Charles Avallone v. Board of Education of the City of Hackensack, Bergen County, 3/15/2021, (#58-21)

58-21
New Jersey Commissioner of Education
Final Decision
Charles Avellone,
Petitioner,
v.
Board of Education of the City of
Hackensack, Bergen County,
Respondent.
Synopsis
In 	June 	2020, 	petitioner 	filed 	an 	appeal 	asserting 	that 	the 	respondent 	Board 	violated
N.J.S.A. 18A:20-34 by improperly granting the use of school premises from April 2020 through
August 2020, free of charge, to a private condominium association. Specifically, on June 15, 2020,
the Board passed a resolution permitting residents of Devonshire Condominium Association
(Devonshire) to use the Hackensack High School parking lots during a period of construction on
Devonshire’s parking area. This agreement coincided with a period of remote educational services
at the high school because of the Covid-19 epidemic. Petitioner sought to set aside the parking
agreement with Devonshire, contending that political corruption on the part of members of the
Board of Trustees had led to the grant of improper use. The Board denied petitioner’s allegations.
The parties filed cross motions for summary decision.
Upon review, the ALJ found, inter alia, that: there are no material facts at issue in this case, and
the matter is ripe for summary decision; N.J.S.A. 18A:20-34 confers wide discretion on the Board
regarding community use of its facilities; the Board did not violate its policy for use of school facilities
by outside groups when it allowed the condominium association to use the parking lots for free while
they were not in regular use by the school community during the Covid-19 epidemic; authorizing such
use did not interfere with the orderly conduct of a thorough and efficient system of education; such
use is contemplated by N.J.S.A. 18A:20-34(c) and the Board’s Policy 7510; the Board’s granting
of this use was not arbitrary, capricious or unreasonable; and, further, any allegations of violation
of the School Ethics Act by members of the Board must be initiated by filing a complaint with the
School Ethics Commission, and petitioner has not filed such a complaint. 	Accordingly, the ALJ
granted the Board’s motion for summary decision, and the matter was dismissed.
Upon review, the Commissioner, inter alia, concurred with the ALJ that the petition must be
dismissed for the reasons well detailed in the Initial Decision. Accordingly, the Initial Decision
of the OAL was adopted as the final decision in this matter, and the petition was dismissed.
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.
March 15, 2021

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OAL Dkt. No. EDU 06749-20
Agency Dkt. No. 145-6/20
New Jersey Commissioner of Education
Final Decision
Charles Avallone,
Petitioner,
v.
Board of Education of the City of
Hackensack, Bergen County,
Respondent.
The record of this matter and the Initial Decision of the Office of Administrative Law
(OAL) have been reviewed and considered. The parties did not file exceptions.
Petitioner in this matter alleges that the Board violated N.J.S.A. 18A:20-34 and its own
policy when it allowed residents of a local condominium association to use the parking lots at
Hackensack High School at no cost when the school was operating remotely due to the Covid-19
pandemic. 	The Administrative Law Judge (ALJ) granted the Board’s motion for summary decision,
finding that N.J.S.A. 18A:20-34 confers wide discretion on the Board regarding community use of its
facilities, and that the Board did not violate its policy by allowing the condominium association to use
the parking lots for free. The ALJ further noted that any allegation of violations of the School Ethics
Act by members of the Board must be initiated by filing a complaint with the School Ethics
Commission, and that petitioner had not filed any such complaint.

3
Upon review, the Commissioner concurs with the ALJ that summary judgment is
appropriate and that the Board’s actions did not violate the statute or its policies, for the reasons
thoroughly detailed in the Initial Decision.
Accordingly, the Initial Decision of the OAL is adopted as the final decision in this
matter and the petition is hereby dismissed.
IT IS SO ORDERED.1
ACTING COMMISSIONER OF EDUCATION
Date of Decision: 	March 15, 2021
Date of Mailing: 	March 16, 2021
1 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.

