Wednesday, March 25, 2015

Title VI Complaints against Dallas ISD Filed 3-25-15 with the Federal Department of Education

The story around this complaint was covered on Channel 8 news the evening of 3-24-15:

This was an unusually detailed news story with good information on finding the data online.

There is a noon news conference on 3-25-15 in suite 520 at 6500 Greenville in Dallas.  We are presenting this complaint to the public, signing it, and then taking it to the U.S. Department of Education this afternoon.  

Here is the complaint being filed, linked here in pdf format, and below:

Title VI Complaints Filed with the Federal Education Department, Dallas, Texas
Against Dallas Independent School District (DISD)
March 25, 2015
“Education is the great equalizer—it should be used to level the playing field, not grow inequality. That means all students regardless of their race, zip code or family income should have equal access to education resources---whether it’s effective teaching, challenging coursework, facilities with modern technology or a safe school environment.” Arne Duncan, October 1, 2014

Dallas ISD, through its policy of using a Title I comparability formula based on teacher staffing, has increased inequities in regular education funding of Dallas public classrooms and disproportionately negatively impacted at-risk, special education (SPED), Limited English Proficiency (LEP), minority, and low income students on its Title I campuses. The huge disparities in equal access, accompanied by illegal supplanting of federal and state dollars, egregious lowering  of regular education funding, teacher and principal staffing patterns, lack of comparability of student services and safety on campuses, lack of effective special education services, lack of access to certain magnet school programs, discrimination in hiring practices that directly impact equal protection guarantees of students, lack of research-based professional development and support for teachers in failing schools, and unequal access to safe schools, all document unconstitutional sourcing between Title I and non-Title I schools.

The harm to at-risk, SPED, LEP, and low income and minority children in Dallas ISD was demonstrated by a 58% increase at the end of the 2013-2014 school year of Dallas ISD schools on the annual the Texas PEG List of failing campuses and is demonstrated through campus climate surveys demonstrating inequities in safe schools. PEIMS documents detailing inequities in funding and illegal supplanting of federal funds are available on the Texas Education Agency (TEA) web site, .  Teacher staffing patterns which dump the least qualified teachers into the most vulnerable schools are available for public view on the MyDataPortal designed by Dallas ISD, . The violation of federal law is apparent in Dallas ISD central staffing patterns through resumes of the central leadership hired compared to better qualified candidates who applied for central administrative positions. These employment decisions violate the equal protection rights of both job seekers and students in Dallas ISD who are negatively impacted by a lack of credentials and experience in central administrative staff.

The inequities in access to comparable levels of principal leadership was demonstrated in the last round of principal appraisals that identified only principals in magnet, vanguard, and early college campuses as the most effective. The use of a Teacher Excellence Initiative (TEI) which ties annual teacher compensation directly to easily manipulated less than objective spot observations and student test scores violates the equal protection rights of students by increasing high rates of teacher churn on the campuses of Dallas ISD’s lowest performing campuses and demonstrates the lack of validity of a teacher compensation tool that is correlated to student demographics, effectively rewarding the teachers who teach the most motivated, competent and best-served students in the district.

Finally, in a school district that is currently blatantly violating federal laws regarding use of Title I funding and is grossly underfunding its Title I campuses, the proposal for choice schools promises to further segregate at-risk, LEP, and SPED students on failing campuses while continuing lack of appropriate resourcing to serve these students.

Complainants ask for immediate relief from both the serious inequities in regular education funding on Title I campuses and relief from discriminatory hiring patterns which negatively impact student achievement.  They ask for federal investigations into the lack of appropriate special education services which directly impact campus safety and racial disparities in student suspensions and adequate education provided by DISD for equal access to magnet school programs by DISD where some schools have a majority of students who did not attend DISD.  , support rather than overtly punitive conduct toward teachers on failing campuses rated Improvement Required, a suspension of the current principal rating rubric, a suspension of the Teacher Excellence Initiative, and a suspension of discussion of choice schools until gross, illegal and unconstitutional inequities in sourcing of Dallas ISD campuses and students are corrected.


An Overview of Regular Education Sourcing and Supplemental Federal Dollars

Regular education dollars, by law, must be sufficient to fund the required Texas learning standards and required academic core classes at each grade for Texas public schools. Title I, special education dollars, compensatory education dollars, School Improvement Grants (SIG), and bilingual dollars may not supplant the necessary regular education dollars provided by local and state governments for the purpose of teaching the TEKS and required classes for graduation.

An examination of PEIMS records documenting the planned campus budgets for 2013-2014 for Dallas Independent School District shows a systematic lowering of regular education dollars on most Title I campuses compared to a neighboring school district with Title I campuses and similar revenue and student demographics. The few DISD non-Title I elementary neighborhood campuses had some of the highest amounts of regular education dollars allotted to them.

An examination of PEIMS records also documents egregious, illegal supplanting of federal Title I dollars on several Dallas public schools campuses. There is also a pattern at some magnet schools of loading in athletic funding while removing operational costs in order to circumvent Title I comparability laws. There is no evidence that any of these back-room machinations were shared in open sessions with the Board of Trustees or with parents.


Federal and State Funding for Special Needs Students

Special needs students have several state and federal funding allotments that must be used only to supplement the local and state regular education funding provided through the foundation program provided by the state of Texas. It is a violation of state and federal law to use funding for special needs students (SPED, LEP, Title monies, compensatory education monies) to supplant (replace) local education dollars.

The regular education program required for each grade and high school must be paid for by local and state foundation dollars. Those dollars cannot be replaced or supplanted by federal  education funding. State compensatory education (SCE) funding also cannot be used to supplant regular education funding.

Federal funding is included in Title programs and dollars, Career and Technical (CTE) courses, Limited English Proficiency (LEP) funding, services for special education students and services for migrant students.[1] All public school administrators are trained on federal laws regarding supplementing rather than supplanting federal dollars for required state dollars to meet state requirements.

Dallas ISD receives over 100 million dollars a year in Title monies and around $154 million a year in state compensatory aid in addition to millions in special education and bilingual funds.

The amount of local and state funding provided for each school in regular education dollars by central administrators in Dallas ISD can be found on the TEA web site in the area where Public Education Information System (PEIMS) records are posted for both school districts and campuses:

These PEIMS documents report how local, state, and federal monies are budgeted and spent by school districts. Most of the time, these campus budgets are determined by central administration, not by campus principals. PEIMS records are official government documents. The TEA web site provides a high level of transparency on actual campus spending patterns. This high level of transparency is sometimes completely different than the overviews of campus budgets provided to the DISD Board of Trustees.

Federal funding flows through the Texas Education Agency which disperses funding to individual public school districts including charter schools in Texas. Superintendents and central staff make determinations regarding campus budgets which are presented to the Board of Trustees.

E-mail requests of Dallas ISD Trustees regarding potential issues regarding Title funding and campus budgets indicate Trustees are unaware of potential illegal and unconstitutional funding patterns within Dallas ISD because information they receive from central staff does not match actual PEIMS records of campus revenue or spending. Annual campus and district budgets presented to the Trustees also obscured illegal and unconstitutional patterns of campus allocations.

Central administrators chose a Title I comparability model based on teacher staffing numbers, rather than dollars spent on campuses, to reach comparability before Title I monies were added to campuses. This Title I comparability model has reached a zenith of unconstitutional inequities in Title I campus sourcing compared to non-Title I sourcing and hides gross supplanting of Title I dollars on Title I campuses and hidden back loading of funds from Title I campuses onto magnet and Early College campuses. There is evidence of supplanting of Title I funds, supplanting of School Improvement Grants, supplanting of special education money, and consistent lowering of regular education funding in both planned and audited PEIMS records for Title I campuses in Dallas ISD. All of these practices are illegal and have increased in the last few years as funding for the Superintendent’s special projects came on line and as huge sums were added to the surplus budget.

Financial Model of Inequity and Violation of State and Federal Laws

As will be demonstrated through a comparison of PEIMS records for Title I and non-Title I campuses and comparisons of magnet schools to IR neighborhood schools, the Dallas ISD campus sourcing model for Title I comparability is severely flawed and gives an illegal and unconstitutional disadvantage to campuses with high enrollments of LEP, SPED, and at-risk Title I students because of the consistent practice of DISD central financial managers of lowering regular education funding when federal dollars are available for Title I, special education services, LEP services, CTE, and other federal funds such as School Improvement Grants (SIG).

Many other violations of student equal protection guarantees, such as teacher and principal staffing and programming, may stem from the Dallas ISD illegal and unconstitutional campus sourcing model or may magnify the inequities of a rigged financial model.

 By skimming regular education funding from Title I campuses, regular education dollars were available to rapidly scale the Dallas ISD surplus fund to historic highs. Since Dallas ISD is such a large school district with a majority of Title I campuses, skimming even hundreds of dollars per student from regular education funding provides huge sums of local and state tax monies that can be moved to increased overhead at the central administrative level, to build the surplus fund for the district, and to fund special projects of the Superintendent. Through PEIMS records for planned campus budgets for 2013-2014, it is evident that some Title I campuses were low $1,000 a student or more in regular education funding compared either to non-Title I campuses, to the magnet schools, or to similar Title I campuses in a bordering school district.

An examination of audited PEIMS records for campus spending will indicate that the historically high surplus budget for Dallas ISD may have its source in supplanting SIG, Title I, state compensatory education, special education, and LEP dollars in the place of regular education funds on Title I campuses. Regular education dollars that were skimmed from Title I campuses were moved to the surplus fund, were used to fund special projects of administrators, and were used for increased layers of central administrators.

