Melanie Sohl v. Board of Education of the Town of Boonton, Morris County, 5/18/2021, (#106-21)

106-21
New Jersey Commissioner of Education
Decision
Melanie Sohl,
Petitioner,
v.
Board of Education of the Town of
Boonton, Morris County,
Respondent.
Synopsis
Petitioner, a tenured teacher in the respondent Board’s school district, appealed the Board’s decision to
affirm the results of a harassment, intimidation, and bullying (HIB) investigation into petitioner’s
conduct. The HIB investigation had concluded that the petitioner committed an act of HIB when she
allegedly said to an overweight student who was walking slowly to the front of the classroom, “[i]f there
was a cupcake up there, you would move faster.” Petitioner maintained that she had a good relationship
with the student in question and did not commit an act of HIB. Further, she contended that the Board
failed to comply with the due process requirements of the Anti-Bullying Bill of Rights Act (Act),
N.J.S.A. 18A:37-13 et seq. Petitioner filed a motion for summary decision, which was opposed by the
Board.
The ALJ found, inter alia, that: there are no material facts at issue here, and the matter is ripe for
summary decision; petitioner’s due process rights were violated because the Board did not comply with
the procedural mandates of the Act; the Board failed to provide petitioner with the opportunity to review
the HIB investigatory report, as well as all witness statements and documentary evidence, as required
pursuant to N.J.S.A. 18A:37-15b(6)(d); the Superintendent failed to submit a written summary of the HIB
investigation in order to provide information about the content of the HIB report and any discipline
imposed to the Board, as required under N.J.S.A. 18A:37-15b(6)(c); and after the HIB hearing, the Board
– not the Superintendent – should have issued a detailed written decision in keeping with
N.J.S.A. 37-15b(6)(e). Accordingly, the ALJ granted petitioner’s motion for summary decision,
remanded the matter to the Board for an HIB hearing in accordance with petitioner’s due process rights
under N.J.S.A. 18A:37-15 and ordered that the letter of reprimand be removed from the petitioner’s
personnel file.
Upon review, the Commissioner, inter alia, disagreed with the ALJ’s determination that the petitioner
was not afforded due process and that the Board failed to comply with the procedural requirements of the
Act. As such, the Commissioner rejected the ALJ’s decision to remand this matter for a Board hearing
and instead remanded it to the OAL for a hearing on the merits. Petitioner will have the opportunity to
challenge whether the Board’s finding of HIB was arbitrary, capricious or unreasonable as this matter
proceeds at the OAL. Additionally, the Board is not required to remove the letter of reprimand from
petitioner’s personnel file at this time. Accordingly, the Initial Decision was rejected and the matter was
remanded to the OAL for a determination on the merits.
This synopsis is not part of the Commissioner’s decision. It has been prepared for the convenience of the reader. It
has been neither reviewed nor approved by the Commissioner.

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OAL Dkt. No. EDU 05070-20
Agency Dkt. No. 102-5/20
New Jersey Commissioner of Education
Final Decision
Melanie Sohl,
Petitioner,
v.
Board of Education of the Town of Boonton,
Morris County,
Respondent.
The record of this matter and the Initial Decision of the Office of Administrative
Law (OAL) been reviewed and considered, as have the exceptions filed by the respondent
Boonton Town Board of Education (Board), pursuant to N.J.A.C. 1:1-18.4. The petitioner did
not file a reply.
This matter concerns an allegation of harassment, intimidation, and bullying
(HIB) committed by a teacher against a student. Petitioner is alleged to have told an overweight
student who was walking slowly to the front of the classroom, “[i]f there was a cupcake up there,
you would move faster,” in addition to other food-related comments. The student reported the
alleged comment on January 15, 2020, and the following day, the school’s Principal met with
petitioner, along with the District’s anti-bullying coordinator and the Boonton Education
Association President. The anti-bullying coordinator then conducted an interview with petitioner
on January 27, 2020, with the Board attorney, petitioner’s attorney and the Principal in
attendance. Thereafter, the Superintendent informed petitioner in writing that the HIB allegation
was confirmed and that she would be required to undergo sensitivity training as a remedial
106-21

2
measure and would be issued a letter of reprimand. The Principal issued the letter of reprimand
on February 4, 2020, which recounted that petitioner had admitted making the alleged “cupcake”
comment and other food-related comments to the same student. Petitioner responded by letter
clarifying that she had a good relationship with the student and “did not realize that the student
might have taken the comment to mean anything other than a motivating comment to get them to
the board quicker.” She also explained that the student had previously asked for snacks or
complained of being hungry, and while she denied making food comments toward the student,
she has had many students who are motivated by snacks.
Prior to the Board hearing, the Superintendent submitted to the Board a summary
of the HIB investigation and determination but did not appear to discuss discipline. Petitioner
then appeared with her attorney in an executive session at the February 10, 2020 Board meeting,
during which no testimony on behalf of the district was presented. The Board voted to uphold
the finding of HIB, which was communicated to petitioner in a letter from the Superintendent the
following day.
The Administrative Law Judge (ALJ) found that petitioner’s due process rights
were violated because the Board did not comply with the procedural mandates of the Anti-
Bullying Bill of Rights Act (Act), N.J.S.A. 18A:37-13 et seq. The ALJ remanded the matter so
that petitioner could be afforded a new Board hearing, specifically finding: (1) pursuant to
N.J.S.A. 18A:37-15b(6)(d), the Board should provide petitioner with the opportunity to review
the HIB investigatory report, as well as all witness statements and documentary evidence; (2) the
Superintendent’s written summary to the Board regarding the HIB investigation should inform
the Board of the contents of the HIB report and any discipline imposed, as required by N.J.S.A.
18A:37-15b(6)(c); (3) the Board, not the Superintendent, should issue a detailed written decision

