meetings
         may be called in an emergency                                    Limited to the matter that
               without advance notice                                     requires “emergency”
     (Note: “Emergency” will be strictly construed.)                      attention
                      (Conn. Gen Stat. §1-225(a))




            Minutes must include a                                     Minutes must be filed with the
         statement setting forth the                                   Town Clerk(s) within 72 hours
           nature of the emergency                                     of the meeting


29                                   © Shipman & Goodwin LLP 2022. All rights reserved.
Executive Session
Under circumstances narrowly prescribed by the FOIA,
a public agency may exclude the public from a portion
of its meeting by calling an executive session.
Executive sessions, are defined in Conn. Gen. Stat. § 1-
200(6) as follows:




30                  © Shipman & Goodwin LLP 2022. All rights reserved.
Executive Session
• “Executive sessions” means a meeting of a public agency at which
  the public is excluded for one or more of the following purposes:
      Discussion concerning the appointment, employment,
      performance, evaluation, health or dismissal of a public officer or
      employee, provided that such individual may require that
      discussion be held at an open meeting;
      Strategy and negotiations with respect to pending claims or
      pending litigation to which the public agency or a member
      thereof, because of the member’s conduct as a member
      of such agency, is a party until such litigation or claim
      has been finally adjudicated or otherwise settled;


31                          © Shipman & Goodwin LLP 2022. All rights reserved.
Executive Session
• Matters concerning security strategy or the deployment of security
  personnel, or devices affecting public security;
• Discussion of the selection of a site or the lease, sale or purchase of real
  estate by the state or a political subdivision of the state when publicity
  regarding such site, lease, sale, purchase or construction would
  adversely impact the price of such site, lease, sale, purchase or
  construction until such time as all of the property has been acquired or
  all proceedings or transactions concerning same have been
  terminated or abandoned; and
• Discussion of any matter which would result in the
  disclosure of records that are exempt from disclosure
  under Section 1-210(b)

32                           © Shipman & Goodwin LLP 2022. All rights reserved.
Executive Sessions: Requirements
• There are specific requirements for conducting business in
  executive session:
    Two-thirds of those members of the public agency present
     must vote at a public meeting to go into executive session
     and state the reason(s) for such executive session. Conn. Gen.
     Stat. § 1-225(a).
    Only members of the public agency and those persons
     whose presence is necessary to present testimony or give
     opinions may be present during the executive session. Conn.
     Gen. Stat. § 1-231(a).


33                      © Shipman & Goodwin LLP 2022. All rights reserved.
Executive Sessions: Requirements
• Executive sessions may only be called for the limited statutory
  purposes set out above
• Only discussion is permitted in executive session; any votes
  must be taken in open session
      There should not be a vote taken to come out of executive session

• Minutes must include the vote to go into executive
  session; the reason for the executive session; and,
  the names of the persons in attendance at
  the executive session (subject to limited
  exceptions)

34                           © Shipman & Goodwin LLP 2022. All rights reserved.
Executive Session
     Not an agenda item, but a means of dealing with an agenda item


     Not open: specify who is invited into executive session


     Board cannot take action in executive session

     Board members are not to disclose discussion which occurs
     in executive session

     Do not misuse: be respectful of the public when
     scheduling executive sessions
35                     © Shipman & Goodwin LLP 2022. All rights reserved.
Scenario 3: Executive Session
The Nutmeg Board was in a special budget meeting when it learned of
dire economic news that meant significant staffing cuts were
necessary. Knowing that the Board would need to discuss and decide
the elimination of specific positions, and not wishing to needlessly
distress or excite its employees, the Chair added an executive session
item to the agenda to discuss “personnel matters.” With a 5-3 vote, the
Board entered executive session. After an hour of discussion, the
Board members agreed, without a vote, to direct the Superintendent to
cut 10 staff positions.