Evidence found in audited PEIMS records provides a pattern of campus sourcing that is both illegal and unconstitutional. The damage to students can be found in the increasing number of Dallas ISD campuses rated Improvement Required, in stagnant and regressing test scores, in an exploding PEG list, and in the historically low number of seniors on track for a timely graduation in 2015.

Compared to Austin ISD and Irving ISD, both of which focused local and state tax revenue on classroom instruction, the number of failing schools in Dallas ISD grew significantly in 2013-2014. Both Irving and Austin decreased the number of IR, or failing schools, and decreased their PEG list. This comparison suggests great harm to Dallas ISD students through the use of a Title I comparability model that actually decreased equity in financial sourcing of regular education dollars.



The choice to use a teacher staffing formula for Title I comparability was made by central administrators and presented to DISD Trustees as a model of equity. This comparability choice may have been made to protect the much higher regular education student funding levels at magnet schools and non-Title I campuses compared to regular education dollars at Title I campuses.  It also provided a smoke screen to lower regular education dollars in the presence of double the percentage of special education students on IR campuses.

The District may respond that it is constrained by revenue and cannot create a truly equitable campus funding model that contains a floor for regular education per student spending, but the Dallas ISD is no more constrained than other school districts in Texas that follow the law and do not create two tiers of public schools within their boundaries.

It is remarkably hypocritical for Dallas ISD to join other plaintiffs in demanding a more equitable system of funding the public school foundation program in Texas schools while using a financial model that increases sourcing inequities in its most vulnerable schools.

Dallas ISD has sufficient revenues to provide true equity between Title I and non-Title I campuses. The evidence resides in its bordering school district, Irving ISD, with almost identical financial resources and a high level of student poverty and LEP students. Instead, DISD uses a teacher staffing model for Title I comparability that hides the true funding in local tax dollars in its two tiered public schools of Title I and non-Title I schools.

Complainants are NOT asking for an end to the magnet programs or decreases in funding for the magnet programs or non-Title I schools.

Complainants are demanding a floor, not a ceiling, for Title I schools so that illegal and unconstitutional supplanting of regular education dollars ceases and so that all Title I have comparative spends per student in regular education dollars as compared to a neighboring school district that has lowered the number of low-rated schools in its district with such equality. Title I, neighborhood schools educate approximately 90% of students in Dallas ISD, yet they are the schools that were used to skim regular education dollars away from the classroom instruction of most students. This skimming of regular education dollars from Title I campuses may have been used to build a huge surplus budget and for special projects of the Superintendent.

Based on a comparative, neighboring school district, there is no need for a tax increase to develop an equitable distribution of regular education dollars. Instead, the Dallas ISD must have a laser focus on classroom instruction and must focus its local tax revenue on equitably funding its core mission which is classroom instruction. Increasing property values in Dallas will provide increased tax revenue to provide equitable levels of regular education funding and other sourcing across all Title I campuses.

The DISD Board of Trustees must be trained to better and more frequently question central administrators.  They must demand better transparency from administrators with more time to examine the administration’s requests for budget amendments.  There must be a much more timely transparency regarding increased spending outside the classrooms, and for any changes toward more levels in central administration.

Illegal supplementing of magnet school regular dollars with the high school allotments that belonged on the campuses of low-rated high schools are supplementing, by many thousands of dollars per student in some magnets, by adding monies from the athletic budget.  This may be done so as to not trigger a report of the actual defiance of Title I comparability for magnet schools.  It must stop!


1.       Illegal and Unconstitutional System of Campus Funding

"In recognition of the special educational needs of low-income families and the impact that concentrations of low-income families have on the ability of local educational agencies to support adequate educational programs, the Congress hereby declares it to be the policy of the United States to provide financial assistance... to local educational agencies serving areas with concentrations of children from low-income families to expand and improve their educational programs by various means (including preschool programs) which contribute to meeting the special educational needs of educationally deprived children" (Section 201, Elementary and Secondary School Act, 1965).


When Dallas Independent School District developed a Title I comparability formula to provide similar resourcing across all DISD schools before federal Title monies were added to campuses, DISD superintendents and executive staff chose a comparability model using staffing rather than a floor on regular education dollars before adding special needs programming funds on campuses.

DISD’s use of a staffing formula for Title I comparability intentionally hid from the view of elected DISD Trustees and taxpayers a system of illegally loading campuses with few or no Limited English Proficiency (LEP) students or special education (SPED) students with almost twice the regular education funding per student as the failing campuses (Improvement Required-IR) with the highest percentages of LEP and SPED students. Some Title I neighborhood schools with the highest percentages of LEP and SPED students were also randomly resourced with half the general education funding as non-Title I neighborhood schools and as compared to magnets with no LEP or SPED students. Dallas ISD’s Title I comparability formula demonstrates an egregious pattern of supplanting of federal and state compensatory education dollars for general education dollars.  That is an illegal use of both state compensatory and federal funds.

The records documenting the illegal and unconstitutional practice of supplanting federal and state compensatory funds for regular education funding are available on the Texas Education Agency web site containing campus PEIMS records. Most of the statements regarding the illegal use of federal and compensatory funds are based on audited PEIMS records from Dallas ISD campuses for 2013-2104, but records from the year previous also document egregious misuse of School Improvement Grants in terms of supplanting regular education dollars.

Supplanting of federal and state compensatory dollars by decreasing the required spending per student on regular education programs is illegal, but has been a consistent feature of Dallas ISD’s Title I comparability formula which seems to have focused on producing a similar spend across campuses AFTER Title I funds, CTE funds, compensatory education, special education and bilingual funds were added to Title I campuses. It was never the intention of any supplemental funds to be used to produce similar per student spending across campuses.

There is also no correlation between the needs of IR schools and the campus budgets for those schools. Outside the schools within the South Dallas and West Dallas I20/20 feeder patterns, other IR schools with severe needs for compensatory instruction received no extra funding in 2013-2014. Compared to bordering school districts with Title I campuses, Dallas ISD campuses that were rated IR sometimes had the least amount of funding compared to neighboring school districts.

In Dallas ISD, magnet schools, single-sex leadership schools, Montessori schools, and vanguards once served the purpose of a previous desegregation order.  Many of these choice campuses, where students are carefully screened for admission, have few or no percentages of LEP and SPED students. Regular education funding, dollars supplied by local taxes, are almost twice the per-student spending on these campuses compared to failing campuses with critical masses of LEP and SPED students.

This pattern of a reverse Robin Hood formula, where egregious misuse of federal and state compensatory funds supplanted regular education dollars, could not be accidental or the result of lack of understanding of federal and state funding laws. All education personnel are trained on federal and state guidelines. Also, the pattern of misuse of federal and state compensatory education dollars is consistent for several years and was hidden from the view of Trustees through power point presentations by central administrative staff who were totally dishonest regarding the details of campus funding even after being questioned by some Dallas ISD Trustees.

When double the amount of regular education dollars still did not supply special programming needs on magnet campuses, some magnets had their utilities and food expenditures zeroed out in order to hide lack of Title I comparability, a practice that dishonestly added up to $800 a student to certain campuses. Later, these same campuses received millions in athletic program monies when these campuses lack organized sports. In other cases, new magnets were run off Title I funds, high school allotment funds from other schools, and SIG monies.

These practices are blatantly illegal and were solely the responsibility of central administrative staff.

Although the definition may change from statute to statute, supplement, not supplant provisions basically require that grantees use state or local funds for all services required by state law, State Board of Education (SBOE) rule, or local policy and prohibit those funds from being diverted for other purposes when federal funds are available. Federal funds must supplement—add to, enhance, expand, increase, extend—the programs and services offered with state and local funds. Federal funds are not permitted to be used to supplant—take the place of, replace—the state and local funds used to offer those programs and services. (TEA Handbook)

Systematically decreasing regular education dollars on high LEP, SPED, and at-risk campuses while illegally supplanting large sums of Title I fund, School Improvement Grants (SIG), special education funding, state compensatory education funding, and Career and Technical Education (CTE) funding in place of regular education dollars is also unconstitutional. These practices deprive at-risk, LEP, and SPED students on failing and low performing campuses the federal and state funding intended to equalize learning opportunities for under-served students who have been identified as LEP, SPED, at-risk, and low income. The lost learning opportunities in terms of extra teachers, supplies, and instructional specialists in reading and special education have been in the millions of dollars annually on some secondary and elementary campuses.

On the elementary level, this systematic pillaging of regular education dollars of the lowest income schools gave the wealthiest non-Title 1 schools a huge advantage in regular education funding compared to the lowest income Title I schools. There were in actuality no supplemental funds’ gain in instructional resources for some of the poorest schools because regular education dollars were simply lowered and supplanted with Title I funds.

Dallas ISD’s central financial staff can hardly plead ignorance or incompetence since the pattern of lowering per student regular education spending on IR campuses and other neighborhood schools that are not schools of choice was consistent, persistent, and egregious, never erring in favor of the most vulnerable students in Dallas public schools.

In other cases, Dallas ISD’s administrative staff created unconstitutional revenue streams to dishonestly present comparability figures to the Board of Trustees. This included removing huge sums of state high school allotment funds from the weakest high school campuses and moving these funds to the strongest campuses, running the instructional programs of new choice schools almost entirely off Title I funds, SIG funds, high school allotment funds, and compensatory education monies while removing any costs for facilities’ utilities and maintenance for Low SPED and LEP campuses and illegally moving these costs to other schools.

In what seems to be the only comedic relief in the illegal sourcing of Dallas ISD schools, athletic funding made up the majority of regular education dollars for Dallas ISD’s middle and early college programs and illegally supplanted the Advanced Placement programs at the TAG magnet, and SEM in 2013-2014.