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after the hearing, in keeping with N.J.S.A. 37-15b(6)(e); and (4) the February 4, 2020 letter of
reprimand should be removed from petitioner’s personnel file. However, the ALJ found that
there was no due process violation with respect to petitioner’s opportunity to confront and cross-
examine witnesses because the Act does not require a full adversarial hearing.
By way of exceptions, the Board argues that the ALJ erred in her analysis of the
due process requirements under the HIB statute. Specifically, the Board argues that N.J.S.A.
18A:37-15b(6)(e) does not prohibit the Superintendent – the “CEO” of the Board – from
conveying the Board’s HIB determination to petitioner, and notes that this issue was not raised or
briefed by either party. Additionally, the Board maintains that N.J.S.A. 18A:37-15b(6)(c) does
not require that the Superintendent’s report to the Board on the HIB investigation be written, and
since this issue was decided sua sponte by the ALJ, the Board did not have the opportunity to
submit a certification as to the verbal summary made to the Board during the hearing. The Board
also points out that the ALJ improperly required that a “detailed written decision” be issued after
the Board hearing because N.J.S.A. 18A:37-15b(6)(e) only requires that the Board affirm, reject,
or modify the Superintendent’s decision.
The Board also argues that the ALJ erred in remanding the matter back to the
Board for a new hearing and removal of the reprimand because petitioner’s due process rights
were not violated. According to the Board, N.J.S.A. 18A:37-15b(6)(d) only requires that
petitioner be informed as to the nature of the investigation, whether the district found HIB, and
any discipline imposed, and does not require that the Board produce the full investigatory file,
such as the witness statements or the HIB report. The Board maintains that petitioner was not
deprived of a life, liberty or property interest and, nevertheless, she was fully aware of the
allegations and had the opportunity to be heard at the Board hearing. Additionally, the Board

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contends that the reprimand was issued to petitioner as a result of her inappropriate statements to
a student – and not as an outcome to the HIB investigation – so she would have had to challenge
it through the locally negotiated grievance process rather than as part of her HIB petition. For
these reasons, the Board urges the Commissioner to reject the Initial Decision.
Upon review, the Commissioner disagrees with the ALJ’s determination that the
petitioner was not afforded due process and that the Board failed to comply with the procedural
requirements of the Act. As such, the Commissioner rejects the ALJ’s decision to remand this
matter for a Board hearing and will instead remand this matter to the OAL for a hearing on the
merits.
The Commissioner will address the three relevant provisions of the Act in turn.
First, and most pertinent to this matter, N.J.S.A. 18A:37-15b(6)(d) states:
[P]arents or guardians of the students who are parties to the
investigation shall be entitled to receive information about the
investigation, in accordance with federal and State law and
regulation, including the nature of the investigation, whether the
district found evidence of harassment, intimidation, or bullying, or
whether discipline was imposed or services provided to address the
incident of harassment, intimidation, or bullying. This information
shall be provided in writing within 5 school days after the results
of the investigation are reported to the board. A parent or guardian
may request a hearing before the board after receiving the
information, and the hearing shall be held within 10 days of the
request. The board shall meet in executive session for the hearing
to protect the confidentiality of the students. At the hearing the
board may hear from the school anti-bullying specialist about the
incident, recommendations for discipline or services, and any
programs instituted to reduce such incidents[.]
The Commissioner has previously established that teachers and other staff members who are
accused of HIB are entitled to the same due process protections that are provided to students
under the Act. Ruth Young-Edri v. Board of Education of the City of Elizabeth, Union County,
Commissioner’s Decision No. 174-19, decided July 8, 2019; Stephen Gibble v. Board of

5
Education of the Hunterdon Central Regional School District, Hunterdon County,
Commissioner’s Decision No. 254-16, decided July 13, 2016.
Here, petitioner was provided with two written communications regarding the
investigation prior to the February 10, 2020 Board hearing: a January 28, 2020 letter from the
Superintendent and a February 4, 2020 letter of reprimand from the Principal. The
Superintendent’s letter informed petitioner that the HIB investigation into her alleged actions
was confirmed, and that the Board would vote on the results at its February 10 meeting. The
letter further explained that the following measures were taken to address the situation: (1)
Remedial Measures – Sensitivity Training; and (2) Consequence – Letter of Reprimand. The
February 4, 2020 letter of reprimand memorialized the January 16, 2020 conversation:
During our meeting, you admitted saying, “If there was a cupcake
up there, you would move faster” to a student who was slowly
making their way towards the front of the room to participate in
answering a question. You had also mentioned that “food
comments” were made, by yourself, to the same student during the
study hall that you supervise. Regardless of rapport with a student,
comments of this nature are improper, unprofessional, and must
not be repeated. As the adult in the classroom, you are expected to
act professionally at all times.
The Commissioner finds that when the two written communications are viewed in conjunction,
petitioner was informed of the nature of the investigation, specifically of the cupcake comment
that she was alleged to have said, along with the finding that she had admitted to making the
comment. She was also informed that the district found evidence of HIB, and of the discipline
being imposed in the form of sensitivity training and a letter of reprimand. Accordingly, as
petitioner was provided with information about the investigation in advance of the Board
hearing, the Commissioner finds that the Board met the requirements of N.J.S.A. 18A:37-
15b(6)(d).

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The ALJ relied upon Young-Edri, supra, in which, among other procedural
violations, the petitioner was not provided with a written summary of the HIB investigation. The
written letter of reprimand that Young-Edri received only informed her that she was a perpetrator
in an HIB case, but did not recount any of the factual basis for that determination. Id.
Additionally, in another matter, the Appellate Division issued an unpublished decision
remanding an HIB matter for a new Board hearing and ordered the disclosure of the full HIB
record, including the underlying investigative report and any reports or summaries. J.L., on
behalf of minor child, A.L. v. Board of Education of the Bridgewater-Raritan Regional School
District, Somerset County, A-2022-16T1 (App Div. Oct. 16, 2018).
Those cases are easily distinguishable from this matter. Contrary to Young Edri,
petitioner did receive a written summary of the investigation; the letter of reprimand petitioner
received explained the specific allegation against her. Additionally, the distinguishing factor in
J.L. is that the accused child’s parents were not informed about the HIB investigation until after
the Board voted. Here, petitioner was aware of the HIB investigation: she participated in two
meetings regarding the allegations, received two written communications, responded to the letter
of reprimand acknowledging that she “did not realize that the student might have taken the
comment to mean anything other than a motivating comment to get them to the board quicker,”
and she was represented by an attorney at the Board hearing. Petitioner was aware of the
investigation and its findings, had the opportunity to be heard, and availed herself of her
procedural due process rights.
The Commissioner agrees with the ALJ, however, that petitioner was not entitled
to a trial-type adversarial hearing with the opportunity to cross-examine witnesses. The Act
requires that a hearing be conducted in executive session and that the Board “may hear from the