                       So far, so good?
36                     © Shipman & Goodwin LLP 2022. All rights reserved.
Meeting Requirements
Minutes: Generally, minutes must be available for public inspection within seven
(7) days of session to which they refer, Conn. Gen. Stat. § 1-225(a), and minutes
should include:
                     • When the meeting was convened;
                     • Which members of the public agency were present;
                     • A short description of the business transacted;
                     • A listing of any action taken by the public agency,
                       specifying the votes of each member;
                     • Any executive session held, with a statement of the
                       reason(s) for the executive session and who was in
                       attendance; and
                     • When the meeting was adjourned

37                         © Shipman & Goodwin LLP 2022. All rights reserved.
Meeting Requirements
Agendas: - There is no specific guidance in the FOIA as to the level of detail that is
required in an agenda, but, as a practical matter, the agenda should provide
reasonable notice of the business to be transacted

                       Votes: - The votes (as distinguished from
                       meeting minutes) of all members of the
                       public agency must be reduced to writing
                       and be available for public inspection
                       within 48 hours of the meeting




38                          © Shipman & Goodwin LLP 2022. All rights reserved.
Meeting Procedures
           Boards should adopt formal procedures to
           conduct meetings. Typically Boards utilize
           Robert’s Rules of Order, with specific
           modifications.

           Typical Topics:
           • Date/time of meetings
           • How agendas are created
           • Quorum and voting requirements
39           © Shipman & Goodwin LLP 2022. All rights reserved.
Meeting Procedure: Robert’s Rules of Order
                                                                     One subject
     Key Concepts of                                                 dealt with
        Robert’s                                                      at a time
         Rules:                  Enforce
                                 decorum            Confine debate to the
                                                      merits of a pending
                                                           question
         Allow for the              Recognize and record
     airing of opposite or             a negative vote        Provide
       divergent points                 on a question        for a final
            of view                                           decision

40                       © Shipman & Goodwin LLP 2022. All rights reserved.
 Dealing with Motions


                                                                                                     Once adopted, a
                                                                                  Once question is
                                                                                                     motion becomes
                                                Motion must be                       put before
       Member          Member states                             Chair restates                          officially
                                                 seconded by                       Board, it must
     recognized by      motion for                                motion for                             recorded
                                                   another                         be disposed of
         Chair            Board                                     Board                            statement of an
                                                   member                          before further
                                                                                                       action of the
                                                                                       action
                                                                                                           Board




41
                     © Shipman & Goodwin LLP 2022
Board Member Voting
Members are not required to vote, although Robert’s
Rules anticipates that each member will vote

     Abstentions are not considered as votes for or against
     the motion

          Approval of motions only needs majority of those present
          and voting, unless policy or statute requires otherwise


               The Chairperson can vote and debate on matters before
               the Board in the same manner as the other members

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Board Member Voting

Generally by voice vote or by showing of hands


     Chair announces the result of the vote - vote
     count and whether the vote is
     adopted/defeated

          The minutes must reflect how each board
          member voted

43                    © Shipman & Goodwin LLP 2022. All rights reserved.
Using Robert’s Rules
A tool to allow the Board to accomplish its work


     Robert’s Rules should not get in the way of
     what the Board needs to accomplish

         While members don’t need to be experts, should
         have an understanding of basic concepts

              Robert’s Rules should not be used as a tool to
              disrupt Board business
44                      © Shipman & Goodwin LLP 2022. All rights reserved.
Scenario 4: Who Can Call a Meeting?
Board Member Mal Content has been after the Nutmeg Union of
Teachers for the last two years because they refused to give salary
concessions during these difficult times. He has been asking to put an
item on the agenda for a public meeting, during which the Board
would consider a formal censure of the union and its
membership. You, the Board Chair, have been advised that such a
vote could be problematic. But Mal is persisting, and now he and
two fellow Board members he co-opted are threatening to hold a
public meeting with or without you.

                       Can he do this?
45                     © Shipman & Goodwin LLP 2022. All rights reserved.
Requirements for Calling a Meeting
• Conn. Gen. Stat. Section 10-218 provides in relevant part:
    The chairperson of the board of education or, in case of such chairperson's
     absence or inability to act, the secretary shall call a meeting of the board at
     least once in six months and whenever such chairperson deems it necessary
     or is requested in writing so to do by three of its members. If no meeting is
     called within fourteen days after such a request has been made, one may be
     called by any three members by giving the usual written notice to the other
     members.




46                          © Shipman & Goodwin LLP 2022. All rights reserved.
Scenario 5: Board Member Conduct
Board Member Mal Content, had been causing issues for the Nutmeg
Board. He would often visit school buildings unannounced,
demanding to be able to visit classrooms to “check on
underperforming teachers.” But the last straw for the Board was when
he voted to approve the new teachers’ contract, even though his wife
was a teacher in the district. In a special meeting, where Mal was not
in attendance, they voted 8-0 to oust him from the Nutmeg Board.

