proved, SCAO Original - Cour aoe STATE OF WICHGAN TASEND. a ory arg county PROBATE ; [17-0 60 0US MT = Sar $25 'W- Onna 1, P.O, Box 318, Lansing, Mihigan 4999 Goats Prine name(s, adsess(es), and telaphona tS] [DETROIT PUBLIC SCHOOLS COMMUNITY DISTRICT. 011 W. Grand Blvd, Detroit, Michigan 48; (G13) 576-0100 Defendants name(s, adaroseaa), and telephone nol) STATE SCHOOL REFORMIREDESIGN OFFICE, an ‘autonomous entity within the Michigan Department of | Technology, Management and Budget [Pains attomey, bar no, address. and telephone no. Scott R. Eldridge (P6452) MILLER, CANFIELD, PADDOCK AND STONE, P.L.C, \One Michigan Avenue, Suite 900, Lansing, Michigan 48933, (S17) 487-4918, George Romney Building LIS. Capitol Ave Lansing, Michigan 48909 (517) 284-6972 MONS | NOTICE TO THE DEFENDANT: In the name of the people of the State of Michigan you are notified: u are Doing sued. 2. YOU HAVE 21 DAYS after receiving this summons o file a written answer with the courtand serve a copy on the other party ortake other lawful action with the court 28 daysfyou were served by mail or you were servedoutside this state). (MCR? 1"1{C) 3, Ifyou do not answer or take other action within the time allowed, judgment may be entered against you for the rele demanded in the complaint. issued, [This summons expres cu derome W. Zimmer Jr BA7-30N) Gedo - ivald unless served on of Before ts expraon dae. This document mus bo Sealed by the seal oh Coa COMPLAINT] Instruction: The followings information thatis required to bein the caption of every complaintandis tobe completed ‘by the plaintf. Actual allegations and the claim for relief must be stated on additional complaint pages and attached to this form, | This is a business case in which all or part of the action includes a business or commercial dispute under MCL 600.6035, Family Division Cases Thereisnoother pending or resolved action within the jurisdiction ofthe family division of circuit courtinvolving the family orfamily members of he partes. | An action within the jurisdiction ofthe family division ofthe circuit court involving the family or family members ofthe parties has Deen previously filed nnn nn neice Court The action | remains lis nolonger pending, The docket number and the judge assigned to the aclion are: [Bacarra : Tae Barns General Civil Cases ‘There is no other pending or resolved civil action arising out of the same transaction or occurrence as alleged in the complaint. ‘A chil action between these parties or other partes arising out of the transaction o occurrence alleged in the complaint has been previously filed in Court of Claims Court. ‘The action remains | jisnolonger pending. The docket number and the judge assigned fo the action are: Tae Barro: -000044-Mz, Stephen L. Borrello P7368; [VENUE Paini(s) residence (include cy, io-wnship, (Detendani(e)esdienae (dude iy, Township, or wilagay Pace where acon wo Bias condiclod iE - : 03/17/2017, ALM LL E72 Date ‘Sigaaiure of alterna plan Myourequire special acco:nmaciations to use the court because of a disability of you req(ire a foreign language interpreter tohelp you fully participate in court proceedings, please contact the court immediately to make arrangements, Not (6/15) SUMMONS AND COMPLAINT —wcR 2 102(8)(1), MCR 2.108, MCR 2.105, MOR 2107. MCR 2.119(C)2¥a) (b), MCR 3.2064A)‘SUMMONS AND COMPLAINT PROOF OF SERVICE Case No. TO PROCESS SERVER: You are to serve the summons and complaint not later than 91 days from the date of fling or the date ‘fexpiration on the order forsecond summons. Youmustmake and file your return with the courtclerk. Ifyouare unableto complete service you must return this original and all copies to the court clerk (CERTIFICATE / AFFIDAVIT OF SERVICE /NONSERVICE ©) OFFICER CERTIFICATE OR (1) AFFIDAVIT OF PROCESS SERVER =| | certify that | am a sheriff, deputy sheriff, ballif, appointed Being first duly sworn, I state that | am a legally competent | courtoficer, or attorney fora party (MCR2.104(A][2)),and _—_adultwhoisnotapparty ran office ofa corporateparty, and | that: (wotarzaton not reauired) that: (eotarization required) | served personally a copy of the summons and complaint, | served by registered or certified mail (copy of return receipt attached) a copy of the summons and complaint, together with {Teta docaments sened wh the Summons andl Complaint on the defendant(s): Delendants name ‘Gonipete adross(es) of sence Day. date, ime have personally attemptedto serve the summons and complaint, together with any attachments, on the following defendant(s) and have been unable to complete service. Betendants name ‘Gomplate address(es) of service Day, date. ine | declare that the statements above are true to the best of my information, knowledge, and belie. [Sewice ee | Mie vavelod | Mileage tee | Total feo i ee s s $ | Name Type or pa Tie ‘Subscribed and sworn to before me on County, Michigan. Dae My commission expires: Signature: z Baie Deputy Sour eonaNoany pub Notary public, State of Michigan, County of ACKNOWLEDGMENT OF SERVICE acknowledge that | have received service of the summons and complaint, together with ‘Racimeats Day, date, ime on behalf of SpasOulgnat - Court 2nd copy - Plt ¢ Soreceeeeeees ‘1st copy - Defendant: 3rd copy - Return ‘STATE OF MICHIGAN CASE NO. JUDICIAL DisTRICT fiinaieneun SUMMONS AND COMPLAINT COUNTY PROBATE I | \1 00 006S-MZ Tour waa Tour lopRan@ wa 925 W, Ottawa St, P.O. Box 30185, Lansing, Michigan 48909 (817)373-0807 Pini? hares, address(es), and Telephone no) Doiendanis nails), addresses), and Telephone nov [DETROIT PUBLIC SCHOOLS COMMUNITY DISTRICT | y__ | NATASHA BAKER, the State Schoo! Reform /Redesign 011 W. Grand Biv (Officer, in her official capacity [Detroit, Michigan 48202 | (G13) 576-0100 | Piainifs attomey, bar no, address, and Scott R. Eldridge (P6432) MILLER, CANFIELD, PADDOCK AND STONE, P.L.C. {One Michigan Avenue, Suite 900, Lansing, Michigan 48933. | (517) 487-4918 eee George Romney Building 111 S. Capitol Ave, Lansing, Michigan 48909 (517) 284-6972 [SUMMONS ] NOTICE TO THE DEFENDANT: in the name of the people of the State of Michigan you are notified: 1. You are being sued 2, YOUHAVE 21 DAYS after receiving this summons to file a written answer with the court and serve a copy on the other party ortake other lawful action with the court (28 days if you were served by mailor youwereservedoutside this state), (MOR2.111{C)) 3. Ifyou donot answer or take other action within the time allowed, judgment may be entered against you for the relief demanded inthe complaint issue This Sammons expires: Court Genk. Fi M3.