7
school anti-bullying specialist about the incident, recommendations for discipline, or services,
and any programs instituted to reduce such incidents.” N.J.S.A. 18A:37-15b(6)(d) (emphasis
added). Here, petitioner had the opportunity to present her own witnesses and evidence to refute
the findings against her. As such, despite petitioner’s arguments to the contrary, the
Commissioner cannot find a procedural violation of N.J.S.A. 18A:37-15b(6)(d) that would
require a new Board hearing.
Second, N.J.S.A. 18A:37-15b(6)(c) provides:
[T]he results of each investigation shall be reported to the board of
education no later than the date of the board of education meeting
next following the completion of the investigation, along with
information on any services provided, training established,
discipline imposed, or other action taken or recommended by the
superintendent[.]
Here, following the completion of the HIB investigation, the Superintendent submitted a notice
to the Board describing the allegations and the HIB determination. While the written notice does
not appear to reference the discipline imposed, the statute does not specify the manner in which
the Board must be informed. As it was not addressed by the parties in the briefing or
certifications, it is unclear from the record what happened verbally at the Board meeting and
whether the discipline imposed on petitioner was reported to the Board. As such, the
Commissioner cannot find a procedural violation of N.J.S.A. 18A:37-15b(6)(c).
Finally, N.J.S.A. 18A:37-15b(6)(e) requires:
[A]t the next board of education meeting following its receipt of
the report, the board shall issue a decision, in writing, to affirm,
reject, or modify the superintendent’s decision. The board’s
decision may be appealed to the Commissioner of Education, in
accordance with the procedures set forth in law and regulation, no
later than 90 days after the issuance of the board’s decision[.]

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Following the Board’s vote to sustain the HIB determination on February 10, 2020, the
Superintendent advised petitioner by letter the following day that “the Board upheld your
incident of January 14, 2020.” The Commissioner disagrees with the ALJ that the statute
prohibits the Superintendent from communicating the Board’s decision. Additionally, the statute
does not require a detailed decision. The statute simply requires that the Board “affirm, reject, or
modify the superintendent’s decision.” N.J.S.A. 18A:37-15b(6)(e). As such, there is no evidence
that the Board failed to comply with the requirements of N.J.S.A. 18A:37-15b(6)(e)
As the Commissioner has not found procedural deficiencies with the conduct of
the Board’s HIB investigation, a remand to the Board for a new hearing is inappropriate.
Petitioner will have the opportunity to challenge whether the Board’s finding of HIB was
arbitrary, capricious or unreasonable as this matter proceeds at the OAL. Additionally, the
Board is not required to remove the letter of reprimand from petitioner’s personnel file at this
time.1
Accordingly, the Initial Decision is rejected, and this matter is remanded to the
OAL for a determination on the merits.
IT IS SO ORDERED.2
ACTING COMMISSIONER OF EDUCATION
Date of Decision:
Date of Mailing:
1 The Commissioner declines to address the Board’s argument that the reprimand was not issued as an
outcome of the HIB investigation, but rather as discipline subject to a challenge through the locally
negotiated grievance process, as it is not necessary for this decision.
2 This decision may be appealed to the Appellate Division of the Superior Court pursuant to N.J.S.A.
18A:6-9.1. Under N.J.Ct.R. 2:4-1(b), a notice of appeal must be filed with the Appellate Division within
45 days from the date of mailing of this decision.
May 18, 2021
May 18, 2021

New Jersey is an Equal Opportunity Employer
State of New Jersey
OFFICE OF ADMINISTRATIVE LAW
INITIAL DECISION
SUMMARY DECISION
OAL DKT. NO. EDU 05070-20
AGENCY DKT. NO. 102-5/20
MELANIE SOHL,
Petitioner,
v.
BOARD OF EDUCATION OF THE TOWN
OF BOONTON, MORRIS COUNTY,
Respondent.
Joshua M. Forsman, Esq., for petitioner (Caruso Smith Picini, attorneys)
James L. Plosia Jr., Esq., for respondent (Plosia Cohen, attorneys)
Record Closed: February 3, 2021 	Decided: February 24, 2021
BEFORE SARAH H. SURGENT, ALJ:
STATEMENT OF THE CASE
Petitioner Melanie Sohl (Sohl), a tenured teacher employed by respondent, the
Board of Education of the Township of Boonton, Morris County (Board), appeals from its
determination that she committed an alleged hate, intimidation, bullying (HIB) act against

OAL DKT. NO. EDU 05070-20
2
an overweight student by referencing a “cupcake” as he walked toward the classroom
chalkboard, along with making other “food comments” in his study hall. 	Sohl maintains
her innocence and contends that the Board failed to comply with the due process
requirements of the Anti-Bullying Bill of Rights Act (ABRA), N.J.S.A. 18A:37-13, et seq.,
and that its determination must therefore be reversed with prejudice. Sohl also maintains
that in the alternative, if the matter is remanded, the Board must be ordered to comply
with the ABRA at a subsequent Board hearing. The Board maintains that it did not violate
Sohl’s ABRA due process rights and that Sohl’s motion for summary decision should be
denied.
PROCEDURAL HISTORY
Sohl’s petition of appeal with exhibits was filed by Crystal A. Alonso, Esq., (Alonso)
of Caruso Smith Picini, P.C., with the Commissioner of Education (Commissioner) on or
about April 30, 2020. (P-1). The Board’s answer was filed with the Commissioner on or
about May 19, 2020. 	(R-1). 	The matter was transmitted to the Office of Administrative
Law (OAL) on May 20, 2020, where it was filed on June 2, 2020, to be heard as a
contested case, pursuant to N.J.S.A. 52:14B-1 et seq. and N.J.S.A. 52:14F-1 et seq.
(C-1).
On a July 23, 2020 telephone conference, the parties indicated they would be
cross-moving for summary decision, a briefing schedule was set, and Alonso represented
that Sohl did not deny referencing a “cupcake,” but asserted there were due process
issues regarding discovery and the Board’s February 10, 2020 hearing. The parties were
directed to submit a joint exhibit list and joint stipulation of facts by August 14, 2020. On
August 14, 2020, the Board sent a letter requesting a telephone conference and indicating
that Alonso responded on August 13, 2020 via email to the Board’s proposed joint
submissions stating “I cannot agree to a Joint Exhibit List at this time as there are
documents on your proposed list that have never been provided to me.” (R-2). The Board
indicated that Alonso failed to address its proposed joint statement of facts and the Board
requested that the matter be set down for a plenary hearing.

