In re Proposed Quest Academy Charter School of Montclair Founders Group

The New Jersey Legislature’s Charter School Program Act of 1995 (the act) granted the commissioner of education (the commissioner) (defendant) the power to approve and grant school charters. The act detailed the strict process for applying to establish a new charter school in New Jersey. State statutes and regulations provided detailed requirements for charter-school applications, but they provided little guidance on how a commissioner should evaluate a particular application. Tracey Williams (plaintiff), a founder of the proposed Quest Academy Charter School of Montclair (Quest Academy), applied for licensure for a new charter school. The Montclair public school superintendent, as well as concerned Montclair community members, provided comments opposing Quest Academy’s application. The opponents asserted that the proposed charter school would negatively affect desegregation efforts and funds available to Montclair public schools. The commissioner tersely denied Quest Academy’s application, but she offered Williams the opportunity to discuss the application’s deficits and participate in a training program designed to help charter-school applicants resubmit applications. Williams filed a notice of appeal of the commissioner’s denial to the New Jersey state appellate court. The commissioner then issued a written amplification statement enumerating her specific reasons for denying Quest Academy’s application. The state appellate court upheld the commissioner’s denial of the application, finding that the commissioner’s decision was not arbitrary, capricious, or unreasonable. Williams appealed to the New Jersey Supreme Court, arguing that the process by which a commissioner decides whether to grant a charter-school application constituted an adversarial quasi-judicial process and, therefore, required a hearing and written record. Accordingly, Williams asserted that the correct standard for appellate review of the commissioner’s decision should have been whether the application was supported by substantial credible evidence. The commissioner argued that the process of considering charter-school applications was a quasi-legislative process and that the appellate court used the correct standard—whether the denial was arbitrary, capricious, or unreasonable—to affirm her decision.