\9.300 Oe” aol “Yerome W. Zimmer Jr. “This summons is invalid unless served on or before its expiration date. This document must be sealed by the seal of the court [COMPLAINT] Instruction: Thefoowingis information tats equrestobein the caption ofevery complntandistobecompleted By th plait. actual alegatons and te clan for rle must be slated an additonal complain: page and attached to ie Tote isis a business cae in which aor par of he aco cludes a business or commerialdieputo under MCL 600 2098 FamiyDivsionCases ("there fsnootnerpendingorresclvedaction within the jusdiction ofthe amily vision ofccullcourtnwolvingthetemiyor family mmembersefthe partes, (C) An action within the jurisdiction of the family division of the circuit court involving the family ‘or family members of the parties has boenprevouslyfledin- nn ee a a ae) The action [lremains — [lisnolonger pending. The docket number and the judge assigned to the action are: eat r eae Baro. General Civil Cases ~ ) There is no other pending or resolved civil action arising out of the same transaction or occurrence as alleged in the complaint. WA civil action between these parties or other parties arising out of the transaction or occurrence alleged in the complaint has been previously filed in Court of Claims Court. The action (remains — [-Jisnolonger pending. The docket number and the judge assigned to the action are: Docket no ie Barna: 2017-000044-Mz | Stephen L, Borrello 37368 VENUE | Panis) re8ence (nude Gy, fowsehip, or vilga) (Detandani(a) residence (nclude ey, outa, vilaga) Place where aelen arose or busines con 03/17/2017 ALI LZ, dae Signature of afomayinaii? you require special accommodations 9 uss ine court because of a disability orif you require foreign language interpreter to help you fully participate in court proceedings, please contact the courtimmediately to make arrangements. Mc o1 (5/15) SUMMONS AND COMPLAINT Mca 2.102(8)(11), MCR 2.108, MER 2.405, MOR 2.107, MOR 2.113{6)(2a), (0), MOR 3.206(4)—— ‘SUMMONS AND COMPLAINT PROOF OF SERVICE Case No. TO PROCESS SERVER: You are to serve the summons and complaint nat later than 91 days from the date of filing or the date ofexpirationon the order for second summons. Youtust makeandfile yourretum withthe courtclerk. ifyouare unable tocomplete service you must return this original and all copies to the court clerk. CERTIFICATE / AFFIDAVIT OF SERVICE /NONSERVICE 1 OFFICER CERTIFICATE OR (O AFFIDAVIT OF PROCESS SERVER cert hat ama shor Sept her Ea appohted Bangi cy evar tte tet am legal comport | | sorties oratemoy ora pay (MGR H(A), ond adulwhotsnetapajoran ofscfaconeraspary sed [ fat "esr tact tt ttt mre 1 served personally & copy of the summons and complain, “1 served by registered or ceritied mail (copy ofretum receipt attached) a copy ofthe summons and complaint, togetherwith —_ (Stal acamants served wi he Summons and Compan - = on the defendant(s): [Defendant's name ‘Complete address(es) of service Day, dale, time - __| CIthave personally attempted to serve the summons and complaint, together with any attachments, on the following defendant(s) ‘and have been unable to complete service. Defendants name ‘Gomplata address(es) of sonics Bay, date te | declare that the statements above are true to the best of my information, knowledge. and belief [Service fee ‘Miles traveled | Mileage fee | Total fee Can s |s $ ame Type orp oo ‘Subscribed and sworn to before me on county, tichigan, ate My commission expires: : Signature: = Dae epi cour clanccany pubes Notary public, State of Michigan, County of ACKNOWLEDGMENT OF SERVICE | acknowledge that | have received service of the summons and complaint, together with on Bay, die tne on behalf of Signaturetga - Cou copy - int Approved, SCRO Sa py atandant Sisco Raton STATE OF WCHTGAN ] CASE NO. JUDICIAL DISTRICT ‘UoIciat cinco, SUMMONS AND COMPLAINT : County PROBATE, (1000065: 4, Coa Wino wo. Sou waar > 925 W. Ottawa St, P.O, Box 30185, Lansing, Michigan 48909 [Plante namely aaaesten) and aoprane wT DETROIT PUBLIC SCHOOLS COMMUNITY DISTRICT 01 W. Grand Blvd Det, Michigan 48202 (313) 576-0100 | Defendants narets), address(es), and telephone no) vy _|STATE OF MICHIGAN Prats atiomoy, bar na [Scott R. Eldridge (P66452) oe eee Michigan Department of Attomey General MILLER, CANFIELD, PADDOCK AND STONE, P.L.C, JG. Mennen Williams Building, 7h Floor 525 W. Ottava St, P.O. Box 302: [One Michigan Avenue, Suite 900, Lansing, Michigan 48933, ieee cers (ornasraais ansing, Michigan SUMMONS | NOTICE TO THE DEFENDANT: In the name of the people of the State of Michigan you are notified 1. You are being sued, 2. YOU HAVE 21 DAYS after receiving this summons to file a written answer with the court and serve a copy on the other party ortake other lawful action with the court 28 days if you were served by mailor youwere servedoutside this state). (WeR2.111(C)) 3. Ifyou do not answer or take other action within the time allowed, judgment may be entered against you for the relief demanded, in the complaint, Issued [This Summons expires Court derk ~ 3:11 8017 I 1G Oly Jerome W. Zimmer Jr. “Tis uring val ess Served enor Sf ts anno dle This document most be eal W TTL COMPLAINT) instruction: The followings information that is required to be inthe caption of every complaint andis to be completed ‘by the plaintiff. Actual allegations and the claim for relief must be stated on addtional complaint pages and attached to this form, | This is a business case in which all or part of the action includes a business or commercial dispute under MCL 600.8035. Family Division Cases | There isno other pending orresolved action within the jurisdiction ofthe family division of circuit courtinvolving the family or family members of the partes. ‘An action within the jurisdiction of the family division ofthe circuit court involving the family or family members of the parties has been previouslyfiledin Court The action | remains ‘sno longer pending. The docket number and the judge assigned to the action are: (Backat no age Barn General Civil Cases | There is no other pending or resolved civil action arising out of the same transaction or occurrence as alleged in the complaint. 7 Acivil action between these parties or other partes arising out of the transaction or occurrence alleged in the complaint has been previously fled in Court of Claims Court. The action yiremains jis no longer pending. The docket number and the judge assigned to the action are: (Becket no. age Barra. 2017-000044-Mz, ‘Stephen L. Bortello 37368 VENUE | Plains) resance Tnclude Gy, Weanehi, Wagay Detendani()reslderce (clude iy, township, o aga) lace where aalon arose ar usnaas conducled 0317/2017 dae Senaice owen 7 you require special accommodations iouse the court because of a csabiltyorifyou requir (oreign language interpreter tohelp you full participate in cour proceedings, please contact the cout immediately to make arrangements Mc 01 (5/15) SUMMONS AND COMPLAINT — MCR 2.102(8)11), MR 2 104, MCR 2.105, MOR 2.107, MCR 2113(6}2Na,(b, MER 320848)[PROOFOF SERVE] casos ‘SUMMONS AND COMPLAINT TO PROCESS SERVER: You are to serve the summons and complaint not later than 91 days from the date of fling or the date ‘of expirationon the order for second summons. Youmust make andfie yourreturn withthe court clerk. fyouare unableto complete. service you must return this original and all copies to the cour clerk. OFFICER CERTIFICATE OR (AFFIDAVIT OF PROCESS SERVER | certify that | am a sheriff, deputy sherif, bail, appointed Being first duly swom, | state that | am a legally competent | court officer, or attomey for a party (MCR 2. 