OAL DKT. NO. EDU 05070-20
3
On August 19, 2020, Alonso filed a motion for summary decision with supporting
exhibits and certifications by Alonso and Sohl, pursuant to N.J.A.C. 1:1-12.5, denying
Sohl’s alleged HIB conduct and asserting due process issues. 	(P-2). 	The Board’s
opposition brief was filed on August 28, 2020, (R-3), along with a supporting certification
by Judy Sorochynskyj, the District’s anti-bullying coordinator (ABC), (R-4). The Board did
not cross-move for summary decision, as there were no joint exhibits or stipulations to
material facts.
Alonso filed Sohl’s reply brief and exhibit on September 10, 2020. 	(P-3). 	On
October 14, 2020, Joshua M. Forsman, Esq., (Forsman) represented Sohl on a telephone
conference, and indicated that Alonso had left his law firm. 	Forsman indicated that the
parties were trying to settle the case. 	On December 14, 2020, another telephone
conference was held with the parties, who did not reach a settlement. Oral arguments on
Sohl’s motion were heard on January 13, 2021. On that date, the parties agreed that a
genuine issue of material fact exists as to whether Sohl committed and/or admitted to the
alleged HIB conduct, precluding summary decision on that issue. Thus, the issue of this
summary decision is limited to whether Sohl received ABRA due process prior to and at
the Board hearing.
The record was left open for ten days, so that the Board could forward the HIB
investigation discovery it provided to Alonso on August 4, 2020, (R-7), fifteen days before
Alonso filed Sohl’s motion. 	The Board also volunteered to send letters exchanged
between the Board and Alonso prior to the February 10, 2020 Board hearing, but Forsman
wanted to pre-screen them, with an opportunity to object. 	Not having heard about the
disposition of those letters, I held the record open and contacted the parties about their
status on January 27, 2021.
A telephone conference was held on that issue on February 2, 2021. The Board
had produced to Forsman all correspondence in its file related to this case, but conceded
it was not sure why any of that correspondence was relevant to the due process issues

OAL DKT. NO. EDU 05070-20
4
at hand. 	After hearing Forsman’s objections to the relevance of the letters, the parties
agreed that the Board would only submit to this forum a February 6, 2020 letter from the
Superintendent to Alonso, and that Sohl would be estopped from arguing any due process
issues about the letters Forsman urged to be excluded, should the matter be remanded
to the Board. 	The February 6, 2020 letter was received from the Board on February 3,
2021, (R-5), and the record closed.
FACTUAL DISCUSSION AND FINDINGS
These salient facts are undisputed. I therefore FIND:
Sohl is a tenured mathematics teacher who has been employed by the Board for
eleven years. Aside from the subject of this decision, there is no evidence that she has
any prior disciplinary history as a teacher for the District. She was Boonton High School
student 	G.T.’s 	mathematics 	teacher 	during 	the 	2019–2020 	school 	year 	and 	also
supervised G.T.’s study hall. G.T. was at that time an overweight adolescent in the ninth
grade.
On January 15, 2020, G.T. spoke with Jason Klebez, the school Principal
(Principal), and alleged that on January 14, 2020, as he was walking to the chalkboard to
do a math problem, Sohl said, in front of the entire class, “I bet if there was a cupcake up
here you’d move a lot faster.” G.T. reported that he was upset and embarrassed by the
alleged comment. 	On January 16, 2020, the District’s ABC interviewed G.T. about the
alleged incident, with the Principal in attendance. G.T. confirmed the “cupcake” comment
he had reported to the Principal, and further alleged that on several occasions in study
hall, Sohl had made other food-related comments, such as “what are you doing over here;
there’s no food here.” 	G.T. reported that he was embarrassed and humiliated by such
comments, particularly because they were heard by other students, and he believed they
disparaged his “physique.”

OAL DKT. NO. EDU 05070-20
5
On January 16, 2020, the Principal held a meeting with Sohl, the District’s ABC,
and Bob Davis, the Boonton Education Association President. The Principal questioned
Sohl about the alleged “cupcake” comment. 	The parties now disagree as to whether
during that interview Sohl “recalled” making that specific comment or any other alleged
comments about food to G.T., and whether or not she volunteered that she had made
other “food” comments to G.T. during study hall. 	At the conclusion of the meeting, the
Principal advised Sohl that she would be contacted by the ABC for further investigation
of the alleged HIB violation.
On January 16, 2020, the Board’s attorney received a letter from Alonso stating
that “[g]iven the nature of the underlying allegations, Ms. Sohl is more than willing to
cooperate with the District by participating in an interview.” (R-4 Ex. A). On January 27,
2020, Sohl was interviewed by the ABC, with Alonso, the Board’s attorney, and the
Principal in attendance. 	The parties now disagree as to whether during that interview
Sohl admitted, denied, or did not recall making the alleged comments.
By letter dated January 28, 2020, Robert Presuto, the Boonton Superintendent of
Schools (Superintendent) advised Sohl:
In accordance with the provisions of the New Jersey Anti-
Bullying Bill of Rights Act and the Boonton Board of Education
Policy #5512, parents or guardians of the student who are
parties of a HIB investigation shall receive information about
the outcome of the investigation.
You were reported to have committed an act of . . . (HIB) on
January 14, 2020. 	The complaint was investigated by our
staff and determined to be a Confirmed Incident of HIB. At
its February 10th meeting, the Boonton Board of Education will
vote on the results of the investigation.
All acts of HIB are taken very seriously and we have taken
every measure to ensure that the situation was addressed
appropriately, which had included but not limited to [sic] the
following:

