Richard Milburn Public Charter Alternative High School v. Cafritz; World Public Charter School, Inc. v. District of Columbia Board of Education

Summary

The District of Columbia Court of Appeals considered whether public charter schools were entitled to a trial-type contested case hearing before their charters were revoked. The court held that neither the District of Columbia Administrative Procedures Act nor the Fifth Amendment required such a hearing, concluding that the School Reform Act's provision for an informal hearing was sufficient.

Holdings

1. The District of Columbia Administrative Procedures Act does not itself create a right to a contested case hearing; under the statutory definition, that right must arise from another law or from the Constitution.
2. The School Reform Act requires an informal hearing, not a trial-type contested case hearing, before final revocation of a public charter school charter.
3. The Fifth Amendment does not require a trial-type contested case hearing before the Board finally revokes a public charter school charter when the school receives notice and a meaningful informal opportunity to present oral and written arguments and evidence, followed by judicial review.

Questions Presented

1. Whether the District of Columbia Administrative Procedures Act required the Board to provide a trial-type contested case hearing before revoking the charter schools' charters.
2. Whether the School Reform Act required a trial-type contested case hearing rather than the informal hearing specified in the statute.
3. Whether the Fifth Amendment's procedural due process guarantee required a trial-type contested case hearing before final charter revocation.

Disposition

affirmed