                                      Valid?

47                     © Shipman & Goodwin LLP 2022. All rights reserved.
Board Member Conduct
                  • Board members cannot be removed from
                    their elected position on the Board by a
                    vote of the Board
                  • Board officers can be removed from their
                    office by a vote of the Board
                  • The Board can vote to “censure” a Board
                    member



48          © Shipman & Goodwin LLP 2022. All rights reserved.
Conflict of Interest
• Board members cannot be employed by the school district
• No statutory provision against a relative being employed by the
  school district
• Board member actions may be governed by Board policies or ethics
  provision in local charter
• Board members may need to recuse themselves from impartial BOE
  hearings


49                     © Shipman & Goodwin LLP 2022. All rights reserved.
Scenario 6: Board Member Conduct
Board member, Pamela Parent, has concerns that her child is being
bullied at Charter Oak Elementary School. She visits her daughter’s
school unannounced, demanding to be able to visit her daughter’s
classroom, cafeteria and playground to “check on schoolyard bullies.”
She regularly refers to the specific observations she has made in her
public statements made to the Board as part of Board discussions of
school climate.

                               Concerns?

50                     © Shipman & Goodwin LLP 2022. All rights reserved.
Scenario 7: Board Member Conduct
Concerned that her daughter may have a disability, Pamela Parent
emails Peter Principal and requests an evaluation of her child for a
disability. After the evaluation is complete, the Planning and
Placement Team determines that Pamela’s daughter does not qualify
for special education and Pamela threatens to sue the Board.

                               Concerns?



51                     © Shipman & Goodwin LLP 2022. All rights reserved.
Records

© Shipman & Goodwin LLP 2022.
                        2021. All rights reserved.   Connecticut | New York | Washington, DC | www.shipmangoodwin.com
“Public Record”
The FOIA defines “public record” broadly as follows:




“    • …Any recorded data or information relating to the
       conduct of the public's business prepared, owned, used,
       received or retained by a public agency, whether such
                      Increased
       data or information
                      Flexibilitybe handwritten, typed, tape-
       recorded, printed, photostatted, photographed or                        “
       recorded by any other method.
       Conn. Gen. Stat. §1-200(5).


53                        © Shipman & Goodwin LLP 2022. All rights reserved.
 Records
 Except as otherwise provided by any federal or state law, all records
maintained or kept on file by any public agency shall be public records.


 • The FOIC has no authority to order a public agency to create records
   where none exist
 • The FOIA does not require a public agency to conduct legal research
   or to respond to questions. However, “research” or searching to
   locate public records is always required!

 54                     © Shipman & Goodwin LLP 2022. All rights reserved.
Responding to Records Requests
• There should be a clear process in place for processing and responding to FOI
  requests (including a designation of the individual(s) responsible for
  responding).
• Disclosure must be made "promptly." “Promptness” will turn on the nature and
  extent of the specific request.
• A person making a request is generally entitled to a response within four
  business days. (If the request involves employee personnel or medical files and
  the agency reasonably believes an invasion of privacy would occur, a response
  must be made within ten business days, and special notice requirements apply).

 However, that does not mean the public agency automatically has four days to
 respond to a request. If a record is readily available for inspection or copying,
  it is a FOI violation to make the person requesting the record wait four days.

55                         © Shipman & Goodwin LLP 2022. All rights reserved.
FOIA Exemptions from Disclosure
 There are several specific exemptions to the general rule requiring
 disclosure of public records. See Conn. Gen. Stat. § 1-210(b). The
 following are examples from the complete list of exemptions:

                   • Records exempt from disclosure under federal or state
                     law (e.g. Section 10-151c of the Connecticut General
                     Statutes, which exempts teacher evaluation records from
                     disclosure)
                   • Education records not subject to disclosure under the
                     federal Family Educational Rights and Privacy Act
                     (FERPA)


56                      © Shipman & Goodwin LLP 2022. All rights reserved.
FOIA Exemptions from Disclosure
         • Personnel or medical files and similar files, the
           disclosure of which would constitute an invasion of
           personal privacy.
           Note: The legal standard for invasion of privacy is very strict: 1) the record at
           issue does not pertain to a matter of public concern, and; 2) disclosure of the
           record would be highly offensive to a reasonable person.
         • Communications privileged by the attorney/client
           relationship
         • Records, reports and statements of strategy or negotiations
           with respect to collective bargaining
         • Records pertaining to strategy and negotiations with
           respect to pending claims or litigation to which the public
           agency is a party until such litigation or claim is finally
           adjudicated or settled