104[A[2}), and ‘adult who is nota party oran officer of corporate party, and, | that: (eotaizaton not requiced) that: (notarzation required) || served personally a copy of the summons and complaint, | served by registered or certified mail (copy of return receipt attached) a copy of the summons and complaint, together with CERTIFICATE / AFFIDAVIT OF SERVICE / NONSERVICE {Ist a docamonts sored with he Summons and Complaint — on the defendant(s) Belondants name ‘Complete adress(es) of sonice Day. date tne and have been unable to complete service. Ihave personally attempted to serve the summons and complaint, together with any attachments, on the following defendant(s) [Detendants name ] Complete address(es) of service Day dae, te ] | declare thatthe statements above are true to the best of my information, knowledge, and belief [Service fee [Wiss waveled | ticage ee | Total eo oceaa § L § Namie ype or pry THe ‘Subscribed and swomn to before me on ‘| ‘County, Michigan, Date My commission expires: __ Signature: = tae Deputy cour GeriNotary pubis Notary public, State of Michigan, County of [ ACKNOWLEDGMENT (OF SERVICE | acknowledge that | have received service of the summons and complaint, together with Richman on : Day, date tine on behalf of SignaSTATE OF MICHIGAN IN THE COURT OF CLAIMS DETROIT PUBLIC SCHOOLS COMMUNITY DISTRICT, Plaintiff, vs. STATE SCHOOL REFORM/REDESIGN OFFICE, an autonomous entity within the Michigan Department of Technology, Management, and Budget; NATASHA BAKER, the State School Reform/Redesign Officer in her official capacity; and the STATE OF MICHIGAN, Defendants. Jerome R. Watson (P27082) Scott R. Eldridge (P6452) Amanda Van Dusen (P31195) Michelle P. Crockett (P61830) MILLER, CANFIELD, PADDOCK. AND STONE, P.L.C. Phyllis L. Hurks-Hill Co-counsel for Plaintiff Detroit Public Schools Community Distriet 3011 West Grand Boulevard, Suite 1002 Detroit, MI 48202 (313) 873-4528 Public Counsel for Plaintiff Detre Schools Community District 150 West Jefferson, Suite 2500 Detroit, MI 48226 (313) 963-6420 VERIFIED COMPLAINT FOR DECLARATORY, ANDI (CTIVE RELIEF A civil action between other parties arising out of transactions or occurrences similar to those alleged in this complaint has been previously filed in this Court, where it was given docket number 2017-000044-MZ. and was assigned to Judge Stephen L. Borrello, The action remains pending.Plaintiff, the Detroit Public Schools Community District, by its attorneys, MILLER, CANFIELD, PADDOCK and STONE, P.L.C., brings this Complaint against the State School Reform/Redesign Office, Natasha Baker in her official capacity as School Reform/Redesign Officer, and the State of Michigan (collectively “Defendants”), seeking declaratory and injunctive relief. In support of this Complaint, Plaintiff states as follows: L INTRODUCTION 1. Without statutory or other legal authority, Defendants, exercising what amounts to an unconstitutional delegation of legislative power, are attempting to close sixteen Detroit publi schools or remove them from the newly created Detroit Public Schools Community District (DPSCD"). Not only do Defendants lack authority 10 do so, their actions are based on flawed data, violations and misinterpretations of the Revised School Code, arbitrary and capricious criteria, violations of the Michigan constitution, and substantive rules created and relied upon by Defendants in violation of the Administrative Procedures Act. 2 Students’ educations are at stake. On July 1, 2016 — following seven years in which the State of Michigan, through its emergency management law, was in total control of, Detroit's public schools ~ the Legislature created the DPSCD to tum around Detroit's struggling schools, Defendants’ illegal actions now threaten the stability of the very schools that the DPSCD was created to improve — less than a full schoo! year into its existence. 3. This is an action for declaratory and injunctive relief to stop and correct Defendants’ unlawful actions. Defendants’ unlawful actions have a disproportionate, negative impact on minority populations, Indeed, the student bodies of all of the DPSCD schools recently identified for potential closure are 98% or more non-white5. Defendants’ unlawful actions also have a disproportionate, negative impact on those who are economically disadvantaged. Indeed, the student bodies of all of the DPSCD schools recently identified for potential closure are overwhelmingly considered economically disadvantaged. 6. The closure of DPSCD schools also would eliminate comerstones of Detroit ‘communities, and leave many Detroit parents without a viable neighborhood school. 7. Closing schools is not the answer to improving public education in Detroit. Schoo! closure would uproot DPSCD students from their current environment and force them to enroll in new schools that are not substantially better than their current schools. 8. Consistent with the rules of notice pleading in Michigan, the purpose of this Complaint is to put the Defendants on notice of claims consistent with the allegations contained herein, and is not meant to be an exhaustive identification of each and every actionable act (or failure to act) committed by Defendants. II, JURISDICTION AND VENUE 9, This action is filed pursuant to Section 6419 of the Revised Judicature Act, MCL 600.6419, MCR 2.605, MCR 2.201(C)(S), and the Court's power to grant injunctive relief (see MCR 3.310) 10. A speedy hearing and advancement of this matter on the Court's calendar is appropriate under MCR 2,605(D) given that Defendants" conduct has already disrupted the lives of DPSCD students and their families, and DPSCD students will suffer irreversible harm if Defendants’ plans are allowed to progress any further. ‘The immediate and negative impact of Defendants’ conduct on the DPSCD community has been additionally exacerbated by the Defendant State School Reform/Redesign Office's recent decision in January 2017 to send letters to families threatening them that schools may be closed before completing its analysis.11. This Court has jurisdiction and authority to declare the rights and legal relations of the parties to this action, and to award injunctive relief against these Defendants. 12, Venue is proper in this Court. ML. INERAL ALLEGATIONS A. ‘The Parties 13. Prior to July 1, 2016, the public school district responsible for providing educational services to students in the City of Detroit was the Detroit Public School District DPS"). 14, On June 21, 2016, Public Act 192 of 2016 (“Act 192”) was enacted with immediate effect. Act 192 amended The Revised School Code, 1976 PA 451, MCL 380.1 to 380.1853 (“the School Code”). 15, For most of its history, DPS ~ like virtually every other schoo! district in the State — was governed by an elected school board. In 2009, however, acting pursuant to Michigan’s “emergency manager” law, Governor Jennifer Granholm declared a state of financial emergency in DPS, and appointed an emergency manager to DPS’s helm. Michigan's emergency manager law provides State-appointed emergency managers with “broad powers,” including, as relevant, the power to govern “in the place and stead of the governing body.” MCL § 141.1549. 16. A State-appointed emergency manager remained at the helm of DPS for seven years, During that time, DPS accrued hundreds of millions of dollars in debt, and its students” academic performance was the worst in the Nation. 17. Act 192 created the DPSCD, located in Detroit, Michigan. MCL 380.383. 18. With limited exceptions, the DPSCD is organized and conducted in the same manner as a “general powers school district” (the name given to a typical school district in this State), DPSCD has all of the powers of a general powers school district under Section 1 1a of the 4.School Code, along with additional powers granted by law to a community district or the school board of a community district. MCL 380.382, 19. Effective July 1, 2016, Act 192 transferred all but a select few functions, responsibilities, and assets of the Detroit Public Schools (“DPS”) to the newly-created DPSCD, including the responsibility to provide public education services for residents of the same geographic area as the former DPS. MCL 380.383. 