Because of the intentional and persistent manner in which regular education funding has been compromised for the most vulnerable students, Complainants request the development of a new Title I comparability formula that places a floor on regular education spending across all Title I campuses, a formula that actually meets the needs of IR campuses and campuses of extreme poverty with average or above average the district percentages of LEP and SPED students.

Dallas ISD’s present staffing method of maintaining comparability for Title I seems to be a ruse to underfund IR campuses and those campuses with high populations of at-risk, LEP, and SPED students while sliding huge extra sums of funding to non-Title 1 campuses or campuses with the highest achieving students.

Examples include:

·         Lakewood Elementary was funded with a planned per student general education budget of $4758 per student while Clinton Russell received $2365 and Stevens Park $2854 in 2013-2014 according to the PEIMS records for planned campus budgets. Russell received $1604 and Stevens Park $1099 in Title I funds which did not even bring their per-student spending to an equal amount as Lakewood students even after illegally supplanting Title I dollars at Russell and Stevens Park. Stevens Park is a very low income school while Lakewood Elementary is a relatively high income school with a very low level of poverty. After skimming regular education dollars away from Stevens Park, supplanting Title I funds did not bring the campus up to the regular education dollars provided Lakewood.

·         High Tech High received only $126 in regular education dollars and $4620 in Title I funds, a clear and persistent violation of federal law for several years.

·         The Talented and Gifted Magnet, after lowering regular education funding to $4576, received over $2,000 per student in “athletic” funding when no school in the district receives funding in this manner. This athletic boost put the Talent and Gifted Magnet beyond comparability measures at the same time the magnet had its operating costs and foods costs zeroed out of its budget. The total revenue added after posting $4576 for comparability purposes was $2800 in “athletic funding” and no food or operating or maintenance costs.

·         School Improvement Grants totaling $20 million dollars appeared to supplant regular education dollars at North Dallas High School, at Spruce High School, at High Tech High, and at Roosevelt High School.

·         Instructional funding at the Education Magnet was largely Title I funds even though the Education Magnet was covering the utility costs and food costs for other magnets at Townview. The Education Magnet seemed to be used as a shell school to cover Title I incomparability at SEM and TAG by paying the utility and food bills of these schools.

·         Disbursement of Title I funding for campuses followed no formula, but seemed dependent on attempting to level off similar funding levels on Title I campuses.

·         There is no evidence of any attempt to match the needs of most IR campuses to campus funding. Instead, high poverty middle schools such as TW Browne were sourced as if they were flourishing schools with no broad and deep instructional issues.

Dallas ISD’s weakest secondary schools persistently had a lower spend in regular education dollars and sometimes in total dollars than bordering suburbs with no Title I students even though district per student revenue is similar. Extremely poor students in IR schools would have been given extra classroom dollars by moving to non-Title I bordering suburbs that provided higher instructional dollars than the poorest IR secondary schools in Dallas ISD. This inequity in classroom spending in school districts bordering Dallas that contain no Title I schools is shocking. For Dallas ISD middle schools with the most serious academic deficits in the state of Texas to have less classroom instructional spending per student compared to bordering suburbs with no Title I schools reflects on the inequity  and egregious supplanting in some cases in the funding model used in Dallas ISD.

It will be shown in the remainder of these complaints to be filed with the federal Department of Education that Dallas ISD is running a two-tier, unconstitutional education system. The top tier of the system, made up of mainly non-Title I campuses, was provided more funding in regular education dollars, stable staffing in teachers and principals, safe campuses,  and top programming. These schools served much few percentages of LEP, SPED, at-risk and poverty students.

The bottom tier schools, mainly those rated as Improvement Required (IR) by the Texas Education Agency, had millions in regular education dollars illegally removed from them while these schools also suffered from constant churn in teachers and principals, lack of adequate special education services even though secondary IR schools were afloat with special education dollars, lack of effective instructional programming, and lack of research-based education practices. In addition, these schools consistently reported poor campus climates with unsafe learning conditions for students and working conditions for teachers. School climate surveys seemed to be withheld from public scrutiny for these schools in the 2104-2105 school year.

PEIMS documents located on the Texas Education Agency web site,  document the egregious misuse of Title I funding and indicate a pattern of supplanting regular education dollars with School Improvement Grants. The PEIMS documents indicate an intentional, well-planned pillaging of some of the most vulnerable students in all the Texas public schools with a Dallas ISD financial model that streamed the most financial resources per student to some of the top magnet schools in the nation.

When IR schools were and are constantly reconstituted, the instructional failures of these campuses were and are blamed solely on teachers and campus leadership with no hint of the illegal and unconstitutional sourcing of these campuses by central administrators.

A cursory examination of PEIMS documents for the last few years also shows that while the District may tell Trustees there is a formula for the distribution of Title I funds based on the number of students on free or reduced lunch, there is no adherence to this formula.

If a secondary campus has high percentages of special education students, its Title I funding may be minimal because of an internal protocol that seeks to bring most schools to a similar level of overall spending rather than providing an equitable floor of regular education dollars that adds appropriate layers of Title I and special education funds to regular education dollars. The actual needs of the campus are ignored and are deficient in resourcing to move many IR schools off the state list of the lowest achieving schools in the state.

Campuses with low percentages of secondary special education students were sometimes given large doses of Title I funds on top of minimal levels of regular education funds. The Title I funding on Dallas ISD campuses had a random relationship to the actual level of poverty on many campuses.

The see-saw effect of either loading Title I high schools with regular education OR Title I funding is apparent from an examination of PEIMS records and is illegal. Neither Title I nor special education funding should be dependent on any other factors other than the stated formulas given for each.

 IR, or failing middle and secondary schools, have almost twice the district percentage of special education students and high percentages of LEP students for their grade level.

It appears the District is complicit in illegally supplanting Title I, SIG, and special education by both adding large sums of Title I and special education funds to cover lowering regular education dollars and by under-funding Title I campuses by lowering regular education far below the magnet schools and Title I campuses in bordering school districts.


2.       Creating a De Facto, Systemic Method of Supplanting Federal Supplemental Funding on Most Dallas ISD Title I Campuses: Violation of Equal Protection Guarantees and State and Federal Law

Dallas ISD’s current Title I comparability formula hides the fact that compared to Title I campuses in bordering school districts, Dallas ISD Title I campuses and their students have been systematically deprived of millions in regular education dollars through simply substantially lowering the amount of regular education dollars before Title I, CTE, special education, and bilingual funding were added.

This systemic plundering of regular education dollars for other purposes rather than classroom instruction essentially negates much of the impact of supplementary funding for Title I, bilingual programs, state compensatory education funding, Career and Technology funding, and special education funding. Lowering regular education dollars before adding federal and state compensatory and special programming dollars does the most damage to special education, LEP, poor, and at-risk students by removing the power of additional dollars for special needs students. The Dallas ISD Title I comparability formula as well as the “equity” model developed by the current administration are essentially reverse Robin Hood formulas for pulling out any floor on regular education dollars on Title I campuses before supplementary federal and state dollars are added. Non-Title 1 campuses and magnets and choice schools that admit almost no LEP or SPED or at-risk students have the highest amounts of regular education dollars on their campuses. This practice assumes educating high achieving students for the required state standards costs more than educating critical masses of LEP, SPED, and at-risk students found on the campuses of neighborhood, Title I campuses.

Dallas ISD has essentially violated both federal and state law by creating a two-tier system of non-Title I and magnet and choice schools which were allotted in some cases almost twice the amount of regular education dollars as the poorest Title I campuses in the District filled with the highest percentage of LEP, SPED, poor, and at-risk students.

In addition to in-district legal and constitutional violations of equal protection and equal access, Dallas ISD’s current campus funding formula essentially created a de facto separate and unequal school district of Title I campuses within Dallas ISD compared to both its magnet schools and compared to bordering suburban Title I schools in districts that have similar levels of revenue and similar demographics.

Dallas ISD has also violated the Texas state Constitution in refusing to provide an efficient system of education within its borders since the classrooms of Title I campuses were financially violated while state and local funding were used for many purposes other than classroom instruction. Dallas ISD is not a property-poor district, yet the level of per student spending for regular education is much lower than surrounding districts with the same level of tax revenues.

In effect, the current administration is short-changing Title I students of dollars necessary for instruction in the state-required curriculum in order to fund projects that had no impact on student achievement if the PEG list is examined for 2013-2014.

As a sample of the millions removed through a bogus Title I comparability formula relying on staffing instead of instructional dollars, a comparison of regular education spending at the high school, middle school, and elementary  levels in Irving ISD were compared to Title I campuses in Dallas ISD. The data for these comparisons were pulled from the public PEIMS documents available on the Texas Education web site. The comparisons include planned campus budgets for 2013-2014.

Both school districts, Irving ISD and Dallas ISD, have similar levels of revenue, and student demographics are similar on Title I campuses. While Irving ISD was able to bring an IR high school campus off the low performing list in one year, Dallas ISD dramatically increased the number of IR high school campuses in the same year while also under-funding neighborhood high school Title I campuses. Dallas ISD also has many IR high school campuses that have lingered on the IR and AU state lists of poorest performing schools for years.

As an example of the harm inflicted by Dallas ISD’s current use of a sham comparability formula, Sunset High School in Dallas ISD will be compared with Irving High School in Irving ISD. The two schools provide an example of similar-sized high school campuses with similar demographics.

