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CAUSE NO.

_________ _
ALLIANCE/AFT





IN THE DISTRICT COURT
Plaintiff,
DALLAS COUNTY, TEXAS
v.
DALLAS INDEPENDENT SCHOOL
DISTRICT
Defendant. ___ JUDICIAL DISTRICT
PLAINTIFF'S ORIGINAL PETITION,
APPLICATION FOR TEMPORARY RESTRAINING ORDER
REQUEST FOR TEMPORARY INJUNCTION, AND
REQUEST FOR DISCLOSURES
TO THE HONORABLE JUDGE OF THE COURT:
COMES NOW ALLIANCE/AFT, the plaintiff, complaining of Dallas Independent
School District, the defendant, acting through its board of trustees. The plaintiff files this petition
for declaratory judgment pursuant to the provisions of the Uniform Declaratory Judgments Act,
Tex. Civ. Prac. & Rem. Code Section 37.001 et seq. The plaintiff seeks a declaration of the
rights and benefits afforded by Tex. Educ. Code Section 12.015(b), the provision of the Texas
Education Code governing the composition of a home-rule school district chatter commission, as
well as Tex. Educ. Code Section 11.25l(e), the provision requiring that the professional staff
representatives who select the teachers on the charter commission be elected. Essentially, as
detailed herein, the plaintiff maintains that the individuals who have selected the teacher
representatives for the charter commission do not possess the requisite legal authority to do so
because they were appointed to their positions rather than being elected as required by Tex.
FILED
DALLAS COUNTY
6/11/2014 4:20:54 PM
GARY FITZSIMMONS
DISTRICT CLERK
DC-14-06281
Smith Gay
14TH-A
Educ. Code Section 11.25l(e). The plaintiff seeks to enjoin the Dallas Independent School
District board of trustees from acting outside its statutory and legal authority in appointing
improperly selected teachers to the charter commission. The plaintiff would respectfully show
the court as follows:
I. DISCOVERY
1. Discovery is intended to be conducted under Level II.
II. PARTIES
2. Plaintiff Alliance/ AFT is a labor organization that represents classroom teachers
and other employees who are employed by the Dallas Independent School District. Alliance/
AFT is a local affiliate of Texas American Federation of Teachers, a statewide labor
organization, and the American Federation of Teachers, a national labor organization. It is also
affiliated with the AFL-CIO. Alliance/ AFT represents its members in matters related to their
wages, hours, and terms and conditions of employment. Alliance/AFT has approximately 7000
members, approximately 4800 of whom are classroom teachers. As required of labor
organizations representing public employees in Texas, Alliance/AFT does not claim the right to
strike. Alliance/ AFT has its principal place of business at 334 Centre Street, Dallas, Texas,
75208-6504, in Dallas County, Texas.
3. Defendant Dallas Independent School District ("DISD" or "the District") IS a
political subdivision and independent school district within the meaning of the Texas Education
Code, organized pursuant to law, and charged with the responsibilities of operating and
maintaining a public school district within its geographical boundaries. It may be served with
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process through service on its superintendent, Dr. Mike Miles, Dallas I.S.D., 3700 Ross Avenue,
Dallas, Texas 75204.
III. JURISDICTION AND VENUE
4. This Court has jurisdiction under Texas Civil Practice & Remedies Code Sections
37.004, 37.011, 65.011 and 65.023(a). Venue is proper in this Court pursuant to Texas Civil
Practice & Remedies Code Section 15.002(a)(l) & (3).
IV. ASSOCIATIONAL STANDING
5. Alliance/AFT has approximately 7000 members. Approximately 4800 of those
members are classroom teachers. Alliance/ AFT is interested in enforcing and protecting those
members' rights under the Texas Education Code, including their right to have the classroom
teacher members on the home-rule charter commission selected in accordance with the law
designed to insure fair and democratic representation. Alliance/ AFT is vitally interested in
protecting the learning enviromnent of DISD students and the employment rights of its members,
both of which will be on the line as the home-rule chatter commission determines the contours of
the chatter. Thousands of Alliance/AFT's members are aggrieved by the actions of the
defendant and the organization brings this declaratory judgment action on their behalf.
6. Alliance/ AFT has as one of its central purposes the protection of employment rights
and benefits of its members. This declaratory action is germane to that purpose.
7. Alliance/AFT's members who are aggrieved by the actions of the defendant have
standing to file this action on their own behalf.
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8. Neither the claims asserted herein nor the relief requested requires the filing of
individual petitions for declaratory judgment nor the participation of individual members as
patties in this action.
V. STATEMENT OF FACTS
9. Tex. Educ. Code Section 12.011 et seq. provides a process through which a school
district may adopt a home-rule school district chatter under which the district will operate. Under
these provisions, a school board names a charter commission, which then has one year to write a
proposed charter. Tex. Educ. Code 12.0 15( c). The proposed chatier must ultimately be approved
in an election in which the adoption of the chatter is on the ballot and in which at least 25% of the
registered voters of the district vote. Tex. Educ. Code 12.022(a).
10. The home-rule school district charter law has profound consequences for the
educational system provided by a school district. Its provisions allow a school district to operate
largely free of the state laws that exist to safeguard educational quality. In a home-rule charter, a
school district is subject to the Education Code only to the extent that the Education Code
specifically provides and to the rules of the State Board of Education or the Commissioner of
Education only to the extent that they specifically provide. Tex. Educ. Code 12.012(a)(1) and
(2).
11. This means that, for example, a charter commission could devise a chatter under
which teachers would lose their current rights under the Texas Education to have employment
contracts, due process in termination or nomenewal proceedings, a minimum salary schedule,
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plamting and preparation time, duty-free lunch, and leaves of absences for temporary disability.
These are rights that Texas teachers have fought long and hard to secure and that have been in
place for decades.
12. The process for the development of a home-rule school district charter is begun if the
school board "receives a petition requesting the appointment of a charter commission to frame a
home-rule school district chmier signed by at least five percent of the registered voters of the
district." Tex. Educ. Code 12.014(1).
13. On May 22, 2014, the DISD board of trustees accepted a petition circulated by a pro-
home-rule district charter organization, Support Our Public Schools. After disqualifying about
21,000 signatures, DISD administrators represented that it had verified signatures of
approximately 24,650 individuals, barely meeting the 5% threshold. The board of trustees
accepted the administration's representation and moved to take the next step towards the
development of a charter, which is the naming of a 15 member charter commission.
14. The home-rule school district chmier statute contains specific provisions regarding the
make-up of the charter commission. Most significantly for the purposes of this action, "at least 25
percent of the commission must be classroom teachers selected by the representatives of the
professional staff pursuant to Section 11.25l(e)," a provision in the Education Code petiaining to
a district-level advisory committee. Tex. Educ. Code 12.015(e). Additionally, the charter
commission must be composed of residents of the district and must reflect "the racial, ethnic,
socioeconomic, and geographic diversity of the district." Tex. Educ. Code 12.015(a) and (b). A
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majority must be parents of school-age children attending public school. Tex. Educ. Code
12.015(b).
15. The district-level advisory committees referred to in Tex. Educ. Code Section
11.251(e) were part of the Texas Legislature's efforts in 1995 to ensure that professional
educators had a role in local planning and decision-making. Section 11.251 sets up a
comprehensive scheme under which each school district has a district-wide planning and
decision-making committee composed of professional staff representatives, parents, business
representatives, and community members, as well a campus-level committees. Tex. Educ. Code
Section 11.251 (b). These "site-based decision-making" committees were set up by the
legislature to ensure the involvement of the school community in "planning, budgeting,
curriculum, staffing patterns, staff development, and school organization." Tex. Educ. Code
Section 11.251(d). The district-level committee meets with the board or the board's designee
during the school year to provide input and approval on such matters.
16. Tex. Educ. Code Section 11.251 (e) requires that the professional staff representatives
on the district-level committee be elected democratically. The law states: "The board shall adopt
a procedure ... for the professional staff in the district to nominate and elect the professional staff
representatives who shall meet with the board or the board designee as required under this
section. At least two-thirds of the elected professional staff representatives must be classroom
teachers" (emphasis added). The parents, community members and business representatives are
selected in accordance with district policy. In other words, while the statute allows school
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districts latitude in the method of selecting other members on the district-level committee, the
legislature explicitly required that teacher representatives be elected by their peers.
17. In accordance with Section 11.251 (e), DISD has adopted policies providing for and
governing the election of professional staff representatives to the district-level advisory
committee. A true and correct copy of the policies is attached and incorporated herein as Exhibit
A-1 and A-2. Under DISD Policy BQA (Local), the district-level committee "shall be composed
of at least 15 members who shall represent campus-based professional staff, District-level
professional staff, parents, businesses, and the community. At least two-thirds of the elected
professional staff representatives must be classroom teachers and the remaining staff
representatives shall include both campus- and District-level professional staff members." As far
as elections are concerned, DISD policy fmiher provides, "The consent of each nominee shall be
obtained before the person's name may appear on the ballot. Election of the committee shall be
held in the fall of each school year at a time determined by the Board or its designee. Nomination
and election shall be conducted in accordance with this policy and administrative regulations."
Elected representatives "shall serve staggered two-year terms." Exhibit A-1.
18. Effective for the 2013- 14 school year, DISD had in place a district-level committee
composed of 30 individuals. A true and COlTect copy of the roster of the committee is attached
and incorporated herein as Exhibit A-3.
19. Contrary to the provisions of the law and the district's own policy, the professional
staff members of the district-level committee in 2013-2014 were not elected by the professional
staff in the district. On information and belief, for many years prior to 2013-2014, the
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professional staff representatives have been selected by campus principals. See Affidavit of Rena
Honea, attached and incorporated herein as Exhibit A; Affidavit of Jimmy Guillory, attached and
incorporated herein as Exhibit B; Affidavit of Mary Ann Climer, attached and incorporated
herein as Exhibit C. Additionally, legal counsel for DISD has confirmed that members on the
district-level committee are "nominated by their campuses." See April 21, 2014 correspondence
from DISD counsel Leticia McGowan to Mary Ann Climer, a tme and correct copy of which is
attached and incorporated as Exhibit. C-4. Further, in the Site-Based Decision-Making manual
published on its website, DISD states that teachers serving on the district-level committee will be
selected from Inside Track representatives. See SBDM Manual at 7, a tme and correct copy of
which is attached and incorporated herein as Exhibit A-4. Inside Track is an organization
existing to facilitate communication between the central and campus administrations. ld. at 12;
see also Honea Affidavit, Exhibit A-4. Inside Track representatives are selected by campus
principals. See Dallas ISD Communicator, August 2009, "Inside Track gets a facelift," a tme and
correct copy of which is attached and incorporated as Exhibit A-5.