20. The Legislature enacted Act 192 to provide DPSCD schools with a fresh start on. July 1, 2016 by restructuring the liabilities of DPS, placing DPSCD under new governance, and creating a system of financial oversight, thereby enhancing DPSCD"s ability to deliver educational services. 21. Act 192, moreover, restored day-to-day control over Detroit’s public schools to an elected board, On January 1, 2017 ~ following a six-month period in which a State-appointed “transition manager” remained at the helm of DPSCD ~ an elected school board took office, and was empowered to manage DPSCD schools. 22. DPSCD operates 105 schools, including innovation programs and schools such as STEAM Academies, Career Technical Centers, public Montessori, dual language immersion, expanded Academy of Blended Learning, additional accelerated academic programs and smaller high school communities, 23. DPSCD educates more than 45,000 students. 24. Defendant State School Reform/Redesign Office (“Reform Office”) was created by Executive Order (EO 2015-9) as “an autonomous entity the Michigan Department of, ‘Technology, Management and Budget” (“DTMB”), and meets the definition of “Agency” under the Administrative Procedures Act, MCL 24.203(2),25. The DTMB is a department within the Defendant State of Michigan's Executive Branch, and meets the definition of “Agency” under the Administrative Procedures Act, MCL. 24,203(2). 26. Defendant Natasha Baker serves as the State School Reform/Redesign Officer (°SRO") within the Reform Office. The SRO is an “Agency” as defined in the Administrative Procedures Act. MCI 24.2032). 27. Defendants’ principal places of business are located in Lansing, Michigan. B. Statutory Background: Act 192 and Section 1280¢ of the Revised School Code 28. The Michigan Constitution provides for a system of free public elementary and secondary schools. Const. 1963, art 8, § 2. To oversee and implement this education system, the Constitution provides for a state board of education, a superintendent of public instruction (“State Superintendent”), and a department of education. Const. 1963, art 8, § 3. 29. In 2010, the Legislature established a requirement within the School Code that the State Superintendent “publish a list identifying the public schools in this state that the Michigan Department of Education had determined to be among the lowest achieving 5% of all public schools in the State” (“Bottom 5% List”), as defined for purposes of the federal incentive grant program (known as “Race to the Top” grants) created under Sections 14005 and 14006 of Title XIV of the federal American Recovery and Reinvestment Act of 2009 (“ARRA”). ‘That requirement was codified as Section 1280¢ of the Revised School Code. (Exhibit 1). 30. Michigan never qualified to receive federal Race to the Top grant funding and the Race to the Top program expired in 2011. Yet, Section 1280c remains the law in Michigan. 31. No federal law defines how a Bottom 5% List is to be determined.32. Section 1280c of the Revised School Code mandates that a new Bottom 5% List is to be published “not later than September I of each year.” MCL 380.1280c(1). Section 1280e does not provide any idance, means, or parameters for generating the Bottom 5% Lists 33. Section 1280c also provides that the State Superintendent is to “issue an order school that placing each put included on the [Bottom 5% List] list under the supervision of the state school reform/redesign officer.” MCL 380.1280¢(2). 34, Once identified on a Bottom 5% List, a school is deemed a “Priority Schoo!” subject to the supervision of the SRO for at least the next four years, whether still on the Bottom 5% List or not 35. Thus, the Priority School list is distinct from the annual Bottom 5% Lists. 36. Priority Schools are required to submit a “redesign plan” to the Reform Office that incorporates one of four pre-determined “school intervention models,” namely: “the tumaround model, restart model, school closure, and transformation model.” MCL 380.1280c(2). Each “redesign plan” submitted subject to approval by the SRO. 37. Section 1280c also created the State School Reform/Redesign School District (Reform District”), a public school district, body corporate and governmental agency. The SRO serves as the superintendent of the Reform District. MCL 380.1280e(6). 38. Section 1280c provides that a public school may be placed in the Reform District if the SRO does not approve a redesign plan proposed by a Priority School; or if the SRO “determines that the redesign plan is not achieving satisfactory results.” MCL 380.1280e(6). If 80, the SRO shall serve as the school’s de facto superintendent and school board, and shall impose one of the four school intervention models, including potentially closure. Id.39, There is no statutory or regulatory provision defining or setting parameters for how the SRO “determines that the redesign plan is not achieving satisfactory results,” leaving that statutory phrase susceptible to arbitrary enforcement and administration, 40, Section 1280c provides that the SRO may recommend that the State Superintendent appoint a chief executive officer (“CEO”) to take control of multiple public schools if the SRO “determines that better educational results are likely to be achieved.” MCL. 380.12800(7). 41. If appointed, the CEO would impose one of the four intervention models, including potentially closure. Id, Once appointed, the CEO has all of the same powers and duties that the SRO has for pub! ‘chools placed in the Reform District. Id. 42, There is no statutory or regulatory provision defining or setting parameters for how the SRO “determines that better educational results are likely to be achieved” if the CEO is appointed, leaving it susceptible to arbitrary enforcement and administration. 43, When the Legislature enacted Public Act 192 — the Act which created DPSCD, and thereby provided Detroit public schools a “fresh start” — it added two DPSCD-specific requirements related to the SRO. a. First, under Act 192, the SRO must establish and administer an “accountability system” for all DPSCD schools beginning with the 2017-2018 school year. MCL 380.390, b. Second, until that accountability system has been in effect in the DPSCD for at least three full school years, “if a school operated by a community district among the lowest achieving 5% of all public schools in this state for the immediately preceding 3 school years, as determined under section 1280c, the[SRO] shall order the community district to close the school effective no later than the end of the current school year.” MCL 380.391(1). 44, The SRO thus cannot close DPSCD schools under Act 192 unless either (1) the DPSCD “accountability system” has been in place for at least three full school years; or (2) “a school operated by a community district” was on the bottom 5% list “for the immediately preceding 3 school years.” MCL 380.390. 