Irving ISD central administrators planned $3887 in regular education dollars for Irving High School for the 2013-2104 school year. By state law, regular education dollars must be adequate to support the state-required curriculum and learning standards for all students before the addition of federal and state compensatory dollars. Irving ISD then added all supplemental funding to the $3887 in per student regular education dollars for Irving High School, including $722 in state compensatory funding. Irving High School, a very close match demographically to Sunset High School, received a total of $6655 in per student funding aimed directly at the classroom.

Adding to this picture of inequity in funding is the fact that Dallas ISD received $149 million for state compensatory education (SCE) in 2012-2013 as an indication of the size of typical SCE funds for the District. Yet, SCE funds do not appear on Dallas ISD campus PEIMS reports in the category of Accelerated Education for any high school in 2013-2014. As a note, while the District spent the legally allowable sum of $59 million in overhead administration from these SCE funds in 2012-2013, it could have chosen to add to campus resources instead of funding central administrative positions.

A Dallas ISD evaluation of the 2012-2013 SEC grants states:

The purpose of the State Compensatory Education (SCE) program is to increase academic achievement and reduce the dropout rate of At-Risk students through direct instructional services. The goal is to reduce any disparity in (1) performance on state-mandated assessments, and (2) high school graduation/ completion rates between At-Risk students and all other district students. Texas Education Code (TEC) §29.081 defines the state criteria for identifying At-Risk students.1 Students who meet any of the criteria are to be reported through the Public Education Information Management System (PEIMS) in the fall of each school year. Among the 13 criteria are students who are limited English proficient, students who failed a state assessment, or students who were retained. The district is required to submit the district improvement plan, two campus improvement plans, and the local evaluation of state compensatory education strategies, activities and programs to the Texas Education Agency (TEA) annually.

“An analysis of STAAR and TELPAS assessment results from the district pointed out the need to address special population groups. Disaggregated student achievement data shows that the following student groups need to be addressed in order to close the learning gaps: Hispanic, Limited English Proficient, African-American, special education, and at-risk students. According to these data, there is a need to provide supplemental staff and programs to support the social, emotional, and academic needs of low achieving students, English language learners and other students considered at risk of academic failure, including eliminating any achievement gap between males and females. There is also a need to target training and support to ensure that all teachers are skilled in the use of research-based instructional practices and cultural proficiency. To serve as first-level responses to learning difficulties, the campuses will need to identify and develop proven, practical intervention practices and strategies ..”[2]

Of the  $149 million in SCE monies in 2012-2013, the District only spent $86 million on programs/services for at-risk students while also under-funding by millions its high schools containing high percentages of the targeted at-risk students: special education, LEP, and students who had failed state required tests for graduation. Many SCE-funded positions were left vacant.

There is no evidence from the campus PEIMS reports for Sunset, for example, that SCE funds targeted the at-risk population on Sunset’s campus or any other high school campus with high attrition even though there is evidence of increased attrition at the high school level over the past three years as well as high rates of failure on End of Course Exams with the high attrition HIDING the actual failure rates on EOC exams. Sunset High School received no compensatory state funds[3] even though District evaluation reports describe the majority of at-risk students in Dallas ISD, the students targeted by SCE funding, are male, Hispanic, and LEP.

The District report on SCE funds for 2012-2013 clearly provides a picture of the District failing to hire planned positions and using $50 million for administrative overhead while the formula used for Title I comparability grossly understaffed the classrooms of DISD.

House Bill 5 of the 83rd Legislature will require that all school districts serve students failing EOC exams with SCE funds before any other group. Whether Dallas ISD followed this law will be seen when the public can view campus planned spending for the 2014-2015 school year in PEIMS records.

Yet, in neighboring Irving ISD, there was a plan in place to use SCE funds for the targeted population at Irving High School. Irving ISD had one high school campus rating of Improvement Required or IR in 2013 and by 2014, the high school was no longer IR, perhaps because Irving ISD was not using a bogus plan to strip regular education and SCE funds from its failing high school campus.

If Dallas ISD used SCE funds for credit recovery at its high schools, that program was exposed as a sham in articles by The Dallas Morning News investigative reporters.

Because of DISD’s formula, Sunset High School received only $2977 in regular education dollars and received no state compensatory funding. Exactly where state compensatory funding went is not clear from PEIMS reports.  The total instructional, classroom dollars planned for Sunset High School, a school with major dropout and student achievement issues, was only $4725 compared with $6655 for Irving High School. Between lowering Sunset’s regular education dollars and the absence of state compensatory funds for a school high in at-risk students, Sunset students missed out on $1730 per student in funding compared to its direct demographic peer in Irving, Texas in a school district that has similar per student revenue as Dallas ISD.

That $1730 per student times the 2144 students predicted to enroll in Sunset High School equates to a $3.7 million dollar difference in classroom and instructional funds available for the students of Sunset High School compared to their demographic match in Irving ISD, a neighboring suburb with a high poverty rate and high percentage of Hispanic and LEP students.

Placing a floor of $3800 in regular education funds would have given Sunset High School about $1.8 million in just added regular education revenue which could have significantly lowered class sizes in the academic core.

In the same Dallas ISD Trustee district, belonging to Trustee Eric Cowan, Molina High School lost over a million dollars and Adamson around $870,000 compared to the regular education dollars these schools would have received in general education dollars in a school district with similar revenue located only a few miles away. Those figures do not include missing SCE funding.

From only the neighborhood high schools of North Oak Cliff, a total in 2013-2014 of around four million dollars was removed from classrooms of students attending DISD neighborhood high schools compared to the regular education instructional dollars provided neighborhood high school students a few miles away in a school district with similar revenue. While some corporate reformers harp on zip codes not defining the educational outcomes of urban students, none of these reformers has compared regular education spending for classroom instruction as dependent on the vagaries of zip codes.

Aside from the two-tier system operating WITHIN Dallas ISD where magnet and non-Title I schools receive almost twice the regular education funding as some neighborhood Title I schools, Dallas ISD cannot even demonstrate a comparable spend to similar Title I schools sitting on its borders that are a demographic match to its neighborhood Title schools.

In Pleasant Grove, Samuell High School, which has been on the state unacceptable list for almost a decade, is lacking over a million dollars in funding from the 2013-2014 school year if any equitable and legal method of funding regular education dollars similar to the formula used in Irving ISD had been applied rather than a mishmash of special education dollars and Title I funding.

Skyline High School lost $5.3 million dollars in regular education funding if its students had received the same per student regular education funding that is available in Irving ISD’s high schools. In addition, athletic funding seems to have been moved off the campuses of comprehensive high schools and transferred to magnet and Early College campuses to boost classroom instructional resources.

Regular education funding across all Irving ISD high schools was very similar—around $3800. In Dallas ISD in 2013-2014, the following schools failed to meet the $3800 regular education funding awarded Irving High School even though these schools are also high LEP, SPED, and high poverty: Adamson, Bryan Adams, Molina, Hillcrest, Thomas Jefferson, Kimball, Samuell, Seagoville, Spruce, Sunset, WT White, Carter, North Dallas, Conrad, and Skyline.

In contrast, Booker T. Washington High School for the Performing and Visual Arts, serving in reality as a multi-county high school funded by local property taxes of Dallas taxpayers, was scheduled for $5775 in regular education dollars and was awarded a third of a million dollars from the athletic budget to further increase its instructional resources according to PEIMS records for 2013-2014. Booker T. Washington has one of the lowest levels of poverty in the district and the highest percentage of white students, many of whom are from out of district. Booker T. Washington’s regular education dollars for 2013-2014 were twice that of Sunset High School.

The only Dallas high schools that are high poverty that were awarded a higher spend than Irving High School in regular education dollars are those neighborhood high schools with shrinking populations: Pinkston, Roosevelt, Lincoln, and Madison whose small student populations increased costs and were part of I20/20. The increased regular education dollars at these high schools and the total instructional spend was much less than the resources given IR schools in Austin ISD where central and campus administrators put effective instructional plans and resources on campuses and decreased their PEG list in 2013-2014.

The current Dallas ISD comparability formula used for 2013-2014 essentially removed $19 million in regular education funds from Dallas ISD high schools loaded with LEP and SPED and at-risk students if compared to similar student populations in Irving ISD, a district with similar levels of tax revenue. Not placing a ceiling on Title I high school campuses while providing a floor of $3800 in regular education funding would cost the District $19 million a year based on 2013-2014 PEIMS records.

Complainants are not requesting a ceiling on campus regular education dollars for existing high schools or ceiling for magnet programs which have had severe cuts in regular education dollars in the past few years.

Instead, complainants are demanding a floor for regular education dollars for Title I high schools that is comparable to a much more successful district, Irving ISD, sitting on the border of Dallas ISD.

Complainants are also requesting that the Department of Education monitor regular education spending on Dallas ISD Title I campuses for the future in order to monitor compliance in regular education spending across campuses.

Complainants are also requesting that Dallas ISD quit robbing other programs and grants, such as high school allotment or the athletic budget, in order to fund its magnet and Early College programs. If magnet programs cannot be run on comparable dollars to Title I comprehensive high schools, Dallas ISD needs to develop honest, transparent solutions to that problem.

Information on Title I comparability presented annually to the Dallas ISD Trustees seemed to focus on some attempt to equalize spending across Title I and magnet schools AFTER Title I schools received Title I, CTE, bilingual, and special education funding. Using an “equity” formula that compares magnets and neighborhood campuses after supplementing for special needs on Title I campuses filled with special education and LEP students is not an equity formula but a perversion of equity; it is a Robin Hood formula that removes regular education dollars from the most vulnerable students.