OAL DKT. NO. EDU 05070-20
6
Remedial Measures – Sensitivity Training
Consequence – Letter of Reprimand
We 	continue 	to 	be 	committed 	to 	providing 	a 	safe 	and
productive educational environment.
If you acknowledge the result, no further action is necessary.
If you are not in agreement with this result, you may request
and receive a hearing with the Board of Education. 	This
request must be received in writing within 45 days of this
notice. 	This hearing shall be held within ten days of the
request.
Please do not hesitate to contact my office with any questions
or concerns you may have regarding this matter.
[(P-2 Ex. A) (bold and emphasis in original).]
By letter dated February 4, 2020, the Principal advised Sohl:
This letter confirms and memorializes our conversation on
January 16, 2020 regarding the concern of inappropriate
comments towards a student.
During our meeting, you admitted saying, “If there was a
cupcake up there, you would move faster” to a student who
was slowly making their way towards the front of the room to
participate in answering a question. You had also mentioned
that “food comments” were made, by yourself, to the same
student during the study hall that you supervise. Regardless
of 	rapport 	with 	a 	student, 	comments 	of 	this 	nature 	are
improper, unprofessional, and must not be repeated. 	As the
adult in the classroom, you are expected to act professionally
at all times.
I have reviewed your personnel file and determined what
disciplinary 	consequences 	are 	warranted. 	After 	much
consideration I have decided that a positive approach to
discipline would be beneficial for you and your classroom
environment. 	The 	attached 	improvement 	plan 	must 	be
completed by Friday, February 21, 2020.
Please review and sign this letter prior to February 5, 2020.
You may choose to provide a written explanation of your
behavior, and I would be happy to attach it to this letter. If you

OAL DKT. NO. EDU 05070-20
7
refuse or fail to sign the copy of this letter by February 5, 2020,
the letter will still be placed in your personnel file.
I, Melanie Sohl have met with administration and had an
opportunity to review this reprimand. I have received a copy
and have been given the opportunity to provide a written
response.
[(P-2 Ex. C).]
The Superintendent was copied on that letter, which was signed by the Principal
and Sohl, who wrote under her signature, “IN RECEIPT ONLY.” By letter dated February
4, 2020, Sohl wrote and signed a lengthy written response stating, in relevant part, that
during the January 16, 2020 meeting,
I did not recall the exact wording of such made comment, I did
however confirm there was a reference to food made to serve
as a motivating factor.
I proceeded to explain my relationship with the student and
that I did not realize that the student might have taken the
comment to mean anything other than a motivating comment
to get them to the board quicker.
. . . .
I had asked the Principal if I was allowed to apologize to the
student as my words were never intended to be hurtful in
anyway [sic].
[(P-2 Ex. C).]
By letter also dated February 4, 2020, Alonso wrote to the Board’s attorney,
confirming that she had received the Superintendent’s January 28, 2020 letter to Sohl,
and requesting that a Board hearing be scheduled “at your earliest convenience,” so that
Sohl could “present her appeal.” 	(P-2 Ex. D). 	Sohl and Alonso appeared before the
Board in an executive session on February 10, 2020.

OAL DKT. NO. EDU 05070-20
8
Sohl now alleges that prior to and during the Board hearing,
[n]o evidentiary materials or discovery from the investigation
were 	ever 	provided 	to 	me. 	I 	never 	received 	witness
statements. 	I never received a findings report from the HIB
investigator. 	At the “hearing,” no evidence was presented
against me by neither [sic] the Board nor [sic] Superintendent.
The 	Superintendent 	was 	present 	at 	the 	“hearing” 	and
remained silent throughout. My attorney and I were permitted
to make brief statements to the Board.
[(P-2 Sohl Certif. ¶¶ 13-14).]
By letter dated February 11, 2020, the Superintendent advised Sohl that at the
February 10, 2020 Board meeting, “the Board upheld your incident of January 14, 2020.
The incident will remain confirmed.” (R-6). That was the entirety of the communique.
The HIB file discovery which the Board provided to Ms. Alonso on August 4, 2020
and to this Tribunal on January 13, 2021 includes Sohl’s February 4, 2020 above-
described response letter to the Principal’s February 4, 2020 letter, and a three-page
“Harassment, Intimidation, & Bullying Incident Report Form” dated January 15, 2020,
which contains no new information. 	(R-7). 	However, it also includes an undated,
unsigned two-page summary of G.T.’s January 16, 2020 interview and Sohl’s January 27,
2020 interview, along with a conclusion that the alleged incident was “a confirmed HIB.”
(R-7).
The summary of G.T.’s interview contains information that was not conveyed to
Sohl by the Principal’s February 4, 2020 letter, including that some of G.T.’s peers
laughed at the alleged “cupcake” comment, while others told G.T., “[t]his is messed up.”
(R-7). 	It also states that G.T.’s friend, whose name was redacted, encouraged G.T. to
report the incident to a Mrs. Soni (Soni), which G.T. did, that Soni referred it to a Mr. Nash,
and that G.T. also reported the incident to his mother. (R-7). It describes G.T.’s feelings
in much greater detail, including that he felt Sohl frequently belittled him, made him “look
dumb,” and that he wanted to switch to another math class to get away from Sohl. (R-7).

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The Board’s August 4, 2020 discovery production also includes a one-page
Investigation Report Form, an Investigation Flowchart and Timelines, and an unsigned
document 	entitled 	“BHS 	HIB 	#7 	Confirmed 	# 	036854,” 	which 	summarizes 	the
investigation and findings. (R-7). “Exec 1/27/20” and “Affirm 2/10/20” are handwritten on
that document, which corresponds with the Board’s January 27, 2020 meeting at which
the Superintendent was to present a summary of the allegations and factual findings, and
Sohl’s February 10, 2020 hearing before the Board. 	(R-7).
The Parties’ Written and Oral Arguments
By way of Alonso’s moving and reply briefs, Sohl argues that the Board violated
her due process rights under N.J.S.A. 18A:37-15b(6)(d) because “she never received
crucial information about the HIB investigation, including, but not limited to, the evidence
gathered during the course of the investigation,” and because “[d]uring the hearing, the
Board failed to produce any evidence in support of [the Superintendent’s] determination
that Ms. Sohl was guilty of violating the [ABRA].” She complains that the Superintendent
did not testify or speak at the hearing, and that she had no opportunity “to face her
accuser, cross-examine witnesses or challenge whatever evidence was gathered during
the HIB investigation,” because “[n]o one testified to their alleged statements and
accusations at the ‘hearing.’”
Sohl argues that those alleged violations of her due process rights “severely
prejudiced her ability to defend against the [HIB] allegation.” 	She relies upon an
unpublished Appellate Division decision, J.L. v. Bd. of Educ., No. A-2022-16T1 (App. Div.
Oct. 16, 2018), https://njlaw.rutgers.edu/collections/courts/appellate/a2022-16.opn.html,
(C-2), and Young-Edri v. Bd. of Educ. of City of Elizabeth, 2019 N.J. AGEN LEXIS 403
(May 30, 2019), adopted Comm’r, 2019 N.J. AGEN LEXIS 845 (July 8, 2019), (P-3 Ex.
A), for the proposition that she was denied due process because she did not receive the
entire HIB investigation file and a “full and proper hearing” before the Board.