20. Since DISD has failed to comply with Tex. Educ. Code Section 11.251(e) and its
own policies BQA (Legal) and BQA (Local) mandating the election of professional staff
representatives to the district-level committee, it lacks the elected professional staff
representatives on that committee who can perform the statntory duty prescribed by Tex. Educ.
Code Section 12.015(b) to name the classroom teachers on the charter commission.
21. Notwithstanding the fact that it did not have an elected district-level committee
capable of making selections of teacher representatives as required by Tex. Educ. Code Section
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12.015(b), DISD nonetheless ananged for the professional staff representatives on its district-
level committee to screen and choose the teacher representatives for the chatter commission. On
or about June 6, 2014, DISD announced that the non-elected professional staff representatives on
the district-level committee had selected the four classroom teachers, along with two alternates,
to serve on the chatter commission. See a true and cmTect copy of the DISD website publication
dated June 6, 2014, attached and incorporated as A-6.
22. While as of the date of the filing of this cause, the DISD board of trustees has not
confirmed the appointment of these teacher representatives to the chatter commission, this action
is imminent. The DISD board of trustees is scheduled to meet on June 12, 2014, a meeting at
which it could confirm the appointment of these chatter commission members. See Agenda for
June 12, 2014, a true and correct copy of which is attached and incorporated as Exhibit A-7.
Futther, the board has announced publicly that it believes that it is obligated under the terms of
Tex. Educ. Code Section 12.015(a) to appoint all chatter commission members no later than June
21, 2014, thirty days after the date (May 22, 2014) upon which it received the petition calling for
the appointment of a charter commission. See Honea Affidavit, Exhibit A. Under the board's
announced timeline, then, the last possible date that the board would act to confirm the
appointment of the teacher representatives would be June 21, 2014, little more than one week
away.
23. The board's appointment of illegally selected teacher representatives to serve on the
charter commission will have an immediate and substantial negative effect on the ability of the
charter commission to accurately and faithfully reflect the interests of classroom teachers.
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Whatever the merits of the teachers who have been named to serve on the charter commission,
the teachers who selected them were not democratically elected by their peers, as required by law
and policy, and cannot legally perform the statutory duty with which they are charged. The
interests and views of the DISD administrators who appointed them to serve on the district-level
committee are not necessarily aligned with the interests of teachers in DISD and the conm1ittee
representatives were not endorsed by their colleagues. This is of critical importance, especially
given that the chmier commission has the authority to design a home-rule chmier that could
substantially alter, reduce and eliminate rights and benefits of teachers.
24. Alliance/AFT's members will suffer immediate and irreparable harm if they are not
represented on the home rule school district charter commission by teachers who have been
selected by their democratically-elected representatives.
VI. CLAIMS
25. Paragraphs 1 through 22 are incorporated herein.
26. The defendant has used a district-level advisory committee constituted in violation of
Tex. Educ. Code Section 11.251(e) to name teachers to serve on the home-rule school district
chmier commission. This violates the requirement in Tex. Educ. Code Section12.015(b) that the
classroom teachers on the charter commission be "selected by the representatives of the
professional staff pursuant to Section11.251( e)."
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VII. APPLICATION FOR TEMPORARY RESTRAINING ORDER
27. Plaintiff has notified the defendant regarding its application for a temporary
restraining order and the hearing for same in compliance with T.R. Civ. P. 680 and Dallas
County Local Rule 2.02.
28. Plaintiffs application for a temporary restraining order is authorized by Texas Civil
Practice & Remedies Code Section 65.011 (!), (2) and (3). Further, plaintiff is entitled to this
form of relief under traditional equity principles.
29. Plaintiff asks the Court to prevent the defendant's board of trustees from appointing
classroom teachers, including but not limited to the teachers selected by the district-level
advisory committee on or about June 4, 2014 (published on June 6, 2014) to the home-rule
school district charter commission, unless and until such classroom teachers have been selected
by professional staff representatives elected to the district-level advisory committee in
accordance with Tex. Educ. Code Section 11.251(e).
30. The purpose of a temporary restraining order and/or temporary injunction is to
preserve the status quo of the litigation's subject matter pending a trial on the merits. Butnaru v.
Ford Motor Co., 84 S.W.3d 198,204 (Tex. 2002). Under traditional equitable relief principles,
in order to obtain this relief, a party must plead and prove: (I) a cause of action against the
defendant; (2) a probable right to the relief sought; and (3) a probable, imminent, and irreparable
injury in the interim. !d.; Amend v. Watson, 333 S. W.3d 625, 627 (Tex. App. -Dallas 2009, no
pet.). This dispute meets these requirements.
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31. Plaintiff pleads a clause of action against defendant. The first injunction
requirement is for the applicant to plead a cause of action against the defendant. Walling v.
Metcalfe, 863 S.W.2d 56, 58 (Tex. 1993). Plaintiffs allegations are detailed in this petition.
32. Plaintiff Has a Probable Right to the Relief Sought. An applicant need not prove
that it will prevail on the merits at trial, but is only required to show a probable right to relief on
the merits and a probable injury in the interim. Sun Oil Co. v. Whitaker, 424 S.W.2d 216,218
(Tex. 1968). It is probable that the plaintiff will recover from defendant after a trial on the merits
because the defendant has violated plain and unambiguous requirements ofT ex. Educ. Code
Sections 11.25l(e) and 12.015(b).
33. Plaintiffs Will Suffer a Probable, Imminent, and Irreparable Injury. An injury
is irreparable if there is no adequate remedy at law as where, for example, a prevailing applicant
could not be compensated adequately in damages, or if damages cannot be measured by any
certain pecuniary standard. Benefield v. State, 266 S.W.3d 25, 30 (Tex. App.- Houston [1 Dist.]
2008, no pet.). This is the case here. If plaintiffs application is not granted, the members of
Alliance/AFT will suffer immediate and certain injury. Harm is imminent because the defendant
has convened the illegally constituted district-level advisory committee for the express purpose
of securing the committee's selection of classroom teacher representatives to serve on the charter
commission and is poised to appoint those individuals to the charter commission. If the
application is not granted, the members of Alliance/AFT and the classroom teachers of Dallas
ISD will be deprived of representation on the commission by individuals who were selected by
democratically elected representatives. There is no remedy that could be provided that would
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replace the contributions made by classroom teachers who have been endorsed through the
operation of democratic procedures. The stakes for classroom teachers could not be higher and
their true voice and opinions deserve to be heard. They deserve to have their interests protected
and served by commission members who have been chosen in accordance with the law. The
granting of the plaintiffs application for injunctive relief would merely preserve the status quo
pending the proper election of a district-level advisory committee and the subsequent naming of
charter commission members by the duly-elected professional staff representatives on the
district-level committee.
34. Although the Court is not required to consider the balance of equities or interests in
deciding whether to grant an application for equitable relief, it is important to note that the
defendant would not suffer any harm by delaying the appointment of the charter commission
until such time as elections can be held for the professional staff representatives on the district-
level committee and those persons can name the classroom teachers to serve on the charter
commission. Under Tex. Educ. Code Section 12.015(c), the charter commission has one year
from its appointment to complete the writing of the proposed charter.
35. Plaintiff is willing and able to post bond. However, the plaintiff notes that under TEX.
R. CIV. P. 684, because defendant is a governmental entity and has no pecuniary interest in the
suit and no monetary damages can be shown, the Court has discretion to fix the sum of the bond.
36. Plaintiffs application for a temporary restraining order is supported by the following
exhibits:
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A. The affidavit of Rena Honea, president of Alliance/ AFT and member of the
district-level advisory committee, attached as Exhibit A and incorporated herein,
along with exhibits 1 - 7 ;
B. The affidavit of Jimmy Guillory, classroom teacher and member of the district-
level advisory committee, attached as Exhibit B and incorporated herein;
C. The affidavit of Mary Ann Climer, citizen of Dallas, attached and incorporated
herein as Exhibit C, along with exhibits 1 - 4;
VIII. REQUEST FOR TEMPORARY INJUNCTION
37. Plaintiff asks the Court to set its application for temporary restraining order/temporary
injunction for a hearing, and after the hearing, issue a temporary injunction against the defendant.
38. Plaintiff has joined all indispensable parties under TEX. R. CIV. P. 39.
IX. SUIT FOR DECLARATORY RELIEF
39. Plaintiff requests that this Court declare and determine the existing rights of the
classroom teacher members of Alliance/ AFT that are afforded by Tex. Educ. Code Sections
11.25l(e) and 12.015(c), as well as whether the defendant's actions described herein, violate
those rights.
X. NO SOVEREIGN IMMUNITY FOR CLAIMS
38. Plaintiff is entitled to all these forms of relief. Defendant is not protected from any
of plaintiffs causes of action, or forms of relief, by goverl1lllental immunity (or in the
alternative, such immunity has been waived). Specifically, a government official in his official
capacity and/or a government entity is liable for declaratory and injunctive relief if there has
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been a violation of a state constitutional provision or statute, as such actions are illegal and ultra
vires. Similarly, the defendant is not protected by any form ofitn111unity, and is liable to plaintiff
for an award of attorney's fees and costs (as determined to be equitable and just), pursuant to,
inter alia, TEX. CJV. PRAC. & REM. CODE 37.009.
XI. NO REQUIREMENT FOR EXHAUSTION OF ADMINISTRATIVE
REMEDIES
39. Plaintiff is not required to exhaust administrative remedies because the relief
requested herein is not available through any administrative agencies. Parties are not required to
pursue an administrative process regardless of the price. Houston Federation of Teachers, Local
2415 v. Houston ISD, 730 S.W.2d 644 (Tex. 1987). "If irreparable harm will be suffered and if
the agency is unable to provide relief, the comts may properly exercise their jurisdiction in order
to provide an adequate remedy." !d.
XII. REQUEST FOR DISCLOSURE
40. Under Texas Rule of Civil Procedure 194, plaintiff requests that defendant disclose,
within 50 days of the service of this request, the information or material described in Rule 194.2.
XIII. OBJECTION TO ASSOCIATE JUDGE
41. Plaintiff objects to the referral of this case to an associate judge for hearing a trial on
the merits or presiding at a jury trial.