New Jersey is an Equal Opportunity Employer
State of New Jersey
OFFICE OF ADMINISTRATIVE LAW
INITIAL DECISION
SUMMARY DECISION
OAL DKT. NO. EDU 06749-20
AGENCY DKT. NO.
CHARLES AVALLONE,
Petitioner,
v.
CITY OF HACKENSACK BOARD OF EDUCATION,
BERGEN COUNTY,
Respondent.
___________________________________
Richard Salkin, Esq. appearing on behalf of petitioner
Ashfan Ajmiri Giner, Esq. appearing on behalf of respondent (Florio, Perrucci,
Steinhardt, Cappelli, Tipton & Taylor, LLC, attorneys)
Record Closed: January 12, 2021 	Decided: January 29, 2021
BEFORE NANCI G. STOKES, ALJ:
STATEMENT OF THE CASE
The Hackensack School District (District) allowed Devonshire Condominium
Association (Devonshire) residents to use the Hackensack High School (HHS) parking lot
at no cost during remote educational services because of the COVID-19 pandemic. Did
those actions violate N.J.S.A. 18:20-34? 	No. The Hackensack Board of Education
(Board) adopted rules authorizing the use of school premises by community organizations
when not in use for school purposes with a fee schedule identifying no user fees for
parking areas.

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2
PROCEDURAL HISTORY
On June 19, 2020, petitioner filed a Verified Petition with the Commissioner of
Education (Commissioner) asserting that the Board violated N.J.S.A 18A:20-34 by
improperly granting school premises use from April 2020 through August 2020, without
cost, to a private condominium association. 	Specifically, on June 15, 2020, the Board
passed a resolution permitting Devonshire residents to use the HHS parking lots during
Devonshire’s parking area construction. Petitioner also maintains that political corruption
led to the grant of improper use.
Petitioner seeks to set aside the June 15, 2020, resolution or any other agreement
allowing Devonshire’s use of school parking lots as “null and void.”
On 	July 	14, 	2020, 	the 	District 	answered 	the 	petition 	denying 	petitioner’s
allegations.
On July 15, 2020, the Department of Education (DOE) transmitted this case to the
Office of Administrative Law, as a contested case under the Administrative Procedure
Act, N.J.S.A. 52:14B-1 to-15, and the act establishing the OAL, N.J.S.A. 52:14F-1 to-13,
for a hearing under the Uniform Administrative Procedure Rules, N.J.A.C. 1:1-1.1 to -
21.6.
On August 26, 2020, I held a pre-hearing conference and established a discovery
schedule.
On October 8, 2020, I held a status conference during which the parties agreed
that the material facts were undisputed, and no hearing was necessary to resolve the
legal issue presented.
On December 15, 2020, petitioner filed a motion for summary decision.

OAL DKT. NO. EDU 06749-20
3
On January 4, 2021, the District opposed petitioner’s application. 	The District’s
opposition will be considered a cross-motion because the District seeks summary
decision in its favor dismissing the petitioner’s appeal.
On January 12, 2021, petitioner replied, and I closed the record.
FINDINGS OF FACT
Based on the documents submitted in support of and opposition to the motion and
cross-motion for summary decision, and when viewed in the light most favorable to the
non-moving party, I FIND the following as FACT for purposes of these motions only:
Petitioner resides in Hackensack, New Jersey. Devonshire is also in Hackensack,
close to the HHS.
Three Board members selected in the 2019 and 2020 Board elections ran as
“Hackensack Smart Schools, Inc.” (Smart School) candidates. 	After the April 21, 2020,
election, Smart School members constituted a majority of the Board.
On April 26, 2019, Smart Schools filed a Receipts and Expenditures Quarterly
Report with the New Jersey Election Law Enforcement Commission (ELEC), noting that
Devonshire residents provided $4000 of the $11,500 in campaign contributions.
In the spring of 2020, the District transitioned to remote learning due to the COVID-
19 pandemic. During this time, HHS students and staff members did not use the parking
lot for academic purposes.
On March 18, 2020, the District administratively approved Devonshire’s request to
use the HHS parking lot while HHS students and staff were not regularly parking in the
lot. At this time, Devonshire’s parking area was under construction.
The District uses an online system to schedule events at its school and facilities,
and a Devonshire resident completed the “event” request describing it as a “rental of [sic]