It was never explained to the Trustees that comparability formulas should have provided equity BEFORE any supplemental funding was added and that there should be no expectation that with a floor on regular education dollars, comprehensive high schools would then have similar total instructional spending per student. The poorest high schools with the largest percentages of LEP, SPED, and at-risk students should have had much higher sums of financial sourcing than magnets with no LEP, SPED, CTE, or at-risk students. The Dallas ISD formula proposes that teaching the mandated state standards and courses to poor, LEP, special education, and at-risk students is much cheaper in regular education dollars, which are supposed to totally fund the state-mandated standards, than teaching the same standards to magnet students who have been carefully filtered for admission to magnet schools.

Dallas ISD’s “equity” formula turns supplemental funding upside down and adds supplemental funding, along with supplanting Title I funds, before reporting comparability to the Trustees. There is no evidence that the Trustees were aware of or understood the perversion of equity in funding provided their constituents. For central administrators to plead they did not understand federal and state laws regarding supplanting federal and state monies is not a defense and is outside the boundaries of belief.


Middle school spending in regular education dollars in Irving ISD demonstrates another egregious pattern in Dallas ISD of underfunding Title I campuses in terms of lowering regular education funding before adding federal supplemental funding.



Dallas ISD neighborhood middle schools, especially those neighborhood IR middle schools filled with high percentages of SPED, LEP, and at-risk students, are provided millions less in regular education dollars compared to middle school students in bordering Irving ISD.

Dallas ISD neighborhood middle schools with the highest per student spend in regular education dollars are located at Marsh, Franklin, Gaston, Long, and Walker and hover around $4100 a student. Zumwalt and Edison had funding in the same range, but are much smaller schools.

Some Dallas ISD middle schools in the worst shape academically in the state are funded at a $1,000 a student less than the average regular education spending per middle school student in Irving ISD.

Spence Talented and Gifted Academy, housed in a neighborhood middle school, had its regular education dollars lowered to $3201 while its Title I funding illegally supplanted the lowered regular education spending for several years.


Dallas ISD Low Rated Middle Schools: Regular Education Funding
PEIMS Records for Planned Campus Budgets 2013-2014
# of Students
Regular Ed Dollars
Browne Middle
O Holmes
Boude Storey

The only middle schools in Dallas ISD that approach the regular education dollars provided all neighborhood middle schools in Irving ISD are Dallas ISD magnets and vanguards—schools of choice where students are filtered for admission. DESA, for instance, is provided $4900 in regular education funding.

The reason so many parents leave Dallas ISD schools after successful experiences at the elementary school level may be found in the gross underfunding of neighborhood middle schools in Dallas ISD. For the most vulnerable students, those in IR schools, no floor for regular education dollars means special education funds are not supplemental, but used in part to provide the state-mandated curriculum.

Improvement Required (IR) middle schools in Dallas ISD are some of the lowest rated schools in the state of Texas, yet these IR middle schools have been systematically grossly underfunded compared to similar middle schools in Irving ISD and other school districts. Browne Middle School, according to, is at the 1.5 percentile of rankings in the middle schools in the state of Texas. Many other IR Dallas ISD middle schools are in the lowest 5% in the state with their peer middle schools either failing charter schools or schools operated by the Juvenile Justice System in Texas. Yet the bogus “equity” model in Dallas ISD stripped millions out of these schools compared to demographically similar schools in Irving ISD.

Providing a floor of even $4500 (less than the average for Irving ISD’s middle schools) would cost Dallas ISD around $18 million a year because every one of its middle schools is under-funded compared to a school district of Title I campuses sitting on the border of Dallas ISD.

Elementary schools in Dallas ISD also show an irregular, random funding of regular education dollars with some non-Title campuses with the lowest level of poverty and LEP students receiving the highest level of regular education funding.

 Non-Title I elementary campuses of Lakewood and Stonewall Jackson are provided high levels of regular education dollars along with some Title I funds. This practice entirely negates the entire point of federal supplemental funding since other elementary schools must use Title I funds to catch up to the level of funding provided nontitle schools.

Stevens Park, Clinton Russell, Truett, and Lowe Elementary Schools (all extremely high LEP schools) were the victims of illegally supplanting Title I funds for regular education monies. Truett’s regular education funding dropped to $3135 while its Title I funding increased to $1098 to bring it up to less than the regular education funding provided Lakewood and Stonewall Jackson at almost $4800 each. Preston Hollow Elementary received almost $5000 per student in regular education funding while the lowest funded elementary schools with the highest levels of LEP, SPED, poverty, and at risk students had total program dollars much less than  nontitle campuses with the lowest levels of poverty in the district. Since Preston Hollow represents a small Title I school and Lakewood and Stonewall Jackson represent non-Title large elementary schools, Plaintiffs are requesting a floor within 10% of the regular education dollars at these schools to provide the floor for all elementary Title I campuses.  A spreadsheet follows this discussion showing how many campuses would be under-funded at a $4400 floor.

This floor also pushes Dallas ISD elementary school campuses toward the average instructional per student spending in Irving ISD on its elementary campuses which is around $6100 solely for instruction, not for operations or administrative costs.

From a competitive standpoint, most Title I campus students in Dallas ISD are at a competitive disadvantage in the instructional resources afforded them compared with both nontitle campuses within the Dallas ISD and compared to Title I campuses in bordering school districts with similar demographics and per student revenue.

None of this under-resourcing of Title I neighborhood schools in Dallas ISD is the result of lack of adequate financing for Dallas ISD compared to bordering school districts. This inequitable, unconstitutional, and illegal campus sourcing scheme was deliberate, systematic, and systemic and the sole purpose was the removal of tax dollars from classroom instruction for other purposes.



Title I Campuses: Illegally Supplanting Title I Funds
Elementary schools:
Regular Ed $
$ Title I Funding
Clinton Russell
Stevens Park





Dallas ISD’s funding formula consistently removes millions in regular education spending from neighborhood Title I elementary school campuses before adding Title, bilingual, and other federal funding.

This practice illegally removes any benefit from federal or state compensatory monies.

The total REGULAR EDUCATION funding per student, supplied by local property taxes in Dallas compared to regular education funding levels in  Irving ISD, adds up to a loss of around $70 million classroom instructional dollars for Dallas ISD Title I students in just one year. Not placing a ceiling on existing campuses that are over the suggested floors would add $7 million more in regular education funding.  It will take $77 million annually to bring Dallas ISD Title I campuses in compliance with bordering school district formulas that focus local property taxes on classroom instruction. This focus on classroom instruction rather than building a surplus budget or skimming regular education funds for special projects is shown to increase student achievement.

The justification for the requirement of a floor on regular education funding per student is simple. Dallas ISD is showing a regression of student achievement over the past couple of years when the Texas PEG list of failing schools is examined.

During just the one year of comparison from PEIMS records for regular education campus spending in 2013-0214, Dallas ISD Improvement Required Schools and low performing schools increased from 45 schools on the Public Education Grant (PEG) list of failing schools to 71 schools in Dallas ISD, a 58% increase.

Austin ISD and Irving ISD, in 2013-2104, with effective classroom funding formulas that focused local tax dollars on classroom instruction, lowered their Public Education Grant (PEG) or low performing schools from 11 to 9 and 15 to 12 respectively..



Dallas ISD has failed to uphold constitutional guarantees of equal protection for its most vulnerable students in developing a widely acclaimed funding model that was touted as a model of financial equity. The truth regarding the lack of equity for LEP, SPED, at risk, and poor students is demonstrated in the PEIMS public documents available on TEA’s web site which provide a picture of illegal supplanting of federal funds, of misuse of athletic funds, and underfunding of a majority of Title I campuses. The gross, systemic lowering of regular education funds is apparent from even a superficial scrutiny of PEIMS records.

Using the vendor ERG to declare Dallas ISD an efficient school district needs examination by the Department of Education since ERG declared Dallas ISD was an efficient school district when the District was illegally supplanting federal dollars and systematically underfunding Title I campuses.

The harm done cohorts of students attending Title I campuses in Dallas ISD can be measured in the increasing number of IR schools and the increasing length of the PEG list compared to Austin ISD and Irving ISD which successfully lowered the number of IR and PEG schools by using a floor for regular education funding of its IR schools.

Complainants are requesting a series of actions to correct the unconstitutional system of regular education funding operating in Dallas ISD on Title I campuses filled with LEP, SPED, and at-risk students. Dallas ISD’s bogus Title I comparability formula has left Title I campuses with thousands of dollars less per student in regular education funding than Title I campuses in a bordering school district, Irving ISD. Complainants are not asking for ceilings on regular education spending on any current campuses, but are insisting on a floor of regular education dollars.

·         An immediate floor will be set for high school comprehensive high schools for regular education per student spending at $3800 in the 2015-2016 budget. This floor at least gives some comparability to the funding of high poverty campuses found in Irving ISD. This floor without a ceiling will cost Dallas ISD approximately $19 million a year even though Title I, neighborhood schools will still suffer gaps in regular education spending per student compared to magnet campuses.

·         An immediate floor will be set for middle school students in regular education funding at $4500 per student for the 2015-2016 budget. This will cost approximately $18 million a year based on the PEIMS documents available for 2013-2104. All Dallas ISD Title I middle school campuses are underfunded.

·         An immediate floor will be set for neighborhood Title I elementary schools for the 2015-2016 budget that matches within 10% the non-Title I campuses of Lakewood and Stonewall Jackson. This will cost around $39 million dollars a year if no ceiling is required for existing campuses.