57                © Shipman & Goodwin LLP 2022. All rights reserved.
FOIA Exemptions from Disclosure
         • Test questions, scoring keys and other data used to administer a
           licensing examination, examination for employment or academic
           examinations
         • Responses to any request for proposals or bid solicitation
           issued by a public agency, or any record or file made by a public
           agency in connection with the contract award process, until such
           contract is executed or negotiations for such award have ended,
           whichever is earlier, provided the chief executive officer of such
           public agency certifies that the public interest in disclosure of
           such records is outweighed by the public interest in the
           confidentiality of such records
         • Preliminary drafts or notes provided that the public agency
           has determined that the public interest in withholding such
           documents clearly outweighs the public interest in disclosure

58                © Shipman & Goodwin LLP 2022. All rights reserved.
FOIA Exemptions from Disclosure
         • However, “disclosure shall be required of: interagency or
           intra-agency memoranda or letters, advisory opinions,
           recommendations or any report compromising part of the
           process by which governmental decisions and policies are
           formulated, except disclosure shall not be required of a
           preliminary draft of a memorandum, prepared by a
           member of the staff of the public agency, which is subject
           to revision prior to submission to or discussion among the
           members of such agency.”
         • Informal advice from the FOIC staff indicates that if the
           personal notes are an agency member’s own notes,
           thoughts, etc., and are not disseminated to other members
           of the agency, they may not be subject to disclosure
59               © Shipman & Goodwin LLP 2022. All rights reserved.
General Confidentiality Considerations
     The district must comply with all legal requirements concerning
     confidentiality (e.g., FERPA)

     Matters discussed in executive session should be maintained as
     confidential unless the Board authorizes disclosure of the information

     Disclosure of confidential information can have significant
     consequences for the district (e.g., legal violations, increased liability,
     compromised position regarding negotiations)

     When in doubt, treat the information as confidential until a proper
     determination has been made regarding confidentiality vs. disclosure


60                       © Shipman & Goodwin LLP 2022. All rights reserved.
Electronic Communications

© Shipman & Goodwin LLP 2022.
                        2021. All rights reserved.   Connecticut | New York | Washington, DC | www.shipmangoodwin.com
Scenario 8: Electronic Communications
It was time for the Nutmeg Board to elect officers. In the week leading
up to the annual meeting, the internet was full of e-mails among Board
members soliciting support from other members. In addition, Board
members had caucused with their respective party Chairs to decide on
who would be the next chair. At the meeting, Mal Content nominated
Penny Pincher as the next Chair. Infuriated, Bob Bombast sent an
angry text message to Mal saying, “What gives, I thought we had a
deal?” Mal responded, “Sorry, Penny is supporting me for Vice-Chair.
Snooze you lose.”

                             Any issues?
62                     © Shipman & Goodwin LLP 2022. All rights reserved.
Electronic Communications
                • Email communication on Board
                  business by Board members to each
                  other (or to or from the Superintendent
                  to Board members) is permissible.
                • Such emails will typically be subject to
                  public disclosure unless exempt
                  (personally identifiable student info,
                  attorney/client information). Even if
                  on personal computer or personal
                  email.

63           © Shipman & Goodwin LLP 2022. All rights reserved.
Electronic Communications
                    Where email communication is unilateral,
                    it will likely not be considered a
                    “meeting” that would trigger FOIA
                    concerns.
                    Where such a communication generates
                    responses that are shared with a quorum
                    of the Board, it is possible that a
                    “discussion” (and hence a “meeting” in
                    violation of the FOIA) will be found


64           © Shipman & Goodwin LLP 2022. All rights reserved.
Who Speaks for the Board?

             • Each Board’s bylaws should state who the
               Board’s spokesperson is
             • Generally, it is the Board’s chairperson
             • Board members do not lose their first
               amendment rights




65           © Shipman & Goodwin LLP 2022. All rights reserved.
Handling Personnel Matters

© Shipman & Goodwin LLP 2022.
                        2021. All rights reserved.   Connecticut | New York | Washington, DC | www.shipmangoodwin.com
Impartial Hearing
• Under Connecticut General Statute 10-151, all teachers have certain due process
  rights, including to a hearing before an impartial hearing panel
• The Board may serve as that panel
• As a result, to preserve the impartiality of the Board members, they should not
  become involved in the details of an individual
  employee’s performance
• Connecticut General Statute 10-222 provides due process
  protections to athletic coaches who have coached a sport
  for at least 3 consecutive seasons
• They may appeal any decision not to renew, or to
  terminate, their contracts to the Board of Education.
  The Board must conduct a hearing and sit as
  an impartial panel.