OAL DKT. NO. EDU 06749-20
4
parking lot” at the HHS. The event application also included insurance information noting
liability insurance of $1,000,000 and sought the use of 40 parking spots.
The Devonshire resident completing the “event” request was an unsuccessful
Smart Schools Board candidate and a contributor to the Smart Schools campaign.
On June 15, 2020, the Board held its regularly scheduled meeting and approved
Resolution E-1 that authorized Devonshire residents to use the parking lot at the HHS
from April 1 until August 30, 2020. 	No Smart Schools Board member voting in favor of
Resolution E-1 resides at Devonshire. 	Although petitioner was virtually present at the
meeting, the Board did not answer his questions concerning Devonshire’s use fees.
Board Policy 7510 (Policy 7510) addresses the use of school facilities. Policy 7510
acknowledges that the facilities belong to the community that paid for them and permits
facility use outside of school operating schedules by community organizations and others
when it “does not interfere with the orderly conduct of a thorough and efficient system of
education.”
Regulation 7510 establishes a “Tier” system that sets conditions for facility use by
individuals or organizations, including service or rental fees, and which entity bears the
cost of custodial and operational services. 	Any request requires the organization to
assume liability for damage to school property and maintain insurance in an amount not
less than $50,000.
Notably, Regulation 7510 only identifies hourly fees for using specific school
facilities, not parking lots. Regulation 7510 considers Tier II use for “divisions of the local
municipal governments, local public school district, local nonpublic schools and regular
meetings of the local community groups, or other approved community groups.”
Section F of Regulation 7510, “Fees,” states that the District only charges a Tier II
organization to use the HHS football field with lights, the weight room with supervision,
the pool, and custodian services. A Tier II organization’s use of all other school facilities
involves no charge, including the gym, cafeteria, classrooms, and auditorium. 	Regulation

OAL DKT. NO. EDU 06749-20
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7510 permits the Board to waive fees if the applicant submits a written request before the
date of use.
The District grants Tier I free use of school facilities for all school clubs and groups,
parent associations, meetings of the particular school, and Scouts.
Tier III encompasses use for fund-raising or other events sponsored by local
community groups and educationally oriented associations. Tier IV comprises any private
interest group not directly or indirectly related to Hackensack Schools or any organization
or individual “outside the community.” Tier III and IV require various fees.
The “school business administrator/Board Secretary” is authorized to approve and
schedule the use of school facilities.
The District considered Devonshire a “Tier II” user not required to pay for the use
of the parking lot; the District did not charge Devonshire.
However, the District charged church groups, the Wheelchair Sports Federation,
the Bergen County Coaches Association, and another county high school to use school
facilities.
In June 2020, Beechwood Heights and Stratford House, two other Hackensack
condominium associations, also sought to use the parking lots. 	Yet, the District did not
approve the requests.
DISCUSSION AND CONCLUSIONS OF LAW
Summary Decision Standard
A party may move for summary decision upon all or any of the substantive issues in a contested
case. N.J.A.C. 1:1-12.5(a). The motion shall be served with briefs, with or without affidavits. When the filed
papers and discovery, together with any affidavits, show that no genuine issue of material fact exists and
that the moving party is entitled to prevail as a matter of law, the judge may grant the motion. N.J.A.C. 1:1-
12.5(b). When such a motion is made and supported, an adverse party, to prevail, must submit an affidavit

