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A high school senior who was expelled from school just days before her graduation for possessing the drug known as ecstasy is entitled to receive a diploma because she completed the required coursework, Pennsylvania’s Commonwealth Court has held. The court, in an opinion by President Judge Joseph T. Doyle in Ream v. Centennial School District, found that the Bucks County Common Pleas Court properly ordered the Centennial School District to award Kristin Ream a diploma. Doyle said that once the school district allowed Ream to complete her coursework while the disciplinary hearing was pending, it had to grant her a diploma under the Pennsylvania General Assembly’s decree that a student who completes “the prescribed course of instruction in high school” is entitled to a diploma. In addition, the Commonwealth Court ruled in 1988 in Shuman v. Cumberland Valley School District Board of Directors, 536 A.2d 490, that a high school senior “may not be denied a high school diploma where she has successfully completed all the coursework required for graduation and is expelled after successful completion of her courses.” In May 1999, Ream, a senior at William Tennent High School, was arrested after Warminster Township police searched her car during a drug sweep at the school and discovered a ring box filled with the drug “ecstasy.” Ream told police she obtained the drugs at a Philadelphia nightclub. At the time of her arrest, Ream was already on probation for possession of marijuana and underage drinking. The school district immediately suspended her. While her disciplinary action was pending, Ream completed her coursework and her final examinations. After an informal hearing, school officials recommended that Ream remain suspended pending an expulsion hearing. At the June 15, 1999, expulsion hearing, Ream argued that she should be awarded a diploma because she had completed all of her coursework, examinations and other requirements for graduation. Ream further testified that she had been accepted to, and planned to attend, Pennsylvania State University and that her admission was contingent upon receipt of a high school diploma. The district expelled Ream and voted to deny her a diploma. After her expulsion, Ream earned her Graduate Equivalency Degree and was admitted to Penn State. She then appealed the district’s decision to the Bucks County Court of Common Pleas. The Common Pleas court ordered the school district to issue Ream a diploma after concluding that she completed the required coursework. The school district appealed. The school district asked the court to overrule Shuman, asserting that the ruling is extremely narrow and limited to the facts of that case. Moreover, Shuman contravenes the school code, which gives the school district the authority to suspend and/or expel students for disobedience, the district contended. The court declined to overrule the decision, finding it “does not in any way limit a school district’s right to promulgate rules and regulations governing the behavior of the students it oversees or to suspend or expel students as a disciplinary measure.” In a footnote, the court pointed out that the district had other options, such as to offer home tutoring without administering final exams until the outcome of the final hearing. In that way, a student who is exonerated may still receive a timely diploma, while the diploma may be denied to those who are not exonerated. “It was the District that chose, in this instance, to proceed with the student’s education and permitted the student to sit for her final examinations,” said the court. “Once having permitted that to occur, Section 1613 of the School Code mandates that the District issue a certificate.”

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