XIV. RELIEF REQUESTED
WHEREFORE, PREMISES CONSIDERED, plaintiff respectfully request that:
I. The defendants be cited to appear and answer.
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2. The Court issue a temporary restraining order and upon hearing, a temporary
injunction, barring the defendant's board of trustees from appointing any classroom teachers,
including but not limited to the teachers selected by the district-level advisory committee on or
about June 6, 2014, to the home-rule school district chatter commission, unless and until such
classroom teachers have been selected by professional staff representatives elected to the district-
level advisory committee accordance with Tex. Educ. Code Section 11.251 (e).
3. The Comt declare and determine that the defendant's actions with respect to the
district-level advisory conm1ittee and home-rule school district charter collllllission, as described
herein, violates the defendant's obligations and the rights of the plaintiffs members under Texas
Education Code Sections 11.251(e) and 12.015(b).
4. The Court issue appropriate permanent injunctive relief enjoining the defendant from
violating the rights of the plaintiffs members under Texas Education Code Sections 11.251(e)
and 12.015(b).
5. Plaintiff be awarded attorneys fees and expenses, as provided for under Tex. Civ.
Prac. & Rem. Code Section 37.009.
6. Plaintiff be awarded all other relief to which the Coutt may find it entitled.
Respectfully submitted,
Edward B. "Ed" Cloutman, III
State Bar No. 04411000
crawfish11@prodigy.net
Edward B. Cloutman, IV
State Bar No. 24074045
edcloutman@prodigy.net
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CLOUTMAN & CLOUTMAN, L.L.P.
3301 Elm Street
Dallas, Texas 75226-2562
(214) 939-9222
(214) 939-9229- fax
DEATS, DURST, OWEN & LEVY, P.L.L.C.
1204 San Antonio, Suite 203
Austin, Texas 78701
(512) 474-6200
(512) 474-7896- fax
Is/ Matiha P. Owen
Martha P. Owen
State Bar No. 15369800
mowen@ddollaw.com
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VERIFICATION
l.(((./
Before me, a notary public, on this 11 day of June, 2014, personally appeared Rena Honea,
known to me to be the person whose name is subscribed to the foregoing Original Petition,
Application for Temporary Restraining Order, Request for Temporary Injunction, and Request for
Disclosures, document, and being by me first duly sworn, declared that she has read the factual
statements therein contained, that he shas personal knowledge of those statements, and that they are
true and correct.

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LL
Notary Public in and for
The State of Texas
AFFIDAVIT OF RENA HONEA
STATE OF TEXAS
COUNTY OF DALLAS
BEFORE ME, the undersigned authority, on this day personally appeared Rena Honea,
who, after being sworn upon her oath, states the following:
1. My name is Rena Honea. I am the president of Alliance/AFT, Local2260.
2. I am over 21 years of age and of sound mind. I have never been convicted of a
crime. I am fully competent to testifY as to the matters stated herein. I have personal
knowledge of the facts stated in this affidavit and they are all true and correct.
3. I have been the elected president of Alliance/AFT since2009. From 2004 to 2009,
prior to being elected as president, I served as the Director of the Education Center, Inc. for the
Alliance/ AFT. Prior to becoming employed by Alliance/ AFT, I was employed as a classroom
teacher by Dallas ISD. I was a teacher at Cowart Elementary from 1978 to 2004.
4. Alliance/AFT is a labor union representing teachers and other employees employed
by Dallas ISD. It is a labor organization that exists in whole or in part to deal with Dallas ISD
concerning grievances, labor disputes, wages, hours of employment, and working conditions. It is
affiliated with the Texas American Federation ofTeachers, a statewide organization, and with
the American Federation of Teachers, a national organization, and the state and national
AFL-CIO.
5. The Alliance is a voluntary employee organization. The Alliance has approximately
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EXHIBIT
i ~
~ - - - -
7000 members. Approximately 4800 of those members are classroom teachers. The Alliance
provides a variety of services and benefits to its members. For example, the Alliance advocates
for employees' interests with DJSD administration and before the DISD board of trustees,
provides assistance to members who are having employment issues/problems with DISD,
pruiicipates on the employee consultation team with DISD, provides professional development,
provides liability insurance, and through its affiliates, Texas AFT and AFT, lobbies for public
education employees' interests before the Texas legislature and Congress.
6. In my role as president, I am the chief executive officer and spokesperson for
Alliance/ AFT. I run the Alliance office on a day-to-day basis, supervise its employees who
organize and service members, attend school board meetings, meet with DISD administrators,
DISD school board members and Alliance/AFT members, and advocate for Alliance members. I
am a member ofDISD's district-level advisory committee and DISD's consultation committee
for employees. As president, I am familiar with the various organizations and channels that DISD
has created for the purpose of communicating with employees, such as Inside Track. Fnrther, as
president, I keep abreast ofDISD initiatives, policies, and activities that are of importance to
Alliance/AFT members and DISD employees.
7. As president, I have been actively monitoring the petition submitted by the Support
Our Public Schools organization to have DISD create a home-rule school district charter, as well
as the actions of the DISD board of trustees in response to that petition, including the
appointment of a commission to write the charter. I have been following those developments
closely as this is an issue of utmost importance to DISD employees, including but not limited to
its members who are teachers. The Alliance is vitally interested in protecting the learning
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environment ofDISD students and the employment rights of its members. I am familiar with the
provisions in the Texas Education Code that pertain to the home-rule school district charter
process and am aware that under this process, the charter commission that is appointed by the
school board has the authority to opt-out of most legal protections, rights and benefits for
teachers and other employees. I have met with and talked with countless concerned and worried
teachers and other DISD employees.
8. On May 22, 2014, I attended the board meeting at which the DISD board accepted the
petition circulated by Support Our Public Schools to force the creation of a home-rule school
district charter commission. DISD has created a link on its website, www.dallasisd.org/homerule,
in which it publishes information regarding this issue. I regularly visit and review that website.
Attached and incorporated into this affidavit as Exhibit A- 6 is a notice that was published on the
DISD website describing the board's action on May 22, 2014, as well as announcing that the
board would move to name a commission within 30 days. That same notice contains an
announcement from June 6, 2014 to the effect that the District-wide Advisory Committee (DAC)
had taken action to select four teachers (and two alternates) to serve on the charter commission.
9. The DISD board is scheduled to meet on Thmsday, June 13, at 3:00p.m. Based on the
agenda for the meeting that has been posted for that day, a true and correct copy of which is
attached and incorporated herein as Exhibit A-7, I anticipate that the board will take formal
action to select the teacher representatives identified by the DAC last week to serve on the
charter commission as the representatives of classroom teachers. Further, I have heard the board
state publicly on a number of occasions, including at the board meeting on May 22, 2014, that it
would name the chmter commission members no later than June 21, 2014.
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10. Through myro1e as president, I am familiar with the Texas laws providing for the
creation of district-level planning and decision-making committee. In DISD, that committee is
known as the Districtwide Advisory Council ("DAC"). As the president of Alliance/AFT, I am a
member oftheDAC. I began serving on theDAC in the 2011-2012 school year.Attached and
incorporated into this affidavit as Exhibit A - 3 is a true and correct copy of the roster of
members in 2013 - 20 I 4. The DAC is composed of professional staff members, parents,
community members, and business members. Of the professional staff members ofthe
committee, this past year, there were I 4 teachers, along with some instructional coaches and
principals. To my knowledge, since I became president of Alliance/AFT in 2009, DISD has not
conducted elections as the means of selecting the professional staff members to serve on the
DAC. Instead, professional staff members are selected by their campus principals or other
administrators to serve on the DAC.
11. DISD has published on its website, www.dallasisd.org, a manual for Site-Based
Decision Making. A true and correct copy of this manual (minus the appendices) is attached and
incorporated herein as Exhibit A-4. This describes the decision-level advisory committee and
states that members ofthe DAC will be selected from Inside Track representatives. See page 7 of
Exhibit A-4. I am familiar with the Inside Track organization. Inside Track is an organization
that is supposed to give employees a way to communicate with DISD administrators. As part of
the information that I gather on a regular basis about DISD, I review a publication entitled Dallas
ISD Communicator. Attached and incorporated herein as Exhibit A-5 to this affidavit is a true
and correct copy of the August 2009 issue of the Dallas ISD Communicator that reflects that
Inside Track representatives are selected by principals.
4
12. As president, I am familiar with the policies of Dallas ISD, particularly as they deal
with matters pertinent to employees. Dallas ISD publishes its policies though a link on its
website, www.dallasisd.org. Attached and incorporated herein as Exhibit A-I is a true and
correct copy of the DISD local policy on the district-level advisory committee, BQA (Local).
Attached and incorporated herein as Exhibit A-2 is a true and correct copy of the DISD legal
policy on the district-level advisory committee, BQA (Legal). Again, while these policies provide
for the election of professional staff members to the DAC, I am not aware of such elections
having taken place at least since 2009, when I became president.
Further Affiant sayeth not.
Signed this 11 day ofJune, 2014.
RENA HONEA
BEFORE ME, the undersigned Notary Public, on this day personally appeared Rena
Honea, who being by me duly sworn upon oath deposed and stated that she has read the above
Affidavit; that she is cognizant of all facts stated above and that all of the information is true and
correct to the best of her knowledge.
SUBSCRffiED AND SWORN TO before me on this the ) \:J:hday of June, 2014 to
witness which my hand and official seal of office.
-
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My Commission Expires: g-'L v-I ( (J
6
Dallas lSD
057905
PLANNING AND DECISION-MAKING PROCESS
DISTRICT-LEVEL
BOA
(LOCAL)
DISTRICT-LEVEL
COMMITTEE
CHAIRPERSON
MEETINGS
DUTIES OF
COMMITTEE
COMPOSITION
In compliance with Education Code Section 11.251, the District-
level committee shall advise the Board or its designee in establish-
ing and reviewing the District's educational goals, objectives, and
major Districtwide classroom instructional programs identified by
the Board or its designee. The committee shall serve exclusively in
an advisory role except that the committee shall approve staff de-
velopment, in accordance with minimum standards developed by
the Commissioner of Education, of a Districtwide nature.
The Superintendent of Schools shall be the Board's designee who
shall appoint the committee's chairperson from among the commit-
tee's members. The Superintendent of Schools shall meet with the
committee periodically.
The chairperson of the committee, in consultation with the Superin-
tendent of Schools or designee, shall set its agenda, which must
be based on the areas noted in statute [see BQA(LEGAL)] and Dis-
trict goals. Meetings shall be held four times per year; additional
meetings shall be held at the call of the Superintendent of Schools.