OAL DKT. NO. EDU 06749-20
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setting forth specific facts showing that a genuine issue of material fact exists that can only be determined
in an evidentiary proceeding. Ibid.
Even though a statute calls for a “hearing,” a motion for summary decision supported by
documentary evidence where the objector submits no evidence to demonstrate that a genuine issue of
material fact exists, the motion procedure constitutes the hearing, and no trial-type hearing is
necessary. Contini v. Newark Bd. of Educ., 286 N.J. Super. 106, 120-21 (App. Div. 1995), certif. denied,
145 N.J. 372 (1996).
To determine whether a genuine issue of material fact exists that precludes summary judgment,
the motion judge must consider whether the competent evidential materials presented, when viewed in the
light most favorable to the non-moving party, are sufficient to demonstrate that the moving party is entitled
to a judgment as a matter of law. Brill v. Guardian Life Ins., 142 N.J. 520, 540 (1995).
Moreover, even if the non-movant comes forward with some evidence, the court must grant
summary judgment if the evidence is “so one-sided that [movant] must prevail as a matter of law.” Ibid. at
536. If the non-moving party’s evidence is “merely colorable or is not significantly probative,” the judge
should not deny summary judgment. Bowles v. City of Camden, 993 F. Supp. 255, 261 (D.N.J. 1998).
In this case, no genuine issue as to the material facts exists; the only question
presented is whether the District’s and Board’s actions violated N.J.S.A. 18A:20-34 and
established policies and regulations for the use of school facilities. 	More pointedly, no
genuine issue exists that the District allowed Devonshire residents to use the HHS’s
parking lot without cost when the staff members and students could not use the areas for
educational 	purposes. 	Also, 	evidence 	supports 	that 	many 	Devonshire 	residents
contributed to the Smart Schools Board candidate campaigns that hold a majority on the
Board. Moreover, the District later denied the parking requests of other similarly situated
condominium associations. 	Since these facts are clear and undisputed, I CONCLUDE
that this case is ripe for summary decision.
Alleged Board Misconduct
Initially, the Board maintains that the Commissioner does not have jurisdiction over any dispute
relating to school board elections and improper political conduct. Under N.J.A.C. 1:1-3.2, the OAL’s
statutory authority to hear contested cases is derivative from the agency that is empowered to hear and

OAL DKT. NO. EDU 06749-20
7
determine the issue. Thus, the OAL has jurisdiction over the case if the Commissioner has jurisdiction over
the case and transmits it to the OAL.
Under N.J.S.A. 18A:6-9, the Commissioner’s jurisdiction is defined, and is limited to “controversies
and disputes arising under the school laws.” In Dunellen Bd. of Educ. v. Dunellen Ed. Assoc., 64 N.J. 17,
23 (1973), the New Jersey Supreme Court concluded that “the Legislature enacted provisions entrusting
school supervision and management to local school boards . . . subject to the supervisory control [of] . . .
the State Commissioner of Education.”
However, “[t]he sweep of the Department’s interest and the Commissioner’s jurisdiction does not
extend to all matters involving boards of education.” Archway Programs v Pemberton Twp. Bd. of Educ.,
352 N.J. Super. 420, 424-25 (App. Div. 2002). Significantly. N.J.S.A. 18A:6-9 states that “controversies and
disputes concerning the conduct of school elections shall not be deemed to arise under the school laws.”
See N.J.S.A. 19:1-1 (‘“Election” means the procedure whereby the electors of this State or any political
subdivision thereof elect persons to fill public office or pass on public questions.”).
Yet, petitioner does not assert Devonshire residents improperly contributed to the board member
campaigns or that Smart Schools candidates failed to report those contributions requiring petitioners to
present their claims to ELEC. See N.J.S.A. 19:44A-5, 44B-7 (ELEC charged with enforcing violations of
the New Jersey Campaign Contributions and Expenditures Reporting Act, N.J.S.A. 19:44A-1 to -47, and
candidate financial disclosure requirements under N.J.S.A. 19:44B-1 to -10).
Irrespective, petitioner asserts Board members acted in a manner favoring political supporters, e.g.,
Smart School Board members have a conflict of interest. Alleged unethical actions by Board members fall
under the jurisdiction of the School Ethics Commission (SEC). The Legislature passed the School Ethics
Act in 1991. See L.1991 c. 393 § 7. The Legislature later amended the Act to include a separate Code of
Ethics. See L. 2001 c. 178 § 5. As written, the Act is a conflict of interest statute, which addresses
“prohibited acts,” while the Code is an ethics code, which lists “affirmative duties.” See L. 2001 c. 178 § 5.
Under N.J.S.A. 18A:12-27, the Legislature established the SEC within the Department of Education
to enforce those ethical standards guiding school officials through a procedure for reviewing ethical
violations 	and 	investigating 	those 	complaints 	and 	ultimately rendering 	recommendations 	to 	the
Commissioner as to the imposition of sanctions when demonstrating violations occurred. N.J.A.C. 6A:28-
1.1(b).
Under the Act, the SEC must first determine whether sufficient probable cause exists to credit the
allegations in the complaint against a school official. N.J.A.C. 6A:28-10.7(b)(1). 	Significantly, under