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10
At oral arguments on Sohl’s motion, the parties agreed that the HIB investigation
file was not provided to Sohl prior to the Board hearing, that it was provided to Alonso on
August 4, 2020,1 fifteen days prior to Alonso’s filing of Sohl’s motion, and that there are
no other documented witness statements aside from G.T.’s and Sohl’s.
Forsman maintained that all HIB discovery was required to be provided under the
ABRA prior to the hearing, whether or not Alonso requested it. 	However, he conceded
that Alonso was an experienced attorney at the time of the Board hearing, that she did
not request any discovery prior to the hearing, and that he did not know why she
proceeded to the hearing without it, because Sohl’s law firm was well aware of N.J.S.A.
18A:37-15. Forsman asserted that although there were no other witness statements, full
discovery may have improved Sohl’s defense by triggering further investigation and
potential interviews with other students who may have witnessed the alleged incident.
The Board’s opposition brief asserts that Sohl’s due process rights were not
violated, as she “was fully apprised of the nature of the allegations against her,” and “she
acknowledged making the offending statements to the student.” 	The Board relies upon
L.K. v. Mansfield Twp. Bd. of Educ., 2019 N.J. AGEN LEXIS 62 (Jan. 16, 2019), rejected
on other grounds Comm’r, 2019 N.J. AGEN LEXIS 345 (April 22, 2019), for the
proposition that the Board was not required to produce testimonial evidence at the
hearing. 	It also relies upon DeFalco v. Hamilton Twp. Bd. of Educ., 2019 N.J. AGEN
LEXIS 515 (June 25, 2019), adopted Comm’r, 2019 N.J. AGEN LEXIS 732 (July 26,
2019), for the proposition that the ABRA does not mandate a judicialized discovery and
trial process, and merely requires that an accused staff member be apprised of the
alleged HIB charge, the evidence upon which it is based, and the opportunity to present
evidence, witness testimony, and oral arguments to the Board.
1 On January 28, 2021, I inquired about what appeared to be missing pages 2-3 of the Board’s Investigation
Report Form, which was supplied by the Board to Alonso on August 4, 2020. (R-7). On February 4, 2021,
the Board responded by supplying a three-page SSDS Incident Report Form, (R-8), which was not
previously produced to this Forum or, according to Forsman, Alonso. The Board has not produced any
additional pages of its Investigation Report Form, which contains the redacted names of two witnesses.

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At the OAL oral arguments, the Board maintained that it was not required to
produce HIB discovery sua sponte, and that Sohl had adequate notice of the charge
against her, as outlined in the Principal’s February 4, 2020 letter to Sohl. 	The Board
accused Sohl’s law firm of “playing a gotcha game,” in essence, by inviting the alleged
due process error. The Board argued that N.J.S.A. 18A:37-15(d) contemplates, at most,
that only Loudermill2 due process was arguably required – that is, notice of the allegations
and an opportunity to be heard, because no property rights were lost – Sohl was merely
reprimanded, not suspended or dismissed.
The Board explained that there were no other witness statements because G.T.’s
allegation was investigated by interviewing Sohl first, and she allegedly admitted to the
allegation, obviating the need to cause further disruption by interviewing other potential
witnesses. 	For the same reason, the Board felt no need to call witnesses for what it
believed to be an undisputed statement, and reiterated that it was not obliged to present
witnesses in any event. The Board represented that it did not believe the HIB investigative
report was provided to the Board prior to the hearing, and that the District’s procedure is
to provide that report to the Superintendent, who then renders a decision which is
conveyed to the parent, teacher, and the Board before the hearing.
LEGAL ANALYSIS AND CONCLUSIONS
Summary Decision Standard
A summary decision “may be rendered if the papers and discovery which have
been filed, together with the affidavits, if any, show that there is no genuine issue as to
any material fact challenged and that the moving party is entitled to prevail as a matter of
law.” 	N.J.A.C. 1:1-12.5(b). 	That rule is substantially similar to the summary judgment
rule embodied in the New Jersey Court Rules. 	See R. 4:46-2; Judson v. Peoples Bank
& Trust Co. of Westfield, 17 N.J. 67, 74 (1954).
2 Cleveland Bd. of Educ. v. Loudermill, 470 U.S. 532 (1985).

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In Brill v. Guardian Life Ins. Co., 142 N.J. 520 (1995), the New Jersey Supreme
Court addressed the appropriate test to be employed in determining the motion:
“[A] determination whether there exists a ‘genuine issue’ of
material fact that precludes summary judgment requires the
motion judge to consider whether the competent evidential
materials presented, when viewed in the light most favorable
to the non-moving party, are sufficient to permit a rational fact
finder to resolve the alleged disputed issue in favor of the non-
moving party. 	The ‘judge’s function is not . . . to weigh the
evidence 	and 	determine 	the 	truth 	of 	the 	matter 	but 	to
determine whether there is a genuine issue for trial.’”
[Id. at 540 (quoting Anderson v. Liberty Lobby, Inc., 477 U.S.
242, 250 (1986)).]
In evaluating the merits of the motion, “[a]ll inferences of doubt are drawn against
the movant and in favor of the opponent of the motion.” Judson, 17 N.J. at 75. “When a
motion for summary decision is made and supported, an adverse party in order to prevail
must by responding affidavit set forth specific facts showing that there is a genuine issue
which can only be determined in an evidentiary proceeding.” N.J.A.C. 1:1-12.5(b). “If the
opposing party offers no affidavits or matter in opposition, or only facts which are
immaterial or of an insubstantial nature, a mere scintilla, fanciful, frivolous, gauzy or
merely suspicious, he[/she] will not be heard to complain if the court grants summary
judgment.” Judson, 17 N.J. at 75 (internal quotation marks and citations omitted). When
the evidence “is so one-sided that one party must prevail as a matter of law,” the trial
court should not hesitate to grant summary judgment. Liberty Lobby, 477 U.S. at 252.
Having reviewed the parties’ submissions and heard their oral arguments, I
CONCLUDE that no genuine issues of material fact exist which require an evidentiary
hearing, and that this matter is therefore ripe for summary decision as to the alleged due
process issues.