All committee meetings shall be held during the regular school day
and shall not be open to the public, except for the annual public
meeting held in conjunction with a regularly scheduled Board meet-
ing after receipt of the District-level performance report.
The committee shall perform duties as described in BQA(LEGAL).
The committee shall be composed of at least 15 members who
shall represent campus-based professional staff, District-level pro-
fessional staff, parents, businesses, and the community. At least
two-thirds of the elected professional staff representatives must be
classroom teachers and the remaining staff representatives shall
include both campus- and District-level professional staff members.
The Superintendent of Schools or designee shall develop proce-
dures for:
1. The selection of parents to the District-level and campus-level
committees, and
2. The selection of community members and business represen-
tatives to serve on the District-level committee in a manner
that provides for appropriate representation of the commu-
nity's diversity.
For purposes of this policy, "District-level professional staff" shall
be defined as professionals who have responsibilities at more than
one campus, including, but not limited to, central office staff. [See
BQA(LEGAL) for the definition of "parent" and "community mem-
ber"]
DATE ISSUED: 10/1/2008
LDU 2008.13
BQA(LOCAL)-X
EXHIBIT
& -1.
1 of 2
Dallas lSD
057905
PLANNING AND DECISION-MAKING PROCESS
DISTRICT-LEVEL
BQA
(LOCAL)
ELECTIONS
TERMS
VACANCY
OTHER ADVISORY
GROUPS
Business member representatives need not reside in nor operate
businesses in the District.
An employee's affiliation or lack of affiliation with any organization
or association shall not be a factor in either the nomination or elec-
tion of representatives on the committee. [See also DGA(LEGAL)
and (LOCAL)] The Classroom Teacher Organization shall continue
to function as a consulting body representing the memberships of
employee associations/organizations with respect to wages, hours,
and working conditions under applicable laws of the state, which
are not part of the requirements of the planning and decision-
making committees.
The consent of each nominee shall be obtained before the per-
son's name may appear on the ballot. Election of the committee
shall be held in the fall of each school year at a time determined by
the Board or its designee. Nomination and election shall be con-
ducted in accordance with this policy and administrative regula-
tions.
Representatives shall serve staggered two-year terms and may
serve additional terms with the approval of the Superintendent of
Schools. After the initial election or selection, representatives shall
draw lots, within each representative category, to determine the
length of initial terms.
If a vacancy occurs among the representatives, nominations shall
be solicited and an election held or selection made for the unex-
pired term in the same manner as for the annual election.
The existence of the District-level committee shall not affect the
authority of the Board or its designee to appoint or establish other
advisory groups or task forces to assist it in matters pertaining to
District instruction.
DATE ISSUED: 10/1/2008
LOU 2008.13
BQA(LOCAL)-X
ADOPTED: 2 of 2
Dallas lSD
057905
PLANNING AND DECISION-MAKING PROCESS
DISTRICT-LEVEL
BQA
(LEGAL)
COMMITTEE
PROFESSIONAL
STAFF
PARENTS
BUSINESS
REPRESENTATIVES
AND COMMUNITY
MEMBERS
The District's policy and procedures shall establish a District-level
planning and decision-making committee as provided by Education
Code 11.251 (b)-(e).
The committee shall include representative professional staff, par-
ents of students enrolled in the District, business representatives,
and community members.
Education Code 11.251(b), .253(a)
The Board shall adopt a procedure, consistent with Education
Code 21.407(a) [see DGA], for the professional staff to nominate
and elect the professional staff representatives who shall serve on
the District-level committee. If practicable, the committee shall in-
clude at least one professional staff representative with the primary
responsibility for educating students with disabilities.
At least two-thirds of the elected professional staff representatives
must be classroom teachers. The remaining staff representatives
shall include both campus- and District-level professional staff
members.
Education Code 11.251(e)
Board policy shall provide procedures for the selection of parents
to the District-level committee.
For purposes of establishing the composition of the committee:
1. A person who stands in parental relation to a student is consi-
dered a parent.
2. A parent who is an employee of the District is not considered
a parent representative on the committee.
3. A parent is not considered a representative of community
members on the committee.
Education Code 11.251(c), (e)
Board policy shall provide procedures for the selection of commu-
nity members and business representatives to serve on the Dis-
trict-level committee in a manner that provides for appropriate re-
presentation of the community's diversity.
The committee must include business representatives without re-
gard to whether a representative resides in the District or whether
the business the person represents is located in the District.
Community members must reside in the District and must be at
least 18 years of age.
DATE ISSUED: 10/19/2011
UPDATE 91
BQA(LEGAL)-A
EXHIBIT
A -2.
1 of 3
Dallas lSD
057905
PLANNING AND DECISION-MAKING PROCESS
DISTRICT-LEVEL
BOA
(LEGAL)
MEETINGS
PUBLIC MEETINGS
COMMUNICATIONS
CONSULTATION
RESPONSIBILITIES
DISTRICT PLAN
DROPOUT
PREVENTION
REVIEW
Education Code 11.251(b), (c), (e)
The Board shall establish a procedure under which the District-
level committee holds regular meetings. The Board or designee
shall periodically meet with the District-level committee to review
the committee's deliberations. Education Code 11.251(b)
The District-level committee shall hold at least one public meeting
per year. The required meeting shall be held after receipt of the
annual District performance report from TEA for the purpose of dis-
cussing the performance of the District and the District perfor-
mance objectives. Education Code 11.252(e)
District policy and procedures must be established to ensure that
systematic communications measures are in place to periodically
obtain broad-based community, parent, and staff input and to pro-
vide information to those persons regarding the recommendations
of the District-level committee. Education Code 11.252(e)
The Superintendent shall regularly consult the District-level com-
mittee in the planning, operation, supervision, and evaluation of the
District educational program. Education Code 11.252(f)
The District-level committee shall assist the Superintendent with
the annual development, evaluation, and revision of the District im-
provement plan. Education Code 11.252(a) [See BQ]
'
The District-level committee shall analyze information related to
dropout prevention, including:
1. The results of the audit of dropout records;
2. Campus information related to graduation rates, dropout
rates, high school equivalency certificate rates, and the per-
centage of students who remain in high school more than four
years after entering grade 9;
3. The number of students who enter a high school equivalency
certificate program and:
a. Do not complete the program,
b. Complete the program but do not take the high school
equivalency examination, or
c. Complete the program and take the high school equiva-
lency examination but do not obtain a high school equi-
valency certificate;
4. For students enrolled in grades 9 and 10, information related
to academic credit hours earned, retention rates, and place-
DATE ISSUED: 10/19/2011 2 of 3
UPDATE 91
BQA(LEGAL)-A
Dallas lSD
057905
PLANNING AND DECISION-MAKING PROCESS
DISTRICT-LEVEL
BQA
(LEGAL)
ments in disciplinary alternative education programs and ex-
pulsions under Chapter 37; and
5. The results of an evaluation of each school-based dropout
prevention program in the District.
The District-level committee shall use the information in developing
the District improvement plan.
Education Code 11.255
Note: See BF for information on the committee's role in re-
questing waivers.
DATE ISSUED: 10/19/2011
UPDATE 91
BQA(LEGAL)-A
3 of 3
.
Dallas
Independent
School
Distlict
Dlstrictwide Advisory Committee
2013-14 Roster (currentasofApr/1 1, 2013}
'
'.
'
:
, ...
'
,.,
""
Archer Connie Casa View Elementary Schoof Teacher
Atkins Jennifer Charles Rice Learning Center Instructional Coach
Calderon Diana Cabell Elementary School Teacher
D'Apice Hannah Browne Middle Schoof Teacher
Davis Angela NEA- Dallas President
Freeman Isaac T.C. Marsh Middle School Teacher
Guillory Jimmy Medrano Middle School Teacher
Gutierrez Dallas Dallas lSD Principal Fellow
Higginbotham Melissa W.T. White High Schoof Parent
Hodge Stacey Stand for Children Dallas Director
Honea Rena Alliance/AFT President
Jackson Renee Zan Holmes Middle School Teacher
Lecesne Barbara Community Member
Mercer William Samuel! High School Teacher
Morrissey Elisa Lanier Elementary Schoof instructional Coach
Munves Stephanie Lakewood Elementary School Teacher
Newberry Joey Lakewood Elementary School Teacher
Newton Joshua Science and Engineering Magnet atTownview Teacher
Oliver Ronald Bowie Elementary School Teacher
Ramirez Maria John Quincy Adams Elementary School Parent
Ramirez Mark Molina High School Principal

Ramsey Mark Parent
II
1\-3
Richardson Kyle Woodrow Wilson High School Principal
Rodriguez Johnny Community Member
Dallas
Independent
School
District
Salinas Rosalinda Parent
Stark Shirley Piedmont/Scyene HOA President/Parent
Wade-Pettigrew Katrina Seagoville Elementary School Teacher
Wood Ellen Teaching Trust Co-Founder
Woodie Lisa Hillcrest High School Teacher.
Young Brian T.G. Terry Elementary School Teacher
SITE BASED DECISION MAKING
Dallas Independent School District
tflllllllllllli
f\ -4
Table of Contents
Foreword
History
Definition
Legal Mandates
District and Campus Improvement Plans
District and Campus-Level Planning and Decision-Making Process
District-level Committee
Meetings
Campus-Level Committee
Composition of the District and Campus-Level Planning Committees
Composition of the Districtwide Committee
Composition of the Campus-Level Committee
Selection and Training of New Members
Function of the Site-Based Decision-Making Team
Roles and Responsibilities
Districtwide Committee
Campus-Level Committee
Principal's Responsibilities
Operating Procedures
Communications Framework
Decision-Making Parameters
Planning-Goal Setting
Budget
Curriculum
School Organization
Staffing Patterns
Staff Development
School Safety
Federal and State Requirements
Waivers
Evaluation
Appendices
Site-Based Decision-Making
Dallas Independent School District
3
4
4
5
5
6
6
6
6
7
7
7
8
9
9
9
10
10
11
12
13
13
13
13
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14
14
14
15
15
15
16
2
Foreword
"Our mission is to prepare all students to graduate with the
knowledge and skills to become productive and responsible citizens."
The focus of the Dallas Independent School District is to improve the performance of all
students. Site-based decision-making is a process that will lead to the accomplishment
of that goal at the local campus level, by establishing a framework for school staff,
parents, and business and community stakeholders to join as a team in developing
strategies to improve neighborhood schools.
Many campuses are experiencing the benefits of integrated planning and decision-
making, as evidenced through increased student achievement, clearly outlined goals
and objectives, and greater parent/community involvement. While each school in the
Dallas Independent School District is unique, every school !!..!! be effective in meeting
the needs of the population it serves.