67                         © Shipman & Goodwin LLP 2022. All rights reserved.
Due Process Violations
     A Board may violate an employee’s due process right to an
     impartial hearing by reviewing a personnel file prior to a
     hearing.

     Obtaining other evidence of an employee’s performance
     prior to the hearing.

     Discussing the employee’s performance with other Board
     members outside of the context of a termination or non-
     renewal proceeding.

68                 © Shipman & Goodwin LLP 2022. All rights reserved.
Communication With
the Public

© Shipman & Goodwin LLP 2022.
                        2021. All rights reserved.   Connecticut | New York | Washington, DC | www.shipmangoodwin.com
General Preparedness
• Districts should have procedures/practices for handling sensitive
  communications.
• The district may want to develop a “response team” that designates who
  is responsible for:
      Speaking on the district’s behalf
      Coordinating with outside agencies if necessary

• The district should establish clear lines of communication for decision-
  making for various situations, such as
      Responding to law enforcement investigations
      Closing of a building
      Shutting down of a computer system
      Handling onsite medical emergencies

70                              © Shipman & Goodwin LLP 2022. All rights reserved.
General Preparedness
Districts may also want to include directions for Board members on:
• When and how to communicate with the community at large, the
  press, parents, and/or staff
• Developing steps for dealing with the press and public




71                     © Shipman & Goodwin LLP 2022. All rights reserved.
Dealing With Parents and Staff
     Determine whether the Board should make a statement at all, or
     whether the matter should be left to an administrator

     Determine the subset of persons, if any, who should be notified of an
     event/crisis

     Promptly address immediate safety and educational concerns
     • Be sure not to reveal any FERPA or IDEA-protected or other
       confidential information
     • Consider what resources, if any, may be necessary to assist with
       student needs and parental concerns
     • Consider the appropriateness of a school community meeting


72                      © Shipman & Goodwin LLP 2022. All rights reserved.
Dealing With Parents and Staff
     Communicate, as appropriate, the school district’s next steps

     Identify and provide contact information of a school or district-based
     contact person to address follow-up concerns and questions

     Prepare staff to deal with media inquiries




73                      © Shipman & Goodwin LLP 2022. All rights reserved.
Dealing With The Press
             • Investigative reports and related documents
               must be disclosed, if requested, when the
               investigation is complete
             • Personnel records are pubic records unless they
               fall under a specific exception
             • Maintain a positive relationship with local press
               and work with local media prior to a crisis
             • Designate an individual to handle media
               inquiries
             • Fulfill FOI requests promptly if possible

74           © Shipman & Goodwin LLP 2022. All rights reserved.
Handling Student Issues

                        2021. All rights reserved.
© Shipman & Goodwin LLP 2022.                        Connecticut | New York | Washington, DC | www.shipmangoodwin.com
         The Family Educational Rights and Privacy Act
                                         (“FERPA”)
 While the Board is ultimately responsible for setting policy that will affect each
  student within the district, individual students have privacy rights guaranteed
  by FERPA
 Federal law that applies to recipients of federal funds (e.g. public schools,
  colleges and universities)

•    Protects the confidentiality of student education
•    Limits disclosure to 3rd parties without parental consent
•    Provides parents/guardians with a right to access student records of their
     children
    76                        © Shipman & Goodwin LLP 2022. All rights reserved.
                   “Education Record”

“    • …Any documented information directly relating to a
       student and maintained by the educational institution.
       May include documents, video, audio, film,
                      Increased
       photographs or    computer records
                      Flexibility
     • School districts must maintain the confidentiality of
       any personally identifiable student information
       contained in educational records
                                                                            “
77                     © Shipman & Goodwin LLP 2022. All rights reserved.
Interaction Between FOIA and FERPA

                FOIA                                                        FERPA

     • State law                                            • Federal law
     • Mandate: records must                                • Mandate: records are
       be disclosed, unless                                   confidential, unless
       there’s an applicable                                  parent consents or
       exception                                              there’s an applicable
                                                              exception