·         These actions will occur for the 2015-2016 school year. Allowances will not be made for large Dallas ISD campuses since large campuses have a number of security issues not found in smaller schools. There is no intention of creating more inequities on large campuses by overcrowding classrooms. Trustees will immediately develop a plan for increasing regular education spending on Title I campuses to meet legal standards and this plan will be presented in Town Hall meetings along with an admission of how underfunded some Title I campuses have been in relation to non-Title and magnet school campuses in terms of regular education dollars.

·         Principals will be given discretionary power over increased funding in regular education dollars rather than having staffing patterns set by DISD central staff. This option will give principals choices for their Title I dollars rather than having those dollars’ purposes determined by the Superintendent.

·         If the state of Texas increases funding per student, part of the increased state allowance will be used to decrease the gap in regular education funding between Dallas ISD Title I campuses and magnet campuses so that over time the gap in regular education funding per student decreases between Title I campuses and magnet and choice campuses.

·         Every school in Dallas ISD will post its latest audited and planned campus budget as reflected in the PEIMS documents found on the TEA web site so that the public and parents can monitor how students receive equitable financing across neighborhoods in regular education dollars which are supposed to provide the instructional resources for the TEKS.  Dallas ISD central administrators have failed to provide either Trustees or the public transparency on regular education dollars on campuses across the district and huge gaps across campuses are not explainable due to teacher salaries.

·         Dallas ISD will be monitored so that funding for existing neighborhood Title I schools, filled with LEP, SPED, high poverty, and at-risk students are not marginalized financially in the future with Title I comparability formulas that actually remove any supplemental value for state and federal compensatory and programming funding.

·         Dallas ISD secondary schools’ regular education funding will NOT be raided in order to provide full-day, PreK instruction. Dallas ISD secondary students on neighborhood campuses have the same constitutional rights to comparable funding as magnet and choice school students and a right to comparability with bordering suburbs in their spending per student on regular education for neighborhood schools. Dallas ISD is a property wealthy school district whose constant chaos and corruption seem to be the foundation for its lack of classroom resources. Robbing secondary students to pay for PreK is not an option.

·         Dallas ISD cannot plead lack of financial resources to bring constitutional and legal compliance in campus sourcing of regular education dollars. Dallas Trustees might have sessions with Irving ISD Trustees to educate themselves on efficiencies in the use of public dollars so that local, state, and federal monies remain targeted at equity in the classroom.

·         Dallas ISD may not supplement magnet school campuses with “athletic” donations intended to provide backdoors to extra revenue hidden from comparability tests nor may the district zero out expenditures for food and utilities on favored campuses nor may the Dallas ISD use any other subterfuge in supplementing the funding of its magnet school students. Transparency will light the road ahead and the public will be trained to read the PEIMS records and the regular education spending per student on each campus as an indication of actual equity.

·         Dallas ISD may not bring any new “choice” schools on-line before its unconstitutional and illegal funding of Title I schools are remedied by creating floors for regular education funding for neighborhood high schools, middle schools, and elementary schools. There has been a pervasive lack of transparency or even a functional budget in Dallas ISD when choice schools are added. If Dallas ISD choice schools are added in the future, the Department of Education will monitor student populations to ensure that LEP and SPED and at-risk students are not further segregated in low performing schools and that per student funding is in line with Title I campuses.

·         Dallas ISD may not create “choice” schools that are funded at a higher level than its existing Title I campuses in terms of regular education dollars. The budgets for new choice schools will be fully transparent and brought to the Board of Trustees to be discussed in Open Session. The skimming of regular education dollars off Title I campuses seems to have provided the impetus and funding for programs that will never benefit the skimmed students.




3.       The Teacher Excellence Initiative (TEI): Violation of DISD Students’ Equal Protection Rights and Teacher Due Process Rights

Dallas ISD’s current Teacher Excellence Initiative violates equal protection rights of students on neighborhood campuses filled with LEP and SPED and at-risk students and violates the due process rights of both principals and teachers on these same campuses.

Evidence has already been brought of the illegal and unconstitutional funding of many neighborhood Title I campuses in Dallas ISD. In addition to underfunding some of these campuses by millions of dollars, the level of campus safety, the level of inexperienced teachers, the level of principal efficacy, and the level of churn across campuses is not equitable compared to Dallas ISD magnet schools.

With illegal and unconstitutional funding disparities between IR high SPED and LEP campuses and magnets with few or no SPED or LEP students, there is constant reconstitution on failing high SPED and LEP campuses. This constant reconstitution affects teachers and principals, leaving little accountability for the Superintendent or central staff for the disparities between magnet schools and IR schools in funding, staffing, or programs.

Leading or teaching on high LEP and SPED campus, with a huge disparity in resourcing because of central administrative campus funding decisions, is already a career risk since reconstitutions based on two years of low state ratings can mean principals and teachers are removed and have either their contracts non-renewed or they are fired. In Dallas ISD, these teachers, according to text messages made public in a Human Resources scandal, are not welcomed for other teaching assignments. The onus and accountability for the lowest state ratings rest on principals and teachers even though proof of inequitable and illegal violations of supplanting of federal and state compensatory funds exists along with high churn in principals and teachers.

The annual compensation, not merit bonus money, of Dallas ISD teachers is now tied to a system of performance reviews known as the Teacher Excellence Initiative.

The Superintendent has admitted in an open, public budget meeting on February 16,2015 that he, the Superintendent, would have to hold harmless teachers with good ratings on the TEI in order to encourage them to move to IR campuses such as South Oak Cliff High School. This open admission of the bias in the TEI violates due process for all teachers on all IR campuses and other Title I campuses that have been shorted equitable funding by up to a million dollars in one year.

If the TEI is sensitive to gross differences in student demographics across Dallas ISD campuses and thereby creates invalid teacher appraisals based on student demographics, the TEI is a direct violation of due process for teachers. If the TEI cannot be used for all teachers under all circumstances and the TEI has a punitive effect on teachers on IR campuses, the TEI directly impacts the equal protection rights of students on those campuses since the TEI will lower teacher pay on IR campuses as well as increasing the career risk of teaching on those campuses. The TEI, where teachers essentially compete for their salaries, assumes equity in inputs across Dallas campuses when in reality, evidence exists that there are gross inequities in staffing, funding, and campus safety.

If teaching on an IR campus equates to lower teacher appraisals and lowered teacher compensation for career educators, the TEI cannot be used in Dallas ISD.

The fact that campus contextual factors matter more than attempts to forecast student outcomes by use of different Value Added Measurements (VAM) has already been litigated in the case of a former DISD teacher from Kimball High School.

Former Texas Education Commissioner Robert Scott formally ruled in 2008 that campus factors can override the instructional expertise of individual teachers when Scott awarded back pay to a Kimball High School teacher who was fired during a reconstitution of the campus for low test scores. The pervasive chaos of the campus had more impact on lack of student achievement that efforts of teachers as documented in Scott’s ruling:

Good cause does not exist to terminate Petitioner’s term contract.  The reason given for proposed termination was the failure of Petitioner to demonstrate a pattern of academic achievement by her students.  The Findings of Fact establish that the school’s environment not Petitioner was the cause of the lack of achievement.  Because Petitioner’s actions as a teacher are not found wanting, good cause does not exist to terminate Petitioner’s contract. DOCKET NO. 071-R2-0708


Dallas ISD completely ignored the Commissioner’s ruling and continues to use the CEI as an accurate measure of teacher effectiveness. The CEI is included as part of teacher evaluations in the TEI.

The DISD Classroom Effectiveness Indices (CEI) compares student achievement levels based on different demographic characteristics in order to theoretically provide a level playing field for rewarding or punishing teachers based on predicted student instructional outcomes.

The problem with all VAMS is that not one VAM in existence takes into account the context where classroom learning takes place. There is no handicap for teachers in illegally funded schools where safety is a problem or where teacher and principal churn is constant, weakening the entire school according to a preponderance of research. High SPED and high LEP schools in Dallas ISD work from illegal and unconstitutional disadvantages, but not one input measure of funding or staffing is included in the TEI which will determine teacher compensation.

Because IR schools already represent a threat to any experienced or inexperienced teacher wishing to build a productive career as a teacher, teacher and principal appraisal instruments must provide latitude for the context of different campuses, or teachers and principals suffer disproportionate consequences for instructing children on campuses with high percentages of LEP, SPED, and at-risk students.

The TEI gives a teacher compensation advantage to teachers in low LEP and SPED schools while providing disadvantages to teachers assigned to IR and under-resourced Title I schools. The TEI provides another reason for experienced and proven teacher talent to find “safer” campuses to build their careers. In doing so, the TEI deprives the neediest students on IR campuses from the full advantage of recruiting teacher talent that can be retained on their campuses and equal protection guarantees.

Plaintiffs request the federal  Education Department bring a complete halt to any attempt at tying teacher compensation in Dallas ISD to student output through the TEI. This request is based on the illegal and unconstitutional sourcing of campuses in Dallas public schools and based on the inability of all current VAMs to include the contextual variables of campus conditions that are as important as teacher expertise and effort in determining student achievement outcomes.

In addition, the current superintendents’ public statement that high-rated teachers would have their TEI rating essentially frozen if they transferred to IR schools is a public statement of the lack of validity of the TEI.

The TEI does not include campus safety factors, constant churn in teachers and principals, quality of campus leadership, forced micromanaging of professional practices, and lack of adequate resources on many campuses. All of these factors are totally beyond the control of teachers, yet teachers are held accountable for instructional outcomes.

The current attempts by the Superintendent of giving supplemental pay to high-rated teachers willing to transfer to IR schools ignores the fact the current teachers on IR campuses might also be high-rated if they simply transferred to non-Title I schools. That fact that the majority of the highest paid teachers in the district under the TEI scheme will probably be located on non-Title I campuses is a violation of equal protection rights of Title I students.