It is the desire of the Dallas Independent School District that effective site-based
decision-making teams will be one of the vehicles that will help the district reach and
exceed its goals. To that end, this document is designed to provide technical support to
schools in the on-going implementation of site-based decision-making.
Site-Based Decision-Making
Dallas Independent School District
3
History
House Bill 2885, enacted in July of 1991, required each school district to develop a plan
for decision-making to be filed with the Commissioner of Education. Prior to the State
action, the Board of Education approved a long-range plan for site-based decision-
making through a child-centered approach. This child-centered approach, based on
concepts and functions recommended in the School Development Program by James
P. Comer, had three components:
School-Community Council -the primary unit for campus decision-making
Parent/Family/Community Involvement Component - a mechanism to facilitate
substantive input into the goals and structure of the school
Student Support Team- the mental health support system for students and families.
The DISD began its implementation of the site-based decision-making process with a
pilot of ten schools and adopted a schedule to add all schools by the end of 1996.
Site-based decision-making has continued to evolve throughout the years. Presently, in
order to align more directly with State terminology, the district refers to the process of
decentralized decision-making as Site-Based Decision-Making (SBDM). Campus teams
are referenced as site-based decision-making teams.
Definition
Site-based decision-making is a process for decentralizing decisions to improve the
educational outcomes at every school campus through a collaborative effort. Through
this integrated process, superintendents, central staff, principals, teachers, campus
staff, parents, and community and business representatives assess educational
outcomes of all students, determine goals, and ensure that strategies are implemented
and adjusted to guide student development, increase student achievement, and
improve school operations.
Site-Based Decision-Making
Dallas Independent School District
4
Legal Mandates
In Texas, the focus of district and campus planning and decision-making is to improve
the performance of all students. The ultimate purpose is to attain the state's educational
goals of equity and excellence in achievement for all students. Senate Bill 1 contained
provisions that outlined the district-level and campus-level planning and decision-
making processes. The Texas Education Code (TEC) also sets out minimum
requirements.
It is the responsibility of each school district to interpret and implement the provisions of
the state education code in a manner consistent with the statute that will best serve the
school district's unique characteristics. This guide outlines the details for implementation
of the planning and decision-making process for the Dallas Independent School District.
District and Campus Improvement Plans
1. The Board of Education under TEC 11.251 must ensure that both a district
improvement plan and improvement plans for each campus are developed, revised
and reviewed annually.
The District Improvement Plan must include:
A comprehensive needs assessment
Measurable district performance objectives
Strategies for improving student performance
Strategies for providing information on higher education to secondary students,
teachers, counselors, and parents
Resources needed to implement strategies
Staff responsible for accomplishing each strategy
Time lines for ongoing monitoring
Formative evaluation criteria
The Campus Improvement Plan must:
Assess academic achievement for each student
Set campus performance objectives
Identify how campus goals will be met for each student
Determine resources needed to implement the plan
Identify staff needed
Set time lines
Measure progress periodically
Include goals and methods for violence prevention and intervention
Provide for a program to encourage parental involvement
Site-Based Decision-Making
Dallas Independent School District
5
District and Campus-Level Planning and Decision
Making
Process
1. The Board of Education shall adopt policy to establish a district-level and campus-
level planning and decision-making process. The Board shall establish a procedure
under which meetings are held regularly by district-level and campus-level planning
and decision-making committees.
District-level Committee
In compliance with Education Code 11.251, the district-level Committee shall advise the
Board or its designee in establishing and reviewing the district's educational goals,
objectives, and major districtwide classroom instructional programs identified by the
Board or its designee. The committee shall serve exclusively in an advisory role,
except that the committee shall approve staff development of a districtwide nature.
BQA(LOCAL)
The superintendent shall be the Board's designee to the district-level committee. The
committee shall elect its chairperson from among the committee's members. The
superintendent shall meet with the committee periodically.
Meetings
The chairperson of the committee and the superintendent (or a designee) shall set the
agenda and schedule twelve meetings per year. Additional meetings may be held at the
call of the chairperson. All committee meetings shall be held during the regular school
day.
Campus-Level Committee
A campus-level planning and decision-making committee shall be established on each
campus to assist the principal in developing the campus goals and plan for
improvement. The Site-Based Decision-Making Committee (SBDM) is responsible for
input and involvement in the planning and decision-making process to improve student
achievement. The SBDM team shall serve exclusively in an advisory role, as defined by
the Board in the district's campus-level planning and decision-making implementation
plan.
Site-Based Decision-Making
Dallas Independent School District
6
Composition of the District and Campus-Level
Planning Committees
1. The Board of Education shall establish guidelines for the composition of the district
and campus planning committees. The Board shall adopt a procedure, consistent
with Section 21.407(a) for the professional staff in the district to nominate and elect
the staff representatives who shall meet with the board or the board designee. Board
policy must provide procedures for the selection of parents, community members,
and business representatives that provides for appropriate representative of the
community's diversity.
Composition of the Districtwide Committee
The Districtwide Committee is comprised of members who represent campus-based
professional staff, district-level professional staff, parents, businesses, and the
community. Three-fourths of the district and campus professional staff must be
classroom teachers, and the remaining one-fourth must be professional non-teaching
district and campus-level staff. Committee members shall include:
Nine campus-based teachers selected from Inside Track Representatives
Three principals (one elementary, one middle school, one high school)
Nine non-employee members nominated and elected by the Superintendent's
Advisory Committees
Three parents of students currently enrolled within the district; three community
members, who reside within the district, selected by the Superintendent's
Advisory Committees; and, three business people selected by the
Superintendent's Advisory Committees
Composition of the Campus-Level Committee
The campus site-based decision-making committee has a minimum of 12 members,
including administrators, teachers, support staff, auxiliary personnel, parents,
community and business representatives, and, where appropriate, students. The SBDM
team is composed both of elected and appointed stakeholders.
50% of the SBDM team's membership is comprised of professional and support
staff, and other auxiliary school personnel.
Two-thirds of the school staff are elected with representation based on grade
levels at the elementary school and departments at the secondary school.
One-third of the school staff is appointed by the principal to guarantee
representation of all staff, including support staff.
50% of the SBDM team's membership is comprised of parents, community
representatives, business representatives, and students at levels where
appropriate.
Key parent/community/student groups elect two-thirds of the parent/ community/
business/ student representatives.
Site-Based Decision-Making
Dallas Independent School District
7
Up to one-third of the parent/community/business/student representatives may
be appointed to achieve representational balance.
For purposes of clarification the following definitions exist:
A person who stands in parental relation to a student is considered a parent.
A parent who is an employee of the district is not considered a parent
representative on the committee.
A parent is not considered a representative of community members on the
committee.
Community members must reside in the district and must be at least 18 years of
age.
Business representatives need not reside in nor operate businesses in the
District.
Selection and Training of New Members
It is useful to consider a policy that provides for staggered terms of service for
committee members. Such a provision may ensure the stability of the committee's
decision-making over time. Whether staggered terms are used or not, it is wise to
engage in team-building activities whenever new members join a committee.
Potential non-professional staff candidates may be solicited through newsletters
distributed broadly to all appropriate community and business entities. Announcements
of the request for candidates may be advertised in the local newspaper with a
description of the expected responsibilities and the recommended qualifications of
committee members. Nominees may be solicited from parent and teacher
organizations/associations, chamber of commerce, local businesses and community
organizations.
At the campus level, new legislation requires plans to "provide for a program to
encourage parental involvement." A critical first step in addressing this requirement is to
ensure that a balanced, diverse group of parent representatives are included in the
campus-level committee membership.* Campus by-laws will determine the term lengths
for committee members. It is recommended that elections are held in the spring so that
committee members may meet during the summer to participate in training, review
performance data, revise objectives and strategies to address identified needs, and
make recommendations for the campus improvement plan.
*In schools containing an Early Childhood component, at least two parents representing
Pre-K through 3'd grade must serve on the campus SBDM Committee
Site-Based Decision-Making
Dallas Independent School District
8
Function of the Campus Site-Based
Decision-Making Team
The function of the SBDM team is to advise the principal in establishing the campus
goals and plans for improvement. This SBDM team serves as an advisory body,
responsible for the input and involvement in the decision-making process that will
improve student performance and well being. The SBDM team is limited to an advisory
capacity in all areas, except in the area of staff development. Texas Education Code
requires that the committee approve campus-based training. TEC11.253(e)
Roles and Responsibilities
1. The Board shall a/so ensure that administrative procedure is provided to clearly
define the respective roles and responsibilities of the superintendent, central office
staff, principals, teachers, district-level committee members, and campus-level
committee members in the areas of planning, budgeting, curriculum, staffing
patterns, staff development, school organization, and school safety.
In Senate Bill 1, clear and consistent statutory linkage exists between educational
accountability criteria, district and campus planning and decision-making requirements,
and legal mandates for public disclosure of performance information. Therefore, it is
suggested that responsibility be assigned at all levels of educational leadership to
ensure that effective school improvement is occurring. State statute provides specific
role definition of educational leaders, including school boards, superintendents,
principals, and committees, with respect to planning and decision-making processes
and requirements for public accountability for student performance. For purposes of this
document, the roles and responsibilities of the district committee, campus committee
and the principal will be listed.
Districtwide Committee
o Provides assistance in the development, evaluation, and annual revision of the
district improvement plan
o Provides comments on district-level waivers
Participates in the development of a local appraisal process, if the state process
is not utilized
o Meets periodically with the board or the board designee to share their
deliberations
o Holds at least one public meeting per year to discuss the performance of the
district
o Participates in the development of a student code of conduct
o Participates in the development and approval of districtwide staff development
o Addresses all pertinent federal planning requirements
Site-Based Decision-Making
Dallas Independent School District
9
Campus-Level Committee
Provides assistance in the development, review and revision of the campus
improvement plan
Addresses all pertinent federal planning requirements
Participates in decisions in the areas of planning, budgeting, curriculum, staffing
patterns, staff development, school organization, and school safety
Approves the staff development portion of the Campus Improvement Plan
Holds at least one public meeting per year to discuss the performance of the
campus
Ensures that systematic communications measures are in place to obtain input
and disseminate information regarding recommendations of the campus-level
committees
Provides comments on campus-level waivers
Participates in the development of a local appraisal process, if the state process
is not utilized
Determines the use of funds awarded to the school under the Texas Successful
Schools Award System
Principal's Responsibilities
The principal's role is outlined in state statute as well. The principal is charged with
setting specific education objectives for the campus through the campus planning and
decision-making process. The roles and responsibilities include:
Developing, reviewing, and revising the campus improvement plan (TEC 11.253)
Holding at least one public meeting annually after the receipt of the campus
rating (TEC 11.253)
Consulting the campus-level committee in the planning, operation, supervision,
and evaluation of the campus educational program.