78                     © Shipman & Goodwin LLP 2022. All rights reserved.
Interaction Between FOIA and FERPA
• FOI Statute: Except as otherwise provided by any federal or state
  law, all records maintained or kept on file by any public agency shall
  be public records
• Records protected by the Family Educational Rights and Privacy Act
  (FERPA) are exempt from disclosure under the FOIA




79                      © Shipman & Goodwin LLP 2022. All rights reserved.
 “Personally Identifiable Student Information”


“    • …Personally identifiable student information also
       includes information that is linked or is linkable to a
       specific student that would allow a reasonable person
                      Increased
       in the school community
                      Flexibility to identify the student with
       reasonable certainty
                                                                             “
80                      © Shipman & Goodwin LLP 2022. All rights reserved.
Targeted Requests
• Even if the request or disclosure does not include explicit personally
  identifiable student information, a district may not release
  information if requested by someone who the district “reasonably
  believes knows the identity of the student to whom the education
  record relates”




81                      © Shipman & Goodwin LLP 2022. All rights reserved.
                               Confidentiality
• As a general rule, all personally identifiable information in educational records
  must be kept confidential unless a parent/guardian or eligible student consents,
  in writing, to disclosure
• Written consent must:
                                    Specify which records are being disclosed

                                    Specify the purpose of disclosure


                                    Identify the recipient



           Exceptions to this general rule are outside the scope of this
               presentation but can be found at www.ct.gov/foi/.
82                          © Shipman & Goodwin LLP 2022. All rights reserved.
When Is Prior Written Consent Not Required?
• When disclosure is to a school official, where that
  person has a legitimate educational interest in the
  information
      Who is a school official?

        o Must be under direct control of district

        o Must perform an institutional service/function

        o Access only to information needed; and used only for that purpose

      Annual notification requirements

      District must use reasonable methods to ensure that school
      officials have access only to those records in which they have a
      legitimate educational interest

83                                 © Shipman & Goodwin LLP 20221. All rights reserved.
When Is Prior Written Consent Not Required?
• When a student moves to another school district,
  records may be sent to the receiving district
• In a health or safety emergency
      May consider “totality of circumstances”

      Must have an articulable and significant threat to the
      health/safety of the student or others
      May disclose to “appropriate parties,” including parents

      Recording requirement




84                              © Shipman & Goodwin LLP 2022. All rights reserved.
When Is Prior Written Consent Not Required?
• For directory information
      District must give public notice of what qualifies as directory
      information
      Right to opt out

      May include: name, address, tel. #, email address, photo, DOB,
      participation in athletics etc.
      May NOT include social security numbers

• In response to a court order or subpoena


85                               © Shipman & Goodwin LLP 2022. All rights reserved.
When Is Prior Written Consent Not Required?
• Records that have been de-identified (i.e. the
  personally identifiable student information has been
  removed) may also be released without prior written
  consent
(Reminder: personally identifiable information includes
information that alone, or in combination, is linked or linkable to
a specific student that would allow someone in the school
community without personal knowledge to identify the student
with reasonable certainty)



86                          © Shipman & Goodwin LLP 2022. All rights reserved.
Consent Exception
• To parents of an eligible student (18 yrs
  +) if the parents still claim the student as
  a dependent for tax purposes
• To representatives of a child welfare
  agency (DCF) if it is legally responsible
  for the care/protection of the student




87                        © Shipman & Goodwin LLP 2022. All rights reserved.
Communications Regarding Student Matters

FERPA significantly restricts the district’s ability to communicate on
student matters
                         • FERPA prohibits disclosure/discussion
                           of matters identifiable to an individual
                           student
                         • Comment by the parent of a student
                           does not permit the district to comment
                           on matters related to that student

88                      © Shipman & Goodwin LLP 2022. All rights reserved.
Communications Regarding Student Matters

               • Importance of centralized communication
               • General statements regarding district’s
                 commitments to student safety/wellbeing
               • No communications regarding identifiable
                 students




89            © Shipman & Goodwin LLP 2022. All rights reserved.
Connect With Us:




                           Anne H. Littlefield
                       Shipman & Goodwin LLP
                                 (860) 251-5715
                          alittlefield@goodwin.com



           @ShipmanGoodwin         shipmangoodwin          shipman-&-goodwin-llp




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