Appellants seek reversal of the March 22, 2010 decision of the local board of directors of the Prairie Valley School District to close the Prairie Valley Elementary Building, commencing with the 2010-11 school year.
This is one of two building closing appeals decided by the State Board of Education on September 16, 2010; both are the first appeals to be decided by the State Board since the "Barker rules" were voided by the Iowa Supreme Court. Local school boards have explicit authority from Iowa Code sections 279.11, 279.39, and 280.3 to determine how many attendance centers (schools) to operate, where those attendance centers are to be located, and which students are to be assigned to each attendance center. Therefore, the correct legal standard of review is for "abuse of discretion." Under this standard of review, the State Board may not overturn the decision of a local school board unless the local board's decision was contrary to the law, irrational, and unreasonable. The State Board cannot analyze whether the decision of the local board was the best decision the local board could have made.
Here, many good reasons existed that would have justified closing either the middle school or the elementary building. The middle school is larger than the elementary building, has better parking options, has the better computer lab, and is fully air conditioned. These are substantial, credible reasons that support the decision of the local board to close the elementary building. There is nothing irrational or unreasonable about that decision.
Lacking any legal grounds on which to reverse the local Board, we would do great harm to the administrative legal system were we to substitute our own judgment for that of the Prairie Valley school board. The State Board of Education must uphold a discretionary decision of a local board "in the absence of fraud or abuse" or unless the local board exercised its power "in an arbitrary or capricious manner." There is no fraud and no abuse of discretion here. The local school board carefully studied the issue and did not act in an arbitrary, unreasonable, irrational manner. The local board made a decision that it has authority to make, and the board made that decision lawfully.For the foregoing reasons, it is recommended that the decision of the Board of Directors of the Prairie Valley Community School District made on March 22, 2010, closing Prairie Valley Elementary School be AFFIRMED.