OAL DKT. NO. EDU 06749-20
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N.J.A.C. 6A:28-10.7(c)2, OAL proceedings are limited to those allegations in which the SEC has found
probable cause. 	Yet, petitioner did not bring his complaints to the SEC, and there has been no SEC
determination of “probable cause” or SEC transmittal to the OAL.
Therefore, I CONCLUDE that the Board’s alleged unethical conduct in passing Resolution E-1
granting Devonshire use of school premises is not properly before the OAL.
Use of School Facilities
Instead, the issue is whether the District or Board violated N.J.S.A. 18A:20-34 or the District’s policy
and regulation implemented under the statute. A presumption of lawfulness and good faith applies to a
board of education's actions. In challenges to board actions, the challenger bears the burden of proving
that such acts were unlawful, arbitrary, capricious, or unreasonable. Schuster v. Bd. of Educ. Montgomery
Twp., 96 N.J.A.R.2d (EDU) 670, 676 (citing Schnick v. Westwood Ed. of Educ., 60 N.J. Super. 448 (App.
Div. 1960), and Quinlan v. Bd. of Educ. of North Bergen Twp., 73 N.J. Super. 40 (App. Div. 1962).
In enacting N.J.S.A. 18A:20-34, the Legislature recognized that schools may use their premises for
additional lawful purposes when not needed for education. For example, the statute enumerates certain
suitable functions, including use as polling places, lecture halls, gathering places for civic, social, artistic,
entertainment purposes, or public libraries. However, under N.J.S.A. 18A:20-34(c), a board may also allow
the use of school property and grounds “for such other purposes as may be approved by the board.”
Moreover, these activities may produce revenue for the school district. Courts will afford the Legislature’s
chosen 	language 	its 	natural 	meaning 	when 	no 	ambiguity, 	or 	competing 	intentions, 	is
presented. See, e.g., Merin v. Maglaki, 126 N.J. 430 (1992).
N.J.S.A. 18A:20-34 confers discretion on school boards to respond to the community’s needs for
its facilities. Resnick v. East Brunswick Twp. Bd. of Educ., 77 N.J. 88, 99 (1978). In Resnick, the New
Jersey Supreme Court approved the temporary use of school property for religious purposes, though the
statute makes no mention of worship services. Id. at 102. The lack of strict limitations and only minimum
guidelines demonstrate the statutory discretion afforded boards of education: when not in use for school
purposes and when permitted according to the board’s rules. Id. at 98–100.
Building on Resnick, the Board maintains that N.J.S.A. 18A:20-34 encompasses various functions,
both stated and implied. The Board highlights that nothing in the statute or in Policy and Regulation 7510
precludes Devonshire’s use of the parking area. Indeed, as permitted by N.J.S.A. 18A:20-34, the Board
adopted rules long before this dispute determining the manner in “which school properties may be used
when not in use for school purposes.” Id. at 98.