45. On January 10, 2017, Michigan Senate Education Committee Chairman Phil Pavlov announced that he would introduce a bill to repeal Section 1280c. Senator Pavlov explained that Section 1280e and “its execution have, unfortunately, been deeply flawed,” and that Defendants’ application of Section 1280c has been “chaotic” for schools, students, and the public alike. Senator Pavlov also emphasized that “formulas to identify schools keep changing, tests used to inform those formulas have changed, and department decision-making is vague and subjective.” See http://www.senatorphilpavlov.com/sen-pa repeal-failing-schools-law/, 46. Defendants have indicated that pending efforts to repeal Section 1280c will not affect their plans to potentially close schools or otherwise control them in violation of state law. C. Executive Order 2015-9 Stripped Constitutional Powers Away from the SBE, the MDE, and the State Superintendent, 47. On March 12, 2015, Governor Rick Snyder signed Executive Order 2015-9 (“EO 2015-9"), which created the Reform Office as an autonomous entity within the DTMB, and transferred the Reform District from the Michigan Department of Education (“MDE”) to the newly created Reform Office. (Exhibit 2).48. EO 2015-9 also transferred almost all of the powers under Section 1280c of the School Code ~ powers that were formerly vested with the office of the State Superintendent ~ to the SRO. 49, Asa result, the SRO is responsible for, among other things: a, determining which public schools are among the lowest achieving 5% of all public schools in the State; b. publishing a list each year by September 1 of the lowest achieving 5% of all public schools in the State; c. issuing orders placing each school included on the lowest achieving list under the supervision of the SRO; 4d, releasing public schools from redesign measures imposed under Section 1280 of the School Code or from the jurisdiction of the Reform Office if the SRO determines that significant academic improvement has been made at a particular public school; and e. appointing a CEO to take control of public schools if the SRO determines that better educational results are likely to be achieved. 50. The gan Constitution requires that “[IJeadership and general supervision over all public education” be “vested in a state board of education” and that the state board of education (“SBE”) appoint a State Superintendent as the principal executive officer of the MDE. Const. 1963, art 8, § 3. 51. The only exception to the constitutional requirement that supervision over all public education be vested in (1) the SBE, (2) the State Superintendent and (3) the MDE is for institutions of higher education granting baccalaureate degrees, which is not relevant here. Const. 1963, art 8, § 3. -10-52. EO 2015-9 transferred the Reform Office and SRO's substantial powers related to leadership and supervision over public education to the DTMB and away from the SBE, the State ‘Superintendent and the MDE. 53. EO 2015-9 therefore lates the plain language of the Michigan Constitution, and any action carried out while the Reform Office and SRO have been under DTMB supervision is, unconstitutional dD. Recent Bottom 5% Lists Violate Section 1280c of the School Code 54 Section 1280c of the School Code mandates that the State Superintendent publish a Bottom 5% List each year by no later than September 1. Pursuant to transfer of powers effected by EO 2015-9, the SRO has purported to carry out that duty. 55, Asa condition precedent to being subject to closure in 2017 under Act 192, even if it were to apply under these circumstances, a school within the DPSCD must have appeared on a validly issued Bottom 5% List for school years 2013-2014, 2014-2015, and 2015-2016. MCL 380.391(1). 56. On August 6, 2014, the MDE published what was then called a Top-to-Bottom List, which identified a bottom 5% of public schools for the 2013-2014 school year based on criteria the MDE revised in August 2014 (hereinafter “2013 Bottom 5% List”). 57. The 2013 Bottom 5% List was based on data from the now-retired MEAP test that was administered in the fall of 2013, 58. Twenty-two DPS schools were identified on the 2013 Bottom 5% List. 59. In violation of Section 1280c’s mandate that a new list be published “each year, the State did not publish a new Bottom 5% List in 2015 based on new academic data from the ied the 2013 Bottom 5% List, 2014-2015 school year. Instead, on September 1, 2015 it reput this time entitled “Priority Schools Named in the Bottom 5% in 2014” (hereinafter “2014 Bottom5% List”). This list was nothing more than a duplicate of the 2013 Bottom 5% List, which Defendants have admitted. (Exhibit 3). 60. The SRO has admitted that the 2014 Bottom 5% List was based on the same fall 2013 MEAP test data as the 2013 Bottom 5% list, ‘The old data was reused ~ without statutory authority ~ because during the 2014-2015 school year, the State changed its testing requirements from the MEAP test (administered in the fall) to the M-STEP test (administered in the spring). 61. Asa result, there was no standardized test administered during the 2014 calendar year, and no standardized test measured students’ academic performance between the fall 2013 MEAP test and the spring M-STEP 2015 test. 62. Of course, since the 2014 Bottom 5% List was merely a carbon copy of the 2013 Bottom 5% List, the same twenty-two DPS schools appeared again on the 2014 Bottom 5% List 63, Because the 2014 Bottom 5% List was published on September 1, 2015 but was based on data for the 2013-2014 academic year, it did not satisfy the State's obligation under Section 1280¢ to publish a Bottom 5% List reflecting academie performance for the 2014-2015 school year by September 1, 2015. 64, Put differently, the 2014 Bottom 5% List was published a full year past the deadline prescribed by Section 1280c. 65. On September 1, 2016, the SRO published a Bottom 5% List called the “2015 Lowest Achieving 5% List” (hereinafter “2015 Bottom 5% List”). (Exhibit 4). 66. The 2015 Bottom 5% List was purportedly based on the 2014-2015 M-STEP test administered in spring 2015. 67. Forty-seven DPSCD schools were included on the 2015 Bottom 5% List. 68. Because the 2015 Bottom 5% List was published on September 1, 2016 but was based on data for the 2014-2015 academic year, it did not satisfy the State’s obligation under -12-se CaN, RODE ASTON LC, Section 1280c to publish a Bottom 5% List reflecting academic performance for the 2014-2015 school year by September 1, 2015. 69. Put differently, the 2015 Bottom 5% List was published a full year past the deadline prescribed by Section 1280c. 70. On September 1, 2016, the SRO also sent DPSCD a letter identifying Priority Schools within the DPSCD, including those on the 2015 Bottom 5% List. In that letter, the SRO demanded that already-existing Priority Schools submit a “revised” reform plan by September 30, 2016, without statutory authority to demand a “revised” reform plan. 71. On September 23, 2016, the SRO sent DPSCD a “revised” letter identifying additional Priority Schools, again demanding that already-existing Priority Schools submit a “revised” reform plan by September 30, 2016, without statutory authority to demand a “revised” reform plan, (Exhibit 5), 72, On January 20, 2017, the Reform Office published a Bottom 5% List called the “2016 Lowest Achieving 5% of all Public Schools” (hereinafier referred to as the “2016 Bottom 5% List”). (Exhibit 6), 73, The 2016 Bottom 5% List reflected academic performance for the 2015-2016 academic year. 74. Forty-five DPSCD schools were included on the 2016 Bottom 5% List. 75, Because the 2016 Bottom 5% List was published on January 20, 2017 but was based on data for the 2015-2016 academic year, it did not satisfy the State’s obligation under Section 1280¢ to publish a Bottom 5% List reflecting academic performance for the 2015-2016 school year by September 1, 2016. 