4.       Audition and Recruitment of Out of District Students: Booker T. Washington High School for the Performing and Visual Arts: Violation of Equal Protection Guarantees of Dallas ISD Students

Dallas ISD students who attended Dallas public schools in the eighth grade are now in the minority (only 40%) at Booker T. Washington High School, an arts magnet school financed with Dallas ISD taxpayer monies.

Dallas ISD has had dozens of openings for teachers in the arts since the arrival of the current Superintendent. Dallas ISD has failed to provide adequate training in the arts in grades K-8 so that all interested students in Dallas ISD are prepared to audition at a public Dallas ISD school. Complainants are requesting additional arts classes in all the cluster areas provided at Booker T. Washington in grades K-8 in existing DISD schools, not as part of new choice schools, so that all interested Dallas ISD students are able to successfully compete for admission at the arts magnet. As part of the regular education funding that should be increased on most Title I campuses in order to provide equity, additional arts programming, part of the academic core, must be provided all students.


5.       Lack of Effective Programmatic Remedies and Funding for IR Secondary Schools and Violations of Equal Protection Guarantees

Dallas ISD is not a property poor district, nor does it lack the ability to recruit experienced administrators, principals, and teachers who have a track record of practicing effective research-based programmatic remedies and interventions. Dallas IR secondary schools contain on the average almost twice the number of SPED and LEP students as other neighborhood middle schools, yet research-based programmatic remedies seem absent from campuses which also suffer from discipline policies that are exacerbating unsafe campus conditions.

Plaintiffs are requesting investigation into:

·         The underfunding due to blatant supplanting of Title I funds at Spence Middle School where lack of psychological services may have played a role in a student’s suicide.

·         Unsafe campus conditions at Sara Zumwalt Middle School, Edison Middle School, Billy Earl Dade, Boude Storey, and Marsh Middle School as documented in press stories and parent and community complaints for relief.

·         Lack of appropriate student services and special education expertise, special education teacher training and resources, and psychological services on all IR middle school campuses with particular attention to Billy Earl Dade.

·         Increase in the size of classes for neighborhood secondary schools with large percentages of SPED and LEP students compared to magnet schools containing a much smaller percentage, or none, of these students.

·         Total, public transparency regarding campus climate surveys which should be available on every DISD campus web site to warn parents and communities about unsafe schools.


Teachers in both high SPED middle and high schools report a lack of visibility of special education services and personnel for students mainstreamed into regular classrooms.

While many IR middle and high schools seem to be supplanting special education dollars for regular education dollars, and the supplanting also seems to be taking place on campuses with high SPED populations that have not yet been rated IR, classroom teachers report no intersection with special education teachers who should be providing support for mainstreamed students. Special education teachers are not present in regular classrooms to assist the large numbers of mainstreamed students. This fact may play a major role in the large number of SPED-heavy schools on the state IR list.


Secondary classrooms have become crowded in many neighborhood schools where SPED and LEP students attend school compared to much lower student/teacher ratios and smaller classes for non-SPED and non-LEP students in choice schools.


Dallas ISD classroom teachers have also reported an inability to differentiate instruction for SPED and LEP students in secondary schools due to a cut in teachers’ collaborative planning period,  the addition of 5 hours of classroom instruction per week, lack of adequate training, overcrowded classrooms, and lack of special education support personnel visible in regular classrooms.


Increasing class sizes in IR schools, which contain large  percentages of SPED and LEP students, while removing sufficient planning time and support for teachers may have played a major role in failure at these schools. Collaborative planning time was pushed to an extended day for teachers and took place after school, exhausting teachers and providing more reasons for teacher talent to leave for the suburbs. These dysfunctional practices may stem partly from lack of equitable funding on these campuses.



·         Complainants are requesting that campus climate surveys be posted for public inspection on the web site of each public school in Dallas ISD in order to monitor schools that may need assistance in developing better discipline policies for students.

·         Complainants are requesting an investigation into current special education funding patterns than may indeed be supplanting regular education dollars, especially on campuses with high percentages of special education students and low levels of regular education funding.




6.       Lack of Appropriate Funding and Staffing to Decrease High School Attrition and EOC Failure and Violations of Equal Protection Guarantees

Roosevelt High School in Dallas ISD seemed to be on a path to improvement TEA Commissioner Michael Williams toured the school in the fall of 2012.

The current senior class at Roosevelt contained 179 members as sophomores as reported on the DISD web portal, MyDataPortal. On September 15, 2014, the senior class had dwindled to 75 seniors who were enrolled at Roosevelt.

The latest End of Course exams, taken by students in December, 2014 with results reported in January, 2015, left 59 Roosevelt seniors able to graduate based on their passage of all five End of Course exams required for graduation.

The next round of EOC exams will not take place until the spring, with results reported in early June, too late for a timely spring graduation for Dallas ISD seniors.

As of the latest round of EOC testing, only 6383 Dallas seniors are eligible for graduation, almost a thousand less than the senior class of 2014. Nowhere in any Dallas media outlet or at the Board level has this severe attrition and failure of EOC exams been discussed in their impact on this senior cohort.

This senior cohort has been the recipient of three years of Broad-based corporate reforms.

Complainants are requesting an investigation into the missing students at Roosevelt High School and the extremely high attrition rates for this 2015 senior cohort for Roosevelt, Conrad, Samuell, South Oak Cliff, Lincoln, Pinkston, Spruce, Carter, North Dallas, Thomas Jefferson, Bryan Adams, Sunset High School, WT White, Wilmer Hutchins, and Adamson. Combining high attrition and high failure rates on EOC exams has left these high schools with at least 30% to 60% of their sophomore cohort absent from a timely graduation in 2015 based on attrition rates since their sophomore year in addition to high EOC failure rates.

While the Texas Senate has lowered EOC graduation rates, had the Legislature not been in session, the effects of inequitable and inappropriate resourcing on these Dallas ISD campuses would have punished and impacted disproportionately LEP, SPED, at-risk, minority and poor students.

EOC pass rates have only been reported to the board as the percentage of current seniors who have passed all five tests. This methodology leaves the impression that Dallas ISD pass rates are just a little lower than the state average when in many cases, severe attrition in addition to failure on EOC exams may result in IR status in 2015.

Some missing students may have transferred to other DISD high schools since Skyline’s class of 2014 grew itself out of possible IR status based on low graduation rates by increasing the cohort by 70 students from in-district transfers. Skyline itself is extremely under-funded, but the increase in students eclipsed its high failure rates on EOC exams.

The misuse of credit recovery in low performing schools in order to increase graduation rates has already been documented in the senior class of 2013.

The attrition in the present senior class combined with high rates of EOC failure on IR campuses has lowered the graduating class by almost 2,000 students compared with their numbers as sophomores. Extreme attrition on many campuses is hiding the actual failure rates on End of Course exams.

Part of the under-resourcing of these campuses may be traced to moving state high school allotment dollars from weak campuses to magnet schools as a way of circumventing Title I comparability guidelines, but the majority of the problem seems to begin in under-resourcing regular education dollars for teaching the academic core in most high attrition high schools in addition to the absence of targeted plans for use of State Compensatory Education funds.

North Dallas High School had shown improvements with extra funding from a SIG that allowed an increase in student services personnel and an increase in collaborative planning time for teachers. When North Dallas returned to its previous low funding pattern, those necessary extra personnel disappeared along with increased planning time for teachers. Student attrition at North Dallas may return it to IR status because funding by Dallas ISD does not adequately resource the high school with a large population of homeless students.

 It appears that classroom financial cuts and cuts in student services personnel have damaged student retention and achievement levels in high SPED and LEP populations. Supplanting Title I dollars and underfunding regular education dollars may be the foundation for increased secondary attrition.

It appears that dropping collaborative planning periods, increasing class sizes, and underfunding high school campuses that are not magnet schools has increased attrition and lowered graduation rates, especially on campuses with high percentages of LEP and SPED students.

·         Complainants are requesting a full investigation by the federal Education Department into high attrition rates on Dallas ISD high school neighborhood campuses. Since Pearson has purchased the GED testing service in Texas, pass rates on the GED have plummeted. Many students in this year’s 2015 DISD graduation class who are missing from a timely graduation may never receive either a diploma or GED unless current graduation policies are changed by state legislators.


7.       A Disproportionately Negatively Impact on African American Students: Equal Protection Violations

ITBS scores of K-12 students in Dallas ISD present a pattern of declining abilities in reading over the past three years, a time of “disruptive reform” in Dallas ISD. Advanced Placement scores for neighborhood high schools with a majority of African American students have the lowest pass rates of all high schools. Special education placements are higher for African American students and research-based intervention policies, such as PBIS (Positive Behavior Interventions and Support) are almost nonexistent as a way of socializing students back into productive membership in school communities with high numbers of minority SPED students.

Increases in the achievement gaps between African American students and other racial and ethnic groups have been pervasive in past few years.  Graduation rates have been negatively impacted in the current senior cohort.

Complainants are requesting immediate, authentic comparability in a Title I formula based on floors for regular education spending in an attempt to increase instructional capacity in schools where the achievement gap is increasing. Complainants also request the Department of Education investigate disparities in suspension rates between racial and ethnic groups since suspension rates appear to be tied to race and the pass rates of Advanced Placement tests on comprehensive high school campuses show a direct correlation to race.


8.       Principal and Teacher Staffing: Violations of Equal Protection of LEP and SPED and At-Risk Students


From public information on uncertified and inexperienced teachers available on MyDataPortal, it is overwhelmingly clear that magnets, vanguards, and some non-Title I campuses have the highest level of experienced teachers, the lowest levels of teacher churn, and the lowest levels of principal churn.

