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Decision Number
301
Book
17
Month
October
Year
1999
In RE
Ryan King
Appellant
Ryan King
Appellee
Fredericksburg Community School District
Full Text
Summary

Ryan King was a senior during the spring semester of the 1998-1999 school year. He was expelled on May 6, 1999, as the result of incidents that had occurred on April 21-22, 1999. The alternative school in New Hampton refused to enroll Ryan because of its policy not to accept expelled students. Ryan was finally able to obtain his GED and was attending Waldorf College. Ryan is planning to pursue a postgraduate degree and for work-search purposes, he did not want his resume to reflect the GED.

At the time Ryan was expelled, he was enrolled in 2 required courses [English & Government]. Passing the 2 courses were the only graduation requirements Ryan had to complete at the time of his expulsion. At the time of his expulsion, Ryan's grades were a high B and an A. Final examination were the only remaining events that could affect Ryan's grade in each of the courses. His expulsion prevented him from taking the final examinations. Even if Ryan had received 0 points on each of the final examination, he still would have passed the two courses.

The District allowed other students in their final semester of their senior year to skip final examinations where they had already earned the required points to receive a passing gade. Other students had received diplomas from the District even though they had not take the final examinations in required courses during the last semester. Ryan did not participate in graduation ceremonies and did not contend that he should have been allowed to do so.

A high school diploma suggests that the student has met the minimal academic requirements of a broad-based secondary education curriculum. Earning a diploma is a significant achievement. "A legal duty is enjoined upon the board under its own rule to issue a diploma to any pupil who has met the requirements and who has been passed by said board for the honors of graduation. Valentine v. Independent Sch. Dist. of Casey, 191 Iowa 1100, 183 N.W.434(1921).

Because Ryan completed the requirements set forth by the District for graduation, it was concluded that the Board's decision in this case is contrary to its esstablished policy and is unreasonable. The Board was cautioned about going beyond the limits of its stated academic requirements which must be fulfilled by each student, extending the requirements to include non-academic matters such as the quality of character or behavior would put the Board in the position of having to evenhandedly apply that subjective standard to every student's high school career before he or she could receive a diploma. Such a subjective standard might invite abuse of the Board's discretion.

That the decision of the Board of Directors of the Fredericksburg Community School District made on May 6, 1999, to deny a diploma to Ryan King was reversed.