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ABRA Due Process Requirements
The purpose of the ABRA is to promote “a safe and civil environment in school” by
preventing “conduct that disrupts both a student's ability to learn and a school’s ability to
educate its students in a safe environment.” N.J.S.A. 18A:37-13. It was promulgated “to
strengthen the standards and procedures for preventing, reporting, investigating, and
responding to incidents of [HIB] of students that occur in school and off school premises.”
N.J.S.A. 18A:37-13.1f. 	It requires all school districts to adopt policies “prohibiting
harassment, intimidation or bullying,” N.J.S.A. 18A:37-15a, and procedures for reporting
and investigating complaints of HIB, N.J.S.A. 18A:37-15b(5)-b(6).
[A] procedure for prompt investigation of reports of violations and complaints . . .
shall at a minimum provide that:
(a) 	the investigation shall be initiated by the principal or the
principal’s designee within one school day of the report of the
incident and shall be conducted by a school anti-bullying
specialist. 	The principal may appoint additional personnel
who are not school anti-bullying specialists to assist in the
investigation. 	The investigation shall be completed as soon
as possible, but not later than 10 school days from the date of
the written report of the incident of harassment, intimidation,
or bullying. 	In the event that there is information relative to
the investigation that is anticipated but not yet received by the
end of the 10-day period, the school anti-bullying specialist
may 	amend 	the 	original 	report 	of 	the 	results 	of 	the
investigation to reflect the information;
(b) 	the results of the investigation shall be reported to the
superintendent of schools within two school days of the
completion 	of 	the 	investigation, 	and 	in 	accordance 	with
regulations promulgated by the State Board of Education
pursuant to the “Administrative Procedure Act,” P.L.1968,
c.410 (C.52:14B-1 et seq.), the superintendent may decide to
provide intervention services, establish training programs to
reduce harassment, intimidation, or bullying and enhance
school climate, impose discipline, order counseling as a result
of the findings of the investigation, or take or recommend
other appropriate action;

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14
(c) 	the results of each investigation shall be reported to the
board of education no later than the date of the board of
education 	meeting 	next 	following 	the 	completion 	of 	the
investigation, along with information on any services provided,
training established, discipline imposed, or other action taken
or recommended by the superintendent;
(d) 	parents or guardians of the students who are parties to
the investigation shall be entitled to receive information about
the investigation, in accordance with federal and State law
and regulation, including the nature of 	the investigation,
whether 	the 	district 	found 	evidence 	of 	harassment,
intimidation, or bullying, or whether discipline was imposed or
services provided to address the incident of harassment,
intimidation, or bullying. This information shall be provided in
writing 	within 	5 	school 	days 	after 	the 	results 	of 	the
investigation are reported to the board. A parent or guardian
may request a hearing before the board after receiving the
information, and the hearing shall be held within 10 days of
the request. The board shall meet in executive session for the
hearing to protect the confidentiality of the students. At the
hearing the board may hear from the school anti-bullying
specialist about the incident, recommendations for discipline
or services, and any programs instituted to reduce such
incidents;
(e) at the next board of education meeting following its receipt
of the report, the board shall issue a decision, in writing, to
affirm, reject, or modify the superintendent’s decision. The
board’s decision may be appealed to the Commissioner of
Education, in accordance with the procedures set forth in law
and regulation, no later than 90 days after the issuance of the
board’s decision.
[(N.J.S.A. 18A:37-15b(6)(a)-(e)) (emphasis added).]
N.J.A.C. 6A:16-7.7 provides further instruction to aid school districts in complying
with statutory HIB requirements. The due process protections embodied in the law have
equal applicability where, as here, a teacher is a target of a HIB investigation. 	Young-
Edri, 2019 N.J. AGEN LEXIS 403 at 6; Gibble v. Bd. of Educ. of Hunterdon Cent. Reg’l
Sch. Dist., 2016 N.J. AGEN LEXIS 1108 at 8 (July13, 2016).

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The parties disagree about the import of N.J.S.A. 18A:37-15b(6)(d), with respect
to what discovery must be provided to a HIB investigation target prior to a board hearing.
That provision has been interpreted in two relatively recent decisions. 	In Young-Edri,
which was adopted by the Commissioner, a teacher accused of HIB conduct against a
student was not provided with the district AB[C]’s written report about the investigation,
which included information the teacher was unaware of, and was not conveyed in the
principal’s subsequent letter of reprimand. Young-Edri, 2019 N.J. AGEN LEXIS 403 at 3.
There 	was 	no 	evidence 	that 	the 	ABC’s 	findings 	were 	shared 	with 	either 	the
superintendent or the board, or that any investigatory materials were shared with Young-
Edri prior to her OAL appeal of the board’s determination that she had bullied the student.
Ibid. 	The superintendent did not render a decision about the bullying allegations and
investigation, even though the board was required to issue a written decision affirming,
rejecting, or modifying the superintendent’s decision. Id. at 6.
Persuaded by those facts and a similar fact pattern in J.L., No. A-2022-16T1, the
ALJ concluded that the board had violated Young-Edri’s due process rights embodied in
N.J.S.A. 18A:37-15b(6)(d)-(e), and remanded the matter to the board, ordering the board
to have the superintendent review the ABC’s determination, ordering that the results of
the ABC’s investigation be shared with the board, ordering that Young-Edri be supplied
with the investigatory file, including witness statements and the ABC’s written report, and
ordering that Young-Edri be permitted to present witnesses and documentary evidence
to the board at a subsequent hearing. Young-Edri, 2019 N.J. AGEN LEXIS 403 at 6-8.
In this case, a written summary of the ABC’s investigation was not provided to Sohl
until almost six months after the Board hearing, and that investigation report contains
information which was not conveyed in the Superintendent’s January 28, 2020 letter or
the Principal’s February 4, 2020 letter to Sohl, including the extent of G.T.’s statements,
how the alleged incident was initially reported to the Principal, by whom, and the names
and roles of other individuals involved in the process and potential student witnesses who
are alleged to have laughed at or frowned upon the alleged “cupcake” comment. (R-7).
Moreover, contrary to N.J.S.A. 18A:37-15b(6)(e), the Superintendent’s February 11, 2020