76. Put differently, the 2016 Bottom 5% List was published nearly five months past the deadline prescribed by Section 1280c. 13!77. Furthermore, the SRO published the 2016 Bottom 5% List without explicitly stating the basis for that list, including what data or rules were used to generate the list. 78. In sum, the State has not published a timely Bottom 5% List since August 6, 2014, as every Bottom 5% List published since that time has been untimely, based on improper data, or both. E, The SRO’s jolation of Act 192 79. Since Act 192's effective date of July 1, 2016, the SRO has threatened publicly to close DPSCD schools under Act 192 and Section 1280c of the School Code. 80. In the summer of 2016, before the announcement on September 1 of which schools would be subject to closure, the Reform Office prepared an “Annual Timeline (2016- 2017)" detailing “proposed target dates” for DPSCD, including a “Closure Dissolution Process” for February 6, 2017 and “Mandated Closures” of DPSCD schools on June 30, 2017, (Exhibit D. 81. On January 20, 2017, the SRO published a list of thirty-eight “Schools Identified for the Next Level of Accountability,” which includes closure, sixteen of which are DPSCD schools. (Exhibit 8). 82. Also on January 20, 2017, the SRO published a list of thirty-five “Schools At- Risk for Next Level of Accouniability,” including closure, twenty-three of which are DPSCD schools. (Exhibit 9). 83. In meetings with DPSCD, the SRO has indicated that the “next level of accountability” will be closure. 84. In a press release dated January 20, 2017, the SRO stated that the thirty-eight schools identified in its list of “Schools Identified for the Next Level of Accountability” were “at tisk of closure.” (Exhibit 10). -14-85. In fact, the SRO’s press release dated January 20, 2017 indicated that the thirty- eight schools identified S list of “Schools Identi for the Next Level of Accountability” were already subject to a “closure notice.” (Ic.). 86. On January 20, 2017, the SRO additionally sent letters (“Parent Letters”) to the parents/guardians of students enrolled in schools on the list of thirty-eight “Schools Identified for the Next Level of Accountability.” (Exhibit 11), ‘The Parent Letters stated, in part, “You are receiving this letter because the school your child attends is at risk of being closed by June 30, 2017 due to academic failure for many years.” ‘The Parent Letters also purported to provide information parents/guardians could use “to enroll [their] child{ren] in a better option for the 2017-2018 school year.” 87. The Parent Letters listed “Additional District's [sic] Within the Area” but did not list the capacity or willingness of schools within those districts to accommodate additional students. Furthermore, many of the additional districts were not in the same county, or even in a contiguous county, as the students” home district, and several were more than 40 miles from the DPSCD school the students currently attend. 88. The January 20, 2017 letters and lists threatening closure have caused tremendous distress, confusion, and anxiety for DPSCD students and their parents/guardians because the threats have created an atmosphere of uncertainty about the future of the students’ educations. 89. As of February 2017, DPSCD has operated schools for only one full academic semester. 90. Act 192 does not provide the SRO with authority to close DPSCD schools, as threatened. 91. Under Act 192, the SRO must establish and administer an “accountability system” for all DPSCD schools beginning with the 2017-2018 school year. MCL 380,390, -15-ie te MICE MND STONE LC 92, Act 192 provides that, until the accountability system has been in effect in the DPSCD for at least three full school years, “if a school operated by a community district is ‘among the lowest achieving 5% of all public schools in this state for the immediately preceding 3 school years, as determined under section 1280¢, the [SRO] shall order the community district to close the school effective no later than the end of the current school year.” MCL 380.391(1). 93. Because DPSCD ~ a brand new school district ~ did not operate any of the schools on any Bottom 5% List for the three immediately preceding school years, the SRO cannot close them under Section 391(1) before July 1, 2019 (three years after DPSCD was first created). 04. Ifthe SRO is permitted to close DPSCD schools during or immediately after the 2016-2017 school year — as she intends to do ~ the DPSCD will never be fen a proper opportunity to fulfill its intended purpose, which is to tur around its lowest achieving schools. This would render Act 192 an exercise in futility. 95, The announcement, in and of itself, that a particular DPSCD school will be closed causes significant harm; it creates instability within the school and robs parents of any confidence in DPSCD"s turnaround efforts, which are just getting started. 96. Stability is a vital element of student success. Studies consistently show that students are affirmatively harmed when they are forced to switch schools. Such students tend to exhibit depressed academic performance and reduced attendance. They are also less likely to graduate from high school or attend college. The negative consequences worsen the more frequently students are forced to change schools. (Exhibit 12). 97, DPSCD students are at particularly grave risk of harm if they are forced to change schools. (Id). -16-The y of Detroit has already seen approximately 150 of its schools close in the last eight years, several times more than in any other Michigan city. During that time, approximately 125 new schools have opened. This has created an unstable educational experience for many DPSCD students. The majority of Detroit students have already switched schools at least once for a reason other than an increase in grade level. ‘The percentages of students who have experienced such forced transfers are especially high in the schools the SRO has slated for closure. Consistent with national studies linking educational instability with poor academic performance and absenteeism, Detroit students perform worse than their peers on academic measures and have higher rates of absenteeism. There are very few high-quality educational institutions with availability in the near vicinity of most of the DPSCD schools the SRO has slated for closure ~ only 20 schools in Detroit are ranked among the State’s top 25% of schools, and most of those are already at eapacity High-quality schools are predominantly located at great distances away from Detroit and are inaccessible by public transportation. Between 20% and 40% of households in most Detroit neighborhoods served by the schools the SRO has slated for closure lack any access to an automobile, making it impossible for families to drive long distances every day to take children to school. The affected neighborhoods also have extremely high levels of families living in poverty, making it highly unlikely that many parents would be able to drive their children 25, 30 or 100 miles to and from school every day, both because of the -I7-costs of gasoline and car maintenance, and because many such parents do not have flexible work schedules. 98. Furthermore, school closures will result in the loss of significant state funding, sabotaging the financial health of DPSCD before it has had a fair opportunity to turn around its lowest achieving schools. 