These staffing patterns are a violation of No Child Left Behind statutes and equal protection guarantees for LEP, SPED, and At-Risk students.

While teacher churn across Dallas ISD has increased in the last couple of years, stripping away needed classroom dollars for teacher recruitment, the process of filling IR and Title I campuses with high percentages of non-experienced teachers who may hold no certifications has increased during the current administration with a focus a disruptive education reform.

From the Superintendent’s appraisal of Dallas ISD principals in 2014, the principals receiving Exemplary ratings, with the accompanying increase in pay, were all located on vanguard, Early College, or magnet school campuses. This rating system and staffing system are a violation of equal protection guarantees of LEP, SPED, and At-Risk and Title I  students since principal talent should be staffed equally across Title I and non-Title I campuses.

Complainants are requesting an investigation into principal churn rates, principal evaluations, and teacher appraisals and staffing for lack of comparability between Title I and non-Title 1 campuses and for IR schools with high percentages of SPED and LEP students.


9.       Illegal Hiring Preferences and Illegal Promotion Preferences: Teach for America and Broad

It is apparent from Dallas ISD employment portals that ask about Teach for America as well as Dallas ISD hiring and promotion patterns that Dallas ISD is violating federal equal protection guarantees in its hiring practices as well as violating the Civil Rights Act of 1964.

Dallas ISD and the state of Texas may engage in no practices that create set-asides for TFA or Broad-trained candidates without violating federal employment and constitutional guarantees regarding equal access for all job seekers. Since most Texas public schools are the recipients of federal funding, federal employment laws and constitutional guarantees of equal protection cannot be violated at whim. No Child Left Behind statutes that prohibit critical masses of uncertified and inexperienced teachers from providing instruction for low income and minority children are ignored in Dallas ISD which practices an overt system of preferential treatment in recruitment, hiring, and promotion for Teach for America and Broad-trained recruits who many times lack any certification, credentials, or experience for their assigned roles.

Complainants request an investigation into current employment and promotion practices in Dallas ISD where TFA has been given unfair advantage in hiring and promotion. Reports of TFA candidates being illegally recruited through job posting unavailable for the rest of Dallas teachers and other candidates violate federal employment laws as well as constitutional guarantees of equal protection.  Resumes of candidates who applied for executive positions and had more experience, credentials, and previous success in urban schools compared to the hired TFA and Broad candidates are available and provide evidence of illegal, discriminatory hiring patterns in Dallas ISD.

These illegal hiring patterns also remove equal protection guarantees from students since filling executive level leadership positions with candidates with no previous experience or credentials in their roles deprives students of the programmatic remedies that would be brought to the District through hiring candidates with successful track records and credentials.

It also appears that a crony system of patronage may exist that provides political support for the superintendent in exchange for executive jobs for candidates lacking credentials, training, or previous experience in their leadership roles.

All of these practices are in direct violation of federal law.


10.   Effective Models of Funding and Interventions for IR Schools are Available

Austin ISD does have a slightly higher amount of per student funding than Dallas ISD and a lower level of student poverty across the district, but Austin ISD does have traditionally low performing campuses that provide close demographic matches to DISD low performing campuses.

Unlike Dallas ISD, supplanting of federal or state compensatory is not in evidence on current Austin ISD IR campuses nor does Austin ISD take a punitive position in regard to its teachers. Austin ISD, smaller than Dallas ISD, has 126 Board Certified teachers.

Austin ISD’s campus funding model has been closely watched by the Texas Civil Rights Project and as a result, failing campuses get the funding and community support they need to help them transition off the list of IR campuses. Austin ISD’s Public Education Grant (PEG) list has shrunk through legally funding its failing campuses and using the collaboration of partnerships to help low achieving campuses. Dallas ISD’s PEG list continues to grow.

While Austin ISD inundates its IR campuses with a high floor of regular education funds in addition to supplemental funding, Dallas ISD uses a reverse Robin Hood plan that takes resources from the poorest schools while shuffling funding and its most experienced teachers to campuses with either low percentages of Title I students or its magnet schools of choice.

Complainants request that public hearings are held to demonstrate to the public and trustees the existence of legal and effective campus funding models and prescriptive remedies for failing campuses as evidenced in the success of Austin ISD or Irving ISD.

Since the public can monitor the supplanting of federal and state compensatory dollars once they understand how these dollars have replaced local monies in regular education funding, the existence of PEIMS records on the Texas Education Agency web site needs to be explained to the Board of Trustees as well as Dallas taxpayers.

Increasing the number of schools rated lowest in the state of Texas is not inevitable for Dallas ISD if research-based, programmatic remedies are used in conjunction with equitable and comparable sourcing in monies and staffing between Title I and non-Title I campuses and between schools meeting state standards and those in the Improvement Required category.


An examination of planned campus budgets for Dallas ISD for 2013-2014 proves that illegal supplanting occurred on Title I campuses, that magnet school campus budgets were rigged to avoid Title I comparability formulas in existence by the District, and that most Title I campuses were grossly underfunded in regular education dollars when compared with a similar bordering ISD with similar demographics and revenue.

There is no evidence that Dallas ISD Trustees knew of these illegal and unconstitutional violations of federal and state law due to annual power point presentations where central administrators assured Trustees that the District was operating under an equity model known as the “Dallas Miracle.”  ( )

There is no way for central administration to escape responsibility for under-funding Dallas ISD’s campuses full of LEP, special education, and at-risk students to an estimated $77 million dollars in one school year. All school administrators are trained on federal and state law regarding supplanting federal and state monies. Not only that, but it is apparent from examining the records that campus budgets were pulled from different buckets of funds by hand and revisited every year. The purpose seems to have been to protect magnet programs through hidden sourcing while pulling as many regular education dollars off Title I campuses as possible.

These regular education dollars could then be used to build the surplus budget and for special projects of central administrators.

It is incumbent upon Dallas ISD Trustees to change the current Title I comparability formula to one where regular education spending has floors on Title I campuses. The first revenue priority is legal and constitutional funding of the classrooms where the majority of Dallas ISD students reside and where LEP, SPED, and at-risk students are found in critical masses.

Pleading lack of funding will not work. Sitting at Dallas ISD’s borders is a school district that does not enjoy what should be the economies of scale found in Dallas ISD. The comparable district in revenue has the same issues of high poverty and high LEP and at-risk students as Dallas ISD. The comparable school district also seems able to maintain its physical structures for students in an efficient manner rather than having seas of portables on overcrowded campuses.

Dallas ISD must change its Title I comparability formula for the budget cycle of 2015-2016 to a formula with a floor for its most disadvantaged students.

In addition to pulling around $77 million dollars in regular education funding off its Title I campuses, Dallas ISD is also engaging in illegal staffing patterns on Title I campuses which are frequently overwhelmed with high numbers of teachers with no teaching experience. Some of these same campuses have lack of sourcing to deal with high levels of student misconduct.

IR Title I campuses also have a pattern of extremely high churn in principals and teachers and have the reputation of being “career enders” for educators. These staffing practices violate the equal protection guarantees of students on these campuses as well as NCLB statutes.

It is clear from the illegal funding and illegal staffing of Dallas ISD Title I and IR schools that the extremely high number of schools on the annual PEG list is not solely a function of high poverty in Dallas schools, but a function of illegal and unconstitutional spending and staffing patterns and lack of constitutional comparability between campuses with low levels of SPED, LEP, at-risk, minority and poor children and those with high levels of these students.

Sourcing in Dallas ISD funding, staffing, and programmatic remedies must follow student need, not the need of central administrators and some Trustees for bragging rights to an historically high level of surplus funds.

Continuing a pattern of chaotic, disruptive education reform that creates even higher teacher and principal churn in IR schools removes constitutional guarantees of equal protection from campuses with high percentages of LEP, SPED, and at-risk students.

We the undersigned hereby declare that the above is true and correct to the best of our knowledge and we file this complaint with the U.S. Department of Education in search of the above mentioned remedies:

1) Date: _____ Signature: __________________ Print Name: ________________


Address: __________________________City/zip: _________________________

Email: ____________________Phone:__________ Relationship: _____________


2) Date: _____ Signature: __________________ Print Name: ________________


Address: __________________________City/zip: _________________________

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3) Date: _____ Signature: __________________ Print Name: ________________


Address: __________________________City/zip: _________________________

Email: ____________________Phone:__________ Relationship: _____________


4) Date: _____ Signature: __________________ Print Name: ________________


Address: __________________________City/zip: _________________________

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5) Date: _____ Signature: __________________ Print Name: ________________


Address: __________________________City/zip: _________________________

Email: ____________________Phone:__________ Relationship: _____________


6) Date: _____ Signature: __________________ Print Name: ________________


Address: __________________________City/zip: _________________________

Email: ____________________Phone:__________ Relationship: _____________


7) Date: _____ Signature: __________________ Print Name: ________________


Address: __________________________City/zip: _________________________

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8) Date: _____ Signature: __________________ Print Name: ________________


Address: __________________________City/zip: _________________________

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9) Date: _____ Signature: __________________ Print Name: ________________


Address: __________________________City/zip: _________________________

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10) Date: _____ Signature: _________________ Print Name: ________________


Address: __________________________City/zip: _________________________

Email: ____________________Phone:__________ Relationship: _____________

[3] There is no evidence of SCE funds being reported through the appropriate “Accelerated Instruction” category on the PEIMS documents even though other school districts across Texas reported these funds correctly.