Site-Based Decision-Making
Dallas Independent School District
10
Operating Procedures
The site-based decision-making team advises the principal in the following areas:
planning, budgeting, curriculum, staffing patterns, staff development, school
organization and school safety. The composition of SBDM teams and committee
structures vary from school to school in accordance with local needs, interests, and
other indigenous factors. In addition, each team determines which committees give
primary attention to these functions and how they organize to address them.
By-laws should be developed as procedures or practices that facilitate and clarify the
work of the site-based decision-making team. These by-laws become the guiding
principles upon which the committee operates. The by-laws should include a process
for:
Reaching collaborative consensus
Selecting officers. Officers will vary from campus to campus; however, the most
common positions are:
./ Chairperson - Works with the school principal to prepare and distribute an
agenda, and conducts the meeting in an organized manner
./ Recorder- Maintains records of team activities
./ Timekeeper- Ensures that team activities are carried out in a timely manner
./ Facilitator - Ensures that meetings and team activities are conducted
efficiently, effectively and orderly; keeps the group on track until it has
accomplished its goals
Establishing guidelines for rotation/removal of SBDM members
Setting frequency of meetings
Preparing agenda
Recording minutes
Holding open meetings
Setting ground rules for conducting meetings
Utilizing committees or project teams
Soliciting broad-based input about issues under review
Disseminating information
Proposing recommendations
Appealing a principal's decision to the General Superintendent, or
Superintendent's designee
Establishing an Evaluation and Modification Committee, chaired by the principal
(required)
Examples of by-laws, agendas, committee structures and other information for
managing the committee can be found in the appendix of this document.
Site-Based Decision-Making
Dallas Independent School District
11
Communications Framework
Communication is critical to shared decision-making. The opinions of all stakeholders
need to be solicited and multiple groups need to be informed regularly of the
recommendations of the SBDM team. Board policy establishes that the principal or
designee shall ensure that the campus-level SBDM communicates on a systematic
basis.
In accordance with TEC Section 11.252(e), district policy and procedures must be
established to ensure that systematic communication measures are in place to obtain
broad-based community, parent, and staff input and to provide information to those
persons regarding the recommendations of the districtwide committee. Local policy
further states that these measures should also exist at the campus level (BQB LOCAL).
Communications can include, but not be limited to, the following:
Periodic meetings to gather input and provide information on the work of the
committee. Meetings can be advertised in district or campus publications and
through the media.
Articles in district or campus publications regarding the work of the committee.
Regular new releases to the media in the district regarding the work of the
committee.
Periodic reports on the work of the committee may be posted on campus bulletin
boards.
Scheduled meetings with representative groups (Inside Track, Superintendent's
Advisory Committees, etc.) to give updates on the work of the committees
Collaboration with co-existing organizations is also important to the success of the site-
based decision-making team. While campuses may have a variety of representative
groups, the following organizations are common to every campus:
Inside Track
Parent Teacher Association (PTA)
Faculty/Staff Advisory Committee (FSAC)
Language Proficiency Advisory Committee (LPAC)
Student Support Team (SST)
Other groups may be sanctioned, particularly at the district level. Mechanisms for
receiving input from all groups need to be taken into advisement by the teams. Each
team has the responsibility to keep its constituents informed.
Site-Based Decision-Making
Dallas Independent School District
12
Decision Making Parameters
The primary functions of site-based decision-making are delineated below. The SBDM
team may choose to propose consensus recommendations to the principal in these
areas. However, the areas that the SBDM does not wish to consider will become the
responsibility of the principal and his/her staff. A SBDM may choose to establish
committees to address issues in each of the decision-making parameters.
These committees provide an opportunity to involve a wide range of stakeholders. The
committee chair must be a member of the site-based decision-making team. However,
the remaining committee members can be chosen from a variety of stakeholder groups
and are not required to be members of the SBDM committee.
Planning/Goal Setting
Identify academic and social needs of students
Develop campus vision
Identify campus/department needs
Collect data for improvement
Select school priorities based on student assessment
Identify parent/community needs
Budget
Make recommendations on the budget process
Maximize the allocated resources to meet program needs
Monitor campus budgets
Determine priorities for expenditures
Ensure budget is aligned with the campus improvement plan and district mission
Curriculum
Set educational priorities that align with district educational priorities and specific
needs of the school community
Determine modifications of curriculum and programs for equity, unique interests
and needs of students
Determine procedures and monitor instructional practices
Research and recommend curriculum initiatives
Recommend instructional changes based upon student needs
Evaluate compliance with District, State and Federal guidelines
Evaluate implementation of the Campus Improvement Plan to determine success
School Organization
Utilize flexible instructional groupings according to guidelines
Give input on internal scheduling of staff
Use leadership teams to assist in research
Implement a management structure that will result in continuous improvement
Site-Based Decision-Making
Dallas Independent School District
13
Collaboratively establish student code of conduct, behavioral expectations and
procedures within the district framework
Initiate waiver request from district or State mandates for procedures
Staffing Patterns
Explore principal and campus staff assignments by developing personnel profiles
Provide a school-based assistance program for new staff members
Identify personnel needs
Develop continuous improvement plans
Review instructional schedules to maximize use of available instructional
specialists
Staff Development
Create development opportunities for employees, parents and community
representatives
Identify needs of campus
Integrate staff development into the campus improvement plan
Implement, monitor and evaluate staff/parent training
Approve the portion of the campus improvement plan addressing staff
development
School Safety
Support efforts to prevent incidents of school violence from occurring, through
v' Appropriate and effective discipline policies;
v' Security procedures;
v' Prevention activities;
v' Student codes of conduct; and
v' A crisis management plan for responding to violent or traumatic incidents on
school grounds.
Promote and support:
v' Assessments/reviews of the physical environment of schools to determine
areas where the safety and/or security of students and staff might be
jeopardized (verify that the school has a current Physical Security
Assessment by the DISD Safety and Security Department);
v' Maintaining statistics of incidents of disruption and school crime/violence so
that administrators can (1) determine the types of problems which are
occurring at their schools, and (2) address solutions;
./ Surveys of the school community that will enable school personnel, parents
and community members to identify areas of concern, as well as behaviors
that might reflect these concerns;
./ Student involvement as a way to establish and maintain the safety and
security of a school, and to communicate irregularities and/or concerns in the
school.
Site-Based Decision-Making
Dallas Independent School District
14
Federal and State Requirements
1. The district policy must provide that all perlinent federal planning requirements are
addressed through the district-level and campus-level planning process.
When state and federal funds are used for special programs and services, these
resources, related strategies, and appropriate formative evaluation criteria should be
indicated in the campus improvement plan to accomplish performance objectives
identified for populations served by such funds. District policies are required under TEC
11.252(f) to ensure that all pertinent federal planning requirements are addressed
through the district-level and campus-level planning process. This means that the
campus improvement plan for a Title I campus should incorporate all of the items
required to obtain the federal Title I funds.
Waivers
Local autonomy also can be enhanced through the use of waivers. Creative and
imaginative initiatives prohibited by law, regulation, or policy might merit the waiving of
rules by appropriate authorities. A waiver should include:
A written plan that states the achievement objectives of the campus or district and
the inhibition imposed on those objectives by the requirement, restriction, or
prohibition
Written comments from the campus-level or district-level committee.
All requests for waivers are submitted first to the area superintendent and then to the
General Superintendent who has established a Waiver Review Committee to examine
the requests and assist schools in their efforts to provide alternative initiatives.
Evaluation
At least every two years, each district must evaluate the effectiveness of the district's
decision-making and planning policies, procedures, and staff development activities
related to district and campus-level planning and decision- making (TEC 11.252).
Plans should be monitored frequently. The evaluation process should include both
formative and summative evaluations. The formative evaluation will be guided by
expected results and incremental timelines associated with the activities developed to
accomplish the performance objectives. The summative evaluation is conducted to
assess the degree to which the district or campus actually accomplished the year's
targeted performance objectives.
Site-Based Decision-Making
Dallas Independent School Districl
15
Dallas lSD CommunicatoJ August 2009 I www.dallasisd.org I i 1 a 1 @
Inside Track gets a facelift
Tc district's employee communications program Inside Track is changing to give employees more access to
district leadership. The goal of the revamp is to reap the benefits of improved communication between the rank
and file and top administrators. These benefits include increased productivity and employee satisfaction and higher
student achievement.
The new format will bring Inside Track representatives from campus and central staff together for quar-
terly meetings with the superintendent and other district leaders. It's hoped these sessions will build rap-
pOlt and trust and provide a forum for the exchange of ideas from the bottom up. 1\vo-way communica-
tion is the whole idea behind Inside Track and the superintendent says he's excited to have more face time
employees.
"This is part of an ongoing effort to encourage a dialogue with district staff," said Superintendent of
Schools Michael Hinojosa, who tours at least one campus per week on his customary Wednesday visits.
"In addition to the visits, last year we held a series of 12 dialogue sessions with staff across the district
where I answered a variety of questions about our financial status and plans to improve the work climate
and academic achievement. The new Inside Track format will permit me to hear directly from employees
ideas about how we can continue our work to make Dallas lSD the best urban district in the country."
The new features of Inside Track include representatives who will gather input from their coworkers,
submit questions via e-mail for discussion at the meetings, attend meetings, collect information, and
share that information with their colleagues.
These employees also will receive periodic news updates on developments affecting the district and e-
mails with information to share with their colleagues. They also will serve as communications
contacts to share positive news of school or department activities, programs, and accomplishments.
The first Inside Track meeting for 2009 is scheduled for 2 p.m., Thursday, Sept. 3, in the administration
building auditorium.
Some things about Inside Track will remain the same. Division heads will still select the representatives for their
depa1tments and submit the names to Communication Principals still select the Inside Track
representative for their campus and submit that uame online on the district intranet at http:jjinet.dallasisd.org
jinsidetrackjindex.html. This year's deadline to submit representatives' names was Wed., Aug. 26.
All employees will still have access to information by submitting questions to Inside Track. As in the past,
these questions will be answered by the appropriate district staff and posted online for viewing by all
employees.
For more information, employees may log on to http:jjinet
.dallasisd.orgjinsidetrackfindex
.html, or call (972) 925-3915.