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16
letter simply notified Sohl that “the Board upheld your incident,” (R-6), when the Board
itself should have issued a written decision detailing 	with specificity the conduct it
determined to be HIB, based upon the Superintendent’s January 28, 2020 letter, which
does not describe the alleged conduct at all, (P-2 Ex. A). 	See Young-Edri, 2019 N.J.
AGEN LEXIS 403 at 3-4 (finding that Board’s letter notifying teacher that it upheld a HIB
determination “did not detail with specificity the conduct or incidents that were perceived
to have risen to a violation of law”).
Under these circumstances, I CONCLUDE that Sohl’s ABRA due process rights
were violated with respect to the mandates of N.J.S.A. 18A:37-15b(6), that this matter
should be remanded to the Board, and that Sohl should be given an opportunity to review
the ABC investigatory report and any and all available statements and other documentary
evidence within five school days after the results of the investigation are reported to the
Board. 	N.J.S.A. 18A:37-15b(6)(d). 	I further CONCLUDE that what appears to be the
Superintendent’s written summary to the Board, entitled “BHS HIB #7 Confirmed,” (R-7),
does not adequately inform the Board of the discipline imposed or the contents of the HIB
investigation report, and that the written investigation report “along with information on
any services provided, training established, discipline imposed, or other action taken or
recommended by the superintendent” is required to be provided to the Board pursuant to
N.J.S.A. 18A:37-15b(6)(c).
As to procedure at the Board hearing, I CONCLUDE there was no due process
violation with respect to an opportunity to confront and cross-examine G.T. or any other
witness. The ABRA does not require a full adversarial hearing, and only requires that it
be conducted in executive session and that “the board may hear from the anti-bullying
specialist about the incident, recommendations for discipline or services, and any
programs instituted to reduce such incidents.” 	N.J.S.A. 18A:37-15b(6)(d) (emphasis
added); Young-Edri, 2019 N.J. AGEN LEXIS 403 at 7-8. 	Thus, the ABC’s testimony is
not required by the ABRA, nor is the Superintendent’s. The purpose of the Board hearing
is to allow Sohl the opportunity to present her own witnesses, evidence, and arguments
in her defense against the charge and the discipline imposed. 	The Board need not

OAL DKT. NO. EDU 05070-20
17
present testimony by the accuser or any other witness, and Sohl would have no right to
confront or cross-examine such witnesses in any event. 	DeFalco, 2019 N.J. AGEN
LEXIS 515 at 7-8, 11-12, 26-27; L.K., 2019 N.J. AGEN LEXIS 62 at 59.
Should Sohl receive an unfavorable result after the Board hears this matter on
remand, she will then have an opportunity for a full adversarial hearing if she wishes to
appeal from the Board’s determination to the Commissioner. 	Young-Edri, 2019 N.J.
AGEN LEXIS 403 at 7 n.1.
ORDER
Based on the foregoing, it is ORDERED that Sohl’s motion for summary decision
is hereby GRANTED, and this matter is REMANDED to the Board to afford Sohl a HIB
hearing in keeping with her due process rights under N.J.S.A. 18A:37-15. This requires
that the February 4, 2020 letter of reprimand be removed from Sohl’s personnel file, that
the Superintendent comply with the mandates of N.J.S.A. 18A:37-15b(6)(c), that the
Board provide Sohl with the investigatory file, including all witness statements, the ABC
report, and all other documentary evidence, in keeping with N.J.S.A. 18A:37-15b(6)(d)
and J.L., No. A-2022-16T1, that Sohl be permitted to present witnesses and evidence at
the hearing, and that the Board, not the Superintendent, issue a detailed written decision
after the hearing, in keeping with N.J.S.A. 18A:37-15b(6)(e) and Young-Edri, 2019 N.J.
AGEN LEXIS 403 at 3-4.
I 	hereby 	FILE 	this 	initial 	decision 	with 	the 	COMMISSIONER 	OF 	THE
DEPARTMENT OF EDUCATION for consideration.
This 	recommended 	decision 	may 	be 	adopted, 	modified 	or 	rejected 	by 	the
COMMISSIONER OF THE DEPARTMENT OF EDUCATION, who by law is authorized
to make a final decision in this matter. 	If the Commissioner of the Department of
Education does not adopt, modify or reject this decision within forty-five days and unless

OAL DKT. NO. EDU 05070-20
18
such time limit is otherwise extended, this recommended decision shall become a final
decision in accordance with N.J.S.A. 52:14B-10.
Within thirteen days from the date on which this recommended decision was
mailed to the parties, any party may file written exceptions with the COMMISSIONER OF
THE DEPARTMENT OF EDUCATION, ATTN: 	BUREAU OF CONTROVERSIES AND
DISPUTES, 100 Riverview Plaza, 4th Floor, PO Box 500, Trenton, New Jersey 08625-
0500, marked “Attention: 	Exceptions.” 	A copy of any exceptions must be sent to the
judge and to the other parties.
February 24, 2021
DATE 	SARAH H. SURGENT, ALJ
Date Received at Agency:
Date Mailed to Parties:
jb

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APPENDIX
EXHIBITS
For the Judge:
C-1 	EDU 05070-20 May 20, 2020 Transmittal from Department of Education
Office of Controversies and Disputes
C-2 	J.L. v. Bd. of Educ., No. A-2022-16T1 (App. Div. Oct. 16, 2018),
https://njlaw.rutgers.edu/collections/courts/appellate/a2022-16.opn.html
For Petitioner:
P-1 	Petitioner’s Petition of Appeal and Exhibits A-D dated April 30, 2020
P-2 	Petitioner’s motion brief, Exhibits A-D, and certifications of Alonso and Sohl
dated August 14, 2020
P-3 	Petitioner’s reply brief and Exhibit A dated September 4, 2020
For Respondent:
R-1 	Respondent’s Answer to Petition of Appeal dated May 19, 2020
R-2 	Respondent’s letter to this Tribunal dated August 14, 2020
R-3 	Respondent’s opposition brief dated August 28, 2020
R-4 	Certification of Judy Sorochynskyj and Exhibit A in support of Respondent’s
opposition dated August 28, 2020
R-5 	Letter from Superintendent to Alonso dated February 6, 2020
R-6 	Letter from Superintendent to Sohl dated February 11, 2020
R-7 	Documents produced by Board to Alonso on August 4, 2020
R-8 	Email from Board dated February 4, 2020 with attached Student Safety
Data System (SSDS) Incident Report Form dated January 27, 2020