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9
Notably, Policy and Regulation 7510 do not generally require Board action to approve and schedule
the use of school facilities, and Policy 7510 allows submission to the Board when the “Business
Administrator deems it advisable.” Initially, the District administratively approved Devonshire’s request and
later submitted the application to the Board via Resolution E-1.
Petitioner asserts that section (c) requires any allowed activities permit “group interaction,
emotional 	lease, 	regular 	participation 	of 	a 	portion 	of 	the 	community, 	and 	character 	building.”
While Resnick discusses these factors likening worship services to “social, civic, and recreational meetings
and entertainments,” an activity need not demonstrate such traits for approval. 	Id. at 99–100. 	Indeed,
contrary to petitioner’s position, the New Jersey Supreme Court explained that the language “other
purposes as may be approved by the board” intends no such limitations:
Had N.J.S.A. 18A:20-34(c) merely provided for “civic, educational and
recreational” use, the legislative intent might aptly be termed as limiting
the use of school premises exclusively to those terms listed. However,
such a construction would render the following phrase, “and such other
uses as may be approved by the board,” meaningless. Moreover, the
absence of a qualifying term such as “like,” “similar” or “related,” with
respect to the above phrase, indicates that the legislature intended to grant
wide discretion to boards of education in such matters. Thus, additional
uses are not strictly limited to civic, social and recreational uses. . . . the
object of [N.J.S.A. 18A:20-34] was merely to entrust to local school
boards, within certain guidelines, the determination of the uses beyond the
purely educational to which school property might be devoted.
[Id. at 99–100. (emphasis added).]
Undeniably, Devonshire is a community organization that requested to use the parking lot during
construction on its parking area when the school did not require its use. Therefore, I CONCLUDE that
authorizing such use “did not interfere with the orderly conduct of a thorough and efficient system of
education,” and that such use is contemplated by N.J.S.A. 18A:20-34(c) and Policy 7510.
Devonshire is not outside the community, did not fund-raise, sponsor an event, or use the facilities
for profit; Tiers III and IV are not applicable. Devonshire is not a school club, Scout group, or related to
school activities, making it ineligible for Tier I classification. Instead, I CONCLUDE that Devonshire is a
community group correctly categorized as a Tier II user.
Regulation 7510 lists a schedule of fees for using various school facilities but does not identify a
separate fee for just parking lot use. Tier II users can utilize most school facilities without payment. Indeed,
Devonshire did not request any school area designated for user fees and also supplied insurance

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10
information on its application. Therefore, I CONCLUDE that Regulation 7510 permits the District and Board
to authorize Devonshire’s use of the HHS parking lot at no cost.
Petitioner correctly notes that the District charged other organizations but did not demonstrate that
those fees were improper. Initially, fees are permitted for organizations “outside the community” or events
of educationally oriented associations such as a high school from another school district. Regardless,
petitioner fails to demonstrate that the charged groups were outside of Tier II, III or IV uses requiring fees,
identifying the school areas used by the charged groups, or providing the events’ nature for which the
District charged fees. Yet, because Devonshire did not request to use any school facilities requiring fees,
I CONCLUDE that the distinction between charged groups and Devonshire is immaterial.
Moreover, petitioner provides little evidence regarding Beechwood Height’s and Stratford House's
parking area requests to buttress his position. Beechwood Heights Condominium made a facilities’ use
request on June 17, 2020, after the March 18, 2020, administrative approval, and the Board’s resolution
passed on June 15, 2020. Petitioner also relies upon a July 14, 2020, email exchange between District
personnel to demonstrate that Stratford House also made a parking lot use request. Yet, the email notes
that the requests of Beechwood Heights and Stratford House were about “ a month ago.” In other words,
the District received other requests after the District and Board allowed Devonshire residents to use the
HHS parking lots. Despite petitioner’s suggestion that the Board improperly favored Devonshire over the
other condominium associations, the evidence supports that the other condominium associations' requests
came after Devonshire obtained approval to use the HHS parking lot.
Therefore, I CONCLUDE that the evidence supports that neither the administrative approval of
Devonshire’s parking request nor Resolution E-1 violated Policy and Regulation 7510 or N.J.S.A. 18A:20-
34(c), or that these actions were unreasonable or arbitrary.
ORDER
Given my findings of fact and conclusions of law, I ORDER that petitioner’s motion for summary
decision is DENIED and that the Board’s cross-motion for summary decision is GRANTED. 	Further, I
ORDER that petitioner’s appeal is DISMISSED.
I 	hereby 	FILE 	this 	initial 	decision 	with 	the 	COMMISSIONER 	OF 	THE
DEPARTMENT OF EDUCATION for consideration.

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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
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.
January 29, 2021
DATE 	NANCI G. STOKES, ALJ
Date Received at Agency: 	January 29, 2021
Date Mailed to Parties: 	January 29, 2021
ljb