EXHIBIT
I 1\-5
611112014 Home-Rule Charter I Home-Rule Charter Information
Home- Rule District Information
An effort has recently been launched by an outside organization to turn Dallas lSD into a home-rule
district. The concept of a home-rule district was created nearly 20 years ago by the Texas Legislature, and as
yet, no community has created such a district.
While the board, the administration and the community continue to examine the issue in depth, this web page
will serve as a clearinghouse with factual information about the process.
Update: june 6, 2014
After a selection process and in accordance with all legal requirements, the professional staff of the
Districtwide Advisory Committee (DAC) has named the following Dallas lSD teachers to serve on the Home Rule
Charter Commission:
o Isaac Freeman, Thomas C. Marsh Middle School
o Ron Oliver, james Bowie Elementary School
o Bonita Reece, Birdie Alexander Elementary School
o julie Sandel, Hillcrest High School
In the event that one of the above named teachers is unable or unwilling to serve, two alternates were also
selected:
o First Alternate: Mark Harrington, Seagoville High School
o Second Alternate: Candace McAfee, Skyline High School
To select the four teachers and two alternates, the DAC:
1. Defined selection criteria and drafted supplemental survey questions to evaluate applicants.
2. Reviewed 75 completed applications and pared the pool to 14 finalists.
3. Individually evaluated the finalist pool and then extensively discussed the finalists as a group.
4. Ultimately determined the four teachers and two alternates based on the application quality and to
ensure diversity in grade band, racejethnicity, and campus location.
Attorneys from the firm of Thompson & Horton, which has been engaged by the Dallas lSD Board of Trustees
to advise the district on home-rule issues, observed the entire process and were regularly consulted concerning
any legal questions.
The remaining 11 members of the charter commission will be selected by the Dallas lSD Board of Trustees.
Eight of the individuals serving on the commission must be district parents.
Update: May 23, 2014
The Dallas lSD Board of Trustees has 30 days to form a 15-person commission to draft a proposed home-rule
charter.
By law, the Board of Trustees must appoint a charter commission of district residents that reflects the racial,
ethnic, socioeconomic and geographic diversity of the district. At least eight members must be parents
school-age children attending Dallas lSD public schools. At least 25 percent of the commission must be
classroom teachers. Trustees will appoint 11 of the 15 members.
The 30-day window to form a commission began May 22 when more than 24,650 signatures on a petition to
htlp://mw.dallasisd.org/horoorule 113
6/11/2014 Home-Rule Charter I Home-Rule Charter lnforrmtion
create a home-rule commission were verified. Once appointed, the commission has up to a year to complete
its work.
Complete the Home Rule Charter Commission Interest Forrn
Update: May 22, 2014
Dallas lSD has verified that a petition to create a home-rule charter has the required number of signatures
needed to cause the district's Board of Trustees to appoint a charter commission. More than 24,650 signatures,
representing more than five percent of the district's registered voters, have been verified during the last week.
More than 49,000 lines on petitions, which included blanks, were reviewed.
Update: May 19, 2014
The Dallas lSD Board of Trustees will meet tonight to discuss hiring a law firm to advise the district regarding
the home-rule initiative.
Update: May 15, 2014
Supporters of the home-rule initiative delivered three boxes of signed petitions to the school district
administration building today.
Message From Superintendent Mike Miles
'A community group has announced its intentions to begin a process that could significantly
impact Dallas lSD. The group's efforts to place the district under the authority of a "home-rule
charter" will likely generate a great deal of conversation, both in the community and within
Dallas lSD. Therefore, I would like to provide you with some information about the process
being initiated.
Chapter 12 of the Texas Education Code outlines the process for bringing a school district
under the authority of a home-rule charter. It should be noted that, in this context, "charter" refers to a
document that establishes how a district operates, similar to how charters work for cities, such as the City of
Dallas. The process to establish a home-rule charter begins with a petition drive. If the petition drive receives
more than 24,459 signatures (5% of registered voters), the Board of Trustees would be required to appoint a
commission of 15 members who would draft a charter that describes how the district would be operated in the
future. That charter then goes to the Commissioner of the Texas Education Agency for approval. It would also
be sent to the U.S. Department of justice for preclearance under the Voting Rights Act. If the Commissioner
approves the charter, the charter would go to voters for approval during a general election. Should a majority of
voters approve the draft charter, the district would then operate under the provisions established in the
charter.
There are some very specific guidelines for this process that are outlined in TEC Chapter 12. If you are
interested in learning more about home-rule charters or the process, you can read the summary from the
Texas Association of School Boards and watch the briefing that the Board of Trustees received on the issue on
Thursday, March 6. This is the first time that this process in Texas state law has been attempted, and there
are a number of unknowns. I would encourage you to stay informed as the process unfolds. However,
regardless of what transpires, our focus as an administration and as a district will remain on improving the
quality of instruction in every classroom so that each of our students is successful in college and their careers.
Mike Miles, Superintendent
httpJ/Iw.w.dallasisd.org/homerule 2/3
6/11/2014
Additional Information
Districtwide Advisory Committee
Home Rule Petition Documents
TASB Home-Rule Districts
Texas Education Code Chapter 12
Home-Rule Charter I Home-Rule Charier Information
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htlp:l/v.v.w.dallasisd.orglllorrerule
313
D
Called Board Meeting Agenda and Notice
Thursday, June 12, 2014 at 3:00p.m.
Dallas
Independent
School
District
Board Room or the Ada L. Williams Auditorium
3700 Ross Avenue, Dallas, TX 75204
The Board shall govern and oversee the management of the public schools of the District. Education Code 11. 151(b)
Vision: Dallas ISO seeks to be a premier urban school district
Mission: Educating All Students for Success
Accomplishments
The Dallas Independent School District is home to two of the top 1 0 schools in the United States.
The Dallas Independent School District's most recent four year graduation rate is 81.3% up from 62.5% in 2007.
1. Notice and Return
2. Moment of Silence and Pledge of Allegiance
3. CLOSED SESSION The Board will retire to closed session pursuant to Texas
Government Code Section 551 concerning the following sections:
551.071 For private consultation with its attorney about pending or contemplated litigation or on
a matter in which the duty of the attorney to the governmental body under the Texas Disciplinary
Rules of Professional Conduct clearly conflicts with this chapter, including advice on Home-Rule
School District Charter Commission.
4. Consider and Take Possible Action to Adopt Process for Naming Appointees to the
15 Member Home-Rule School District Charter Commission
5. Adjournment
If, during the course of the meeting covered by this Notice, the Board of Trustees should determine that a
closed meeting or session of the Board of Trustees is required, then such closed executive meeting or session
as authorized by the Texas Open Meetings Act, Texas Government Code Section 551.001 et seq., will be held
by the School Board at the date, hour, and place given in this Notice or as soon after the commencement of
the meeting covered by this Notice as the School Board may conveniently meet in such closed or executive
meeting or session concerning any and all purposes permitted by the Act, including, but not limited to the
following sections and purposes:
Texas Government Code Section:
551.071
551.072
551.D73
551.074
551.076
Private consultation with Board's attorney.
Discussing purchase, exchange, lease, or value of real property.
Discussing negotiated contracts for prospective gifts or donations.
Discussing personnel or to hear complaints against personnel.
Considering the deployment, specific occasions for, or
security personnel or devices. II EXHIBIT
- 1 -
I
1\-1
551.082
551.083
551.084
Considering discipline of a public school child, or complaint or charge
against personnel.
Considering the standards, guidelines, terms, or conditions the Board will
follow, or will instruct its representatives to follow, in consultation with
representatives of employee groups.
Excluding witnesses from a hearing.
Should any final action, final decision, or final vote be required in the opinion of the School Board with regard to
any matter considered in such closed or executive meeting or session, then the final action, final decision, or
final vote shall be either:
(a) in the open meeting covered by the Notice upon the reconvening of the public meeting; or
(b) at a subsequent public meeting of the School Board upon notice thereof, as the School Board
shall determine.
Authorized and Approved by on --=-:----
Board President or Designee Date
Authorized and Approved by on ---;::--:---
Superintendent of Schools or Designee Date
SIGN LANGUAGE INTERPRETERS
In keeping with the Americans with Disabilities Act, Sign language interpreters are available for
this meeting upon twenty-four hour notice to the Board Services Office, (972) 925-3720. The
Board of Trustees of the Dallas Independent School District reserves the right to waive any of its
policies and/or a part of this agenda, pursuant to policy BF (Local). Meetings are televised live on
Time Warner Cable System on Cable Channels 98, 491, and 492 and on AT&T Uverse Channel
99 (select- Dallas, -Channel98).
INTERPRETES DE LENGUAJE DE SEJiJAS
Para cumplir con Ia ley de los estadounidenses con discapacidades, los interpretes de lenguaje
de seiias estan disponibles para esta reunion solicitandolos con 24 horas de anticipaci6n a Ia
oficina de servicios de Ia Junta Escolar, al telefono (972) 925-3720. La Junta Escolar del Distrito
Escolar lndependiente de Dallas se reserva el derecho de prescindir de cualquiera de sus
normas y/o una parte de Ia presente arden del dfa, segun Ia norma BF (Local). Las reuniones
son televisadas en vivo por el sistema de cable Time Warner en los canales 98, 491 y 492 y en
AT&T Uverse canal 99 (Seleccione-Dallas, -canal 98).
-2-
AFFIDAVIT OF JIMMY GUILLORY
STATE OF TEXAS
COUNTY OF DALLAS
BEFORE ME, the undersigned authority, on this day personally appeared Jimmy
Guillory, who, after being sworn upon his oath, states the following:
1. My name is Jimmy Guillory. I reside at 5509 Belstrum Court, Flower Mound, Texas
75028.
2. I am over 2 I years of age and of sound mind. I have never been convicted of a crime.
I am fully competent to testifY as to the matters stated herein. I have personal knowledge of the
facts stated in this affidavit and they are all true and correct.
3. I am a teacher employed by Dallas ISD. I have just completed my 17th year of
teaching for Dallas ISD. !teach mathematics at Medrano Middle School. I have been assigned to
the Medrano c ~ p u ~ !Iince the 2010 - 2011 school year. I am currently a member of the
. .
Districtwide Advisory Committee ("DAC"). I was not elected to the DAC by the professional
" .
staff in the district. Instead, during the first part of the 2013 - 2014 school year, I was
approached by the principal at Medrano, Theresa Sigurdson, about serving on the DAC. She
asked me if I would be willing to serve on the DAC and I agreed to do so. After that, I began
serving on the committee. My understanding is that I am to serve a two year term, so that my
term of service will end with the 2014-2015 school year.