99. In sum, any State-imposed closure of DPSCD schools before DPSCD has “operated” those schools for at least three years not only violates the plain text of Act 192, it also prevents DPSCD from taking advantage of the fresh start Act 192 was meant to provide F. ‘The SRO’s Arbitrary Application of the Unreasonable Hardship Analysis 100. Act 192 provides that the SRO may choose not to close a schoo! “Jf the [SRO] determines that closure of the publie school would result in an unreasonable hardship to these pupils because there are insufficient other public school options reasonably available for these pupils.” MCL 380.391(3), 101, Act 192 does not further define “unreasonable hardship” or “insufficient other public school options.” 102, The application of Act 192’s “unreasonable hardship” language is therefore susceptible to arbitrary and capricious enforcement. 103, Ina letter received on Friday evening, January 27, 2017 (the “Hardship Letter”), the $RO informed DPSCD schools that its unreasonable hardship review would consist of three parts: (1) a review of “all available data related to the past and current performance” of each school identified for closure; (2) a half-day site visit to each school; and (3) an examination of other public schools in the grade levels and geographic area of each school. (Exhibit 13), 104, The SRO’s Hardship Letter demanded, wi in days, significant data for each school identified for closure, including detailed curricula information, academic and “18.i cra, ODEN TONE, PG, social/emotional/behavioral intervention systems used, and buildin, formation, such as floor plan drawings; but did not request any contextual information regarding the hardship that could arise if the school were closed. 105. The SRO’s Hardship Letter demanded that this information be submitted on or before Wednesday, February 1, 2017, giving schools merely three business days to compile the extensive information requested. 106, Furthermore, the SRO’s Hardship Letter stated that if the SRO were to rescind a closure order based on unreasonable hardship, “the district and school leadership must submit a school improvement plan to the SRO that includes measures to increase pupil growth and improve pupil proficiency, with growth and proficieney measured by performance on state assessments.” 107. The SRO’s Hardship Letter further indicated that the purpose of the half-day site to schools identified for closure would be to assess academic performance and facility vi conditions, 108, The SRO provided no indication of how it developed its “unreasonable hardshi criteria. 109. In fact, the SRO's Hardship Letter indicates that its unreasonable hardship analysis is based on academic performance, rather than the hardship school closure would impose on students, their parents/guardians, and the broader community, 110. In reality, the SRO"s closure of any DPSCD schools would impose severe hardship on students, their parents/guardians, and the broader community, which the SRO's Hardship Letter wholly ignores. -19-111. On February 14, 2017, the State Board of Education adopted a Statement on School Closures and Definition of Hardship (“SBE Statement”), advising that the SRO rescind all school closures. (Exhibit 14), 112, The SBE Statement accurately states that “[n]o clear definition for “Unreasonable Hardship’ exists” for the SRO to apply. 113. The SBE Statement, based on academic research, lists a number of harms that the SRO's plan to close schools has already caused and further harms the SRO's plan will cause if allowed to go forward. ‘These include: a. Students’ increased drop-out rates, decreased achievement, increased risk of substance abuse, decreased occupational prestige, increased symptoms of depression, and increased likelihood to be arrested as adults; and b. Trauma on the community and students’ feelings of loss in a manner similar to mourning. 114, The SBE Statement also correctly pointed out that “[eJonsiderable changes to test content and delivery have occurred over the last four years and [are] likely to change again to address the newly authorized federal law, ‘Every Student Succeeds Act,”” which phased out the No Child Left Behind Act. 115. On February 20, 2017, DPSCD provided the SRO with a detailed, research-based letter describing the harms DPSCD students and their families would suffer if any of their schools were closed. (Exhibit 12). Studies have shown that forcing students to change schools for reasons other than grade promotion decreases academic performance, increases the risk of chronic absenteeism, and reduces the likelihood of graduating from high school, The negative consequences of school closure would be particularly acute for students in DPSCD schools, -20-because there are few or no high-quality schools with available seats in the immediate vicinity of the schools the SRO has threatened to close. 116, Additionally, the SRO has suggested that DPSCD students could attend schools in other school districts, but many of the school districts proposed by the SRO are located far from Detroit, Indeed, some approximately an hour's drive from Detroit. There are no public transportation options available to facilitate transportation to many of the altemative school districts the SRO has proposed, and many of the parents/guardians of DPSCD students lack the transportation resources or the flexible work hours needed to transport students long distances on a daily basis. 117, Because the student bodies of the DPSCD schools identified by the SRO for closure are predominantly economically disadvantaged and their families frequently have no personal transportation, increased travel distances ereate a particularly acute risk of increased drop-out rates, decreased achievement, and the other harms identified in the SBE Statement ‘Any failure by the SRO to consider such harms is urbitrary and capricious, G. The SRO's Invalid Business Rules for Creating the Bottom 5% Lists 118, Section 1280c mandates that the Bottom 5% List is to be created as defined for purposes of the Race to the Top program created under Sections 14005 and 14006 of Title XIV of the federal ARRA. 119. Although Sections 14005 and 14006 of the ARRA invite applications and set certain criteria for Race to the Top grants, they do not define the “lowest achieving 5%” for purposes of Section 1280¢ of the School Code. Further, the grant program created by those Sections expired in 2011. 21.InuieR CMEELE PADBOCKAND STONE PLC | = 120. Without statutory authority, Defendants have created and used their own set of “‘pusiness rules,” with the force and effect of law, for determining the Bottom 5% Lists under Section 1280c. 121. On September 1, 2016 — the same day that it published the 2015 Bottom 5% List the Reform Office published the “SRO Bottom Five Business Rules,” announcing for the first time the rules it used to create the 2015 Bottom 5% List. (Exhibit 15), 122. The SRO Bottom Five Business Rules published by the SRO on September 1, 2016 are different from the previous sct of SRO business rules (dated August 7, 2014) utilized to create the Bottom 5% Lists. 123. The SRO Bottom Five Business Rules establish in detail the complex criteria and data the SRO used to create Bottom 5% Lists under Section 1280c, including “Eligibility” rules and “Calculation Methodology” rules. 124. N ‘er Section 1280c of the School Code nor Act 192 authorizes Defendants to promulgate rules under the Administrative Procedures Act (“APA”). 