Further affiant sayeth not.
SIGNED this f ~ day of June, 20 I 4.
B
STATE OF TEXAS
COUNTY OF DALLAS
Jirruny 'ttimBry ,
BEFORE ME, the undersigned Notary Public, on this day personally appeared Jirruny
Guillory, who being by me duly sworn upon oath deposed and stated that he has read the above
Affidavit; that he is cognizant of all facts stated above and that all of the information is true and
correct to the best of his knowledge.
SUBSCRIBED AND SWORN TO before me on this the \1-W.- day of June, 2014 to
witness which my hand and official seal of office.
.
........
L ..
:-M '"'0..'
..
.. ...
. .o,
. " . "
. ' . .

1t .. ' I
,' .. .. .. :
1'1:,1.
";"'.i6.:1A

ckL l L$:-
Notary Public in and for the Stat of Texas
My Commission Expires: 0-2.0-\ lo
2
AFFIDAVIT OF MARY ANN CLIMER
STATE OF TEXAS
COUNTY OF DALLAS
BEFORE ME, the undersigned authority, on this day personally appeared Mary Ann
Climer, who, after being sworn upon her oath, states the following:
l. My name is Mary Aim Climer. I reside at 1322 Rainbow Drive, Dallas, Texas 75208.
2. I am over 21 years of age and of sound mind. I have never been convicted of a crime.
I am fully competent to testify as to the matters stated herein. I have personal knowledge of the
facts stated in this affidavit and they. are all true and conect.
3. I am Vice-Chair of Dallas Friends of Public Education, an organization that seeks to
support and improve public education in Dallas Independent School District. As im officer and
member of that organization, as well as a concerned citizen, I have been monitoring the efforts of
some individuals to create a home-rule school district chatter in Dallas lSD. In order to acquire
information in connection with this issue, I submitted a Public Information Act request to Dallas
ISD on or about April!, 2014. I requested information pe1taining to the composition of Dallas
ISD's district-level planning and decision-making committee (the "District Advisory
Committee"), including whether the members were appointed or elected. This request was
submitted via e-mail from my e-mail account. A true imd conect copy of the request that I
submitted is attached and incorporated in this affidavit as attachment No. 1.
4. On April I, 2014, after I sent in my request, I received an acknowledgement letter
regarding my request from Leticia McGowan, an attorney employed by Dallas ISD. Attached
and incorporated iu this affidavit as attachment No. 2 is a true and correct copy of the
acknowledgment Jetter that I received from Ms. McGowan on April 1, 2014. Ms. McGowan
EXHIBIT
I
provided me with a number of documents on April16, 2014. However, there was no information
attached that addressed the issue of how the members were selected, such as whether they were
appointed or elected, and what their terms were. Accordingly, on April 17, 2014, I wrote back to
Ms. McGowan to address this issue and ask that she supply the missing infonnation about
whether teachers ate elected or appointed to serve on the District Advismy Committee. Attached
and incorporated in this affidavit as attaclnnent No.2 is a true and correct copy of my back-and-
forth e-mail correspondence of April 17, 2014 with Ms. McGowan. Ms. McGowan responded
via e-mail on that same day, April17, 2014. Included in attachment No.3 is the response that I
received fiom Ms. McGowan on April 17,2014, in which she indicated that she would see if she
"can find additional resources who may have information."
5. On April 21, 2014, I received a follow-up e-mail from Ms. McGowan. A tme and
correct copy of that e-mail is attached as attachment No.4. In her response, Ms. McGowan stated
that "participating teachers are nominated by their campuses."
Further affiant sayeth not.
SIGNED tlris ;tf:J- day of June, 2014.
2
STATE OF TEXAS
COUNTY OF DALLAS
BEFORE ME, the undersigned Notary Public, on this day personally appeared Mary Ann
Climer, who being by me duly swom upon oath deposed and stated that she has read the above
Affidavit; that she is cognizant ofall facts stated above and that all of the information is tme and
correct to the best of her knowledge.
SUBSCRIBED AND SWORN TO before me on this the lOth day of June, 2014 to
witness which my hand and official seal of office.
C k ~ ~
blic in aud-;,fo-r-'t-:-he----;::Sc-ta-,-te_o_f:;-;T::-e-xas
l n ~ P pJ ata
Printed Name ofNotary
My Conm1ission Expires: 04 o 1 1 5
3
e
JOSEI'LATA
NOTARY PUBUG
Sffilo!T-
Cclml. Elql. OWI/2015
~ ~
--------Original Message --------
Subject: Public lnformatiion Request
Date:Tue, 1 Apr 201419:03:00 +0000
From:Mary Ann Climer
To:'Mcgowan,
11
Leticia 0'
11
April!, 2014
Leticia D. McGowan:
This request is made under the Texas Public Information Act, Chapter 552, of Texas Govenm1ent Code, which
guarantees the public's access to information in the custody of govemmental agencies. I respectfully
request the following information:
The procedure adopted by the Board of Trustees for the nomination and election of the professional staff
representatives who currently serve on the DISD district level planning and decision making committee
(District Advisory Committee) as provided for in Texas Education Code 11.251 and in DISD policy BQA
(legal).
Also included in this request are the members' names; dates of appointment or election (with that
specified as to election or appointment); the date terms expire; the category each member represents (such as
community, parent, teacher, business, or other named professional staff)
If minutes or videos of these meetings are kept, either the minutes or where to access videos of the last 4
meetings is requested.
1
ATTACHMENT C-1
It is my preference to have this information emailed or otherwise sent electronically rather than paper
copies.
Disclosure of this information is in the public interest because providing a copy of the information primarily
benefits the general public. I therefore request a waiver of all fees and charges pursuant to Section 552.267 of
the act.
I shall look forward to hearing from you promptly, as specified in the law. Thank you for your cooperation.
Mary Ann Climer
1322 Rainbow
Dallas, TX 75208
214-564-7157 cell
214-943-8607 residence
Email: maclimer@flash.net
2
Mike Miles
Superintendent of Schools
April!, 2014
Mary Ann Climer
1322 Rainbow
Dallas, Texas 75208
VIA EMAIL: maclimer@flash.net
Dear Ms. Climer:
Dallas D
ImletJendent
Sclwol
District
Educating All Students For Success
Your request for various documents regarding the District Advisory Committee was received
on April!, 2014. The reference number assigned to your request is #12902. You will be
contacted once the information has been gathered.
Sincerely,

school Attorney
3700 Ross Ave.
Dallas, TX 75204
(972) 925-3700
W\\'\V.dallaslsd.org
ATTACHMENT C-2
--------Original Message--------
Subject:RE: Public Information Request #12902
Date:Thu, 17 Apr 2014 21:18:28 +0000
From:Mcgowan, Leticia D <LMcGowan@dallasisd.org>
To:'Mary Ann Climer' <maclimer@flash.net>
Good afternoon.
The list the District maintains was attached. The list starts on page 47 of the attachment. There was not any additional
information. Let me see if I can find any additional resources who may have information.
Thank you,
Leticia
From: Mary Ann Climer [mailto:maclimer@flash.net]
Sent: Thursday, April17, 2014 4:08PM
To: Mcgowan, Leticia D
Subject: RE: Public Information Request #12902
Ms. McGowan:
I received and was able to open the information sent on ORR 12902. I am able to open the
attachments. Thank you for sending as requested, however, in my original request I had asked
for certain information that was not included. Since policy lists the terms:
Representatives shall serve staggered two-year term:
serve additional terms with the approval of the Super
Schools. After the initial election or selection, represE
draw lots, within each representative category
7
to det(
~ n n t h nf n i t i ~ l tArmc::t
Please refer to the original request stating:
1
ATTACHMENT C-3
"Also included in this request are the members' names; dates of appointment or election (with that specified as
to election or appointment); the date terms expire; the category each member represents (such as community,
parent, teacher, business, or other named professional staff) "
The information did include names and category each represents but had no term or how
selected. Could you please get the missing information if it is available.
I also apologize for the lousy cut and paste here ... anything to save time today.
Thank you. Sorry to be a bother. And sorry to be long in letting you know of the receipt. I spent
yesterday at city hall. As you can well imagine, this information maybe pertinent.
From: Mcgowan, Leticia D [mailto:LMcGowan@dallasisd.orgl
Sent: Wednesday, April16, 2014 7:06AM
To: 'Mary Ann Climer'
Subject: Public Information Request # 12902
Dear Ms. Climer,
You have requested information related to the Dallas ISD's district level planning and decision making committee.
Attached is the responsive information the Dallas lSD has. Please let me know if additional information is needed.
Sincerely,
Leticia D. McGowan
School Attorney
CONFIDENTIALITY NOTICE: This email message, including all attachments, is for the sole use of the
intended recipient(s) and may contain confidential student and/or employee information. Unauthorized use
and/or disclosure is prohibited under the federal Family Education Rights & Privacy Act (20 U.S.C. 1232g, 34
CFR Part 99, 19 TAC 247.2, Texas Government Code 552.023, Texas Education Code 21.355,29 CFR
1630.14(b)(c)). If you are not the intended recipient, you may not use, disclose, copy or disseminate this
information. Please call the sender immediately or reply by email and destroy all copies of the original message,
including attachments.
2
--------Original Message--------
Subject:RE: Public Information Request #12902
Date:Mon, 21 Apr 2014 13:12:23 +0000
From:Mcgowan, Leticia D <LMcGowan@dallasisd.org>
To:' Mary Ann Climer' <maclimer@flash.net>
Good morning Ms. Climer.
I did follow-up on this request. There is not any additional documentation. I did receive additional information. It is
below:
Participating teachers are nominated by their campuses, and the classroom teacher organizations sit on DAC per
BQA(Local). Principal and parent names came from School Leadership.
Please let me know if additional information is needed.
Sincerely,
Leticia D. McGowan
School Attorney
From: Mary Ann Climer [mailto:maclimer@flash.net]
Sent: Thursday, April17, 2014 4:30PM
To: Mcgowan, Leticia D
Subject: Re: Public Information Request #12902
As always, your office is the best.
Sent from my iPhone
Please excuse typos from the tiny keyboard.
On Apr 17, 2014, at 4:18PM, "Mcgowan, Leticia D" <LMcGowan@dallasisd.org> wrote:
Good afternoon.
The list the District maintains was attached. The list starts on page 47 of the attachment. There was not
any additional information. Let me see if I can find any additional resources who may have information.
1 ATTACHMENT C-4

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