125. The SRO Bottom Five Business Rules, despite having the force and effect of law and meeting the definition of “Rule” under the APA, have not been promulgated in compliance with the APA. 126. As for the 2016 Bottom 5% List, the SRO did not publish business rules or other criteria used to create it. Instead, on information and belief, the SRO relied on the MDE’s “Top- to-Bottom School Rankings and Reward School Identification Business Rules” (“MDE Top-to- Bottom Business Rules”), which were first made publicly available on or around December 12, 2016 (Exhibit 16). 127. The MDE Top-to-Bottom Business Rules were not designed to be used by the SRO to create its Bottom 5% List. aaa128. As adopted by the SRO, the MDE Top-to-Bottom Rules, despite having the force and effect of law and meeting the definition of “Rule” under the APA, have not been promulgated in compliance with the APA. H. The SRO’s Invalid “Exit Criteria” 129. According to the Reform Office, once a school is identified on a Bottom 5% List, it is designated a Priority School, subject to the SRO’s oversight for at least four years. 130. Section 1280¢ of the School Code grants the SRO ill-defined discretion to impose a different redesign plan on a Priority School ~ including closure ~ if the SRO “determines that the redesign plan is not achieving satisfactory results.” MCL 380.1280c(6). The Legislature failed to define “achieving satisfactory results” or otherwise provide standards within which the SRO is to make that determination, amounting to an unconstitutional delegation of authority. 131. In exercising that unconstitutional delegation of legislative authority, Defendants, have created a set of three “exit criteria” that the SRO uses to “release” schools from the Priority designation: 1] Top-to-Bottom Requirement (TTB): The school must have a TTB percentile rank of 5 or higher. [2] Annual Measurable Objective (AMOs): The school must meet its AMOs for both math and reading in the all-students subgroup. [3] Assessment Participation Requirement: ‘The school must have at least a 95% participation rate on all required state assessments.” See hitp://vww.michigan.gov/sro/. These three “exit eriteria” appear nowhere in the School Code, and Defendants have never explained how these “exit criteria” were created or selected. 132. The 95% participation rate exit criterion means that a school’s inability to assess six students in a test group of 100 will prevent that school’s release from the Priority designation. 133. On September 1, 2016, the Reform Office also announced another unilateral change to its exit criteria that is not authorized by statute or promulgated through the APA: “This -23-year, the SRO added another avenue for schools showing rapid turnaround, ranking above 15th percentile two straight years.” See http://www.michigan.gow/dumb/0,5552,7-150-9131_9352- 392526--,00.himl, This fourth “exit criterion” appears nowhere in the School Code, and Defendants have not explained how it was created or selected, 134, Furthermore, in a press release dated September 1, 2016, the Reform Office stated that the 2015 Bottom 5% List “is just one of the considerations reviewed by the SRO when making determinations about priority status and schools reviewed for a next level of accountability, but not the sole factor,” and “{hlistorical data as far back as 15 years also plays a large role in any decisions.” See http://www.michigan.gov/dimby 9352 392526-- 00.htm 135. The Reform Office, however, has not publicized any other considerations to be reviewed by the SRO when making determinations about Priority status. 136. Neither Section 1280¢ nor Act 192 authorizes the SRO or Reform Office to use secret criteria not released to the public, or to consider unidentified “historical data as far back as 15 years.” 137. Defendants’ selection of the “exit criteria” is wholly arbitrary and without explanation; yet they use these “exit criteria,” other secret considerations, and unidentified historical data to determine the fate of DPSCD schools and its students’ educations. The SRO"s ever-shifting definitions of “exit criteria” — unmoored from any statutory language ~ only reinforce the conclusion that the Legislature unconstitutionally delegated its own authority when it empowered the SRO to release schools which are “achieving satisfactory results.” 138, These “exit criteria” also have the force and effect of law and amount to a substantive “Rule” under the APA in that they may determine whether an SRO will release a and avoid school closure, However, the “exit school from the Priority School design: 24.were not promulgated in compliance with the rule-making processes required under the I. Recent Coercion to Enter into “Partnership Agreements” 139, On March 1, 2017, the State Superintendent threatened that the SRO would close DPSCD schools if the district does not enter in a “partnership agreement” with the MDE and SRO within 60 days. (Exhibit 17), No statutory or other authority exists granting either the MDE or the SRO power to force DPSCD to choose between entering into a “partnership agreement” or face school closures by the SRO. By hanging this unlawful threat of school closures over the heads of DPSCD schools, DPSCD is faced with a Hobson’s choice of involuntarily entering into a “partnership agreement” or suffering school closures. In short, the ‘partnership agreements” have not provided any meaningful relief to DPSCD. 140, Defendants have acted as though they have carte blanche to ignore statutory requirements and create secret rules for evaluating school performance. No state agency has inherent authority to do so. The rule of law, from which Defendants are not immune, must prevail. FOR DECLARATORY RELIEF — Vi ions of Section 1280c and Act 192 REQUES 141, Plaintiff hereby reaffirms and incorporates its previous allegations as if restated in full herein, 142. Section 1280 of the School Code requires the SRO to publish a Bottom 5% List “not later than September I of each year.” MCL 380.1280e(1) (emphasis added). 143. Defendants published no such list at all in 2015 to measure performance for the 2014-2015 school year because the SRO in 2015 simply republished the 2013 Bottom 5% List. -25-144, In addition, Defendants have violated Section 1280¢ of the School Code by failing to publish Bottom 5% Lists not later than September 1 of each year. 145. Defendants published a Bottom 5% List based upon 2014-2015 performance a year late, on September 1, 2016. 146, Defendants published a Bottom 5% List based upon 2015-2016 performance nearly five months late, on January 20, 2017. 147, ‘Therefore, there is no timely published Bottom 5% List covering the 2014-2015, or 2015-2016 academic years. 148, There exists an actual case in controversy between the parties in that they dispute, among other things, whether Defendants have violated Section 1280e(1) by failing to publish by September 1 of each of the last three years a Bottom 5% List based on testing for the prior school year. 149, Because Defendants have violated Section 1280¢(1), a condition precedent to the SRO closing DPSCD schools under Act 192 has not been satisfied and the SRO therefore has no authority to close DPSCD schools. 150, WHEREFORE, Plaintiff requests an Order from the Court declaring that: a, Defendants have violated Section 1280c(1) by failing to publish by September 1 of each of the last three years a Bottom 5% List for the prior school year. b. The SRO, therefore, does not have authority to close DPSCD schools under Act 192 based on the Bottom 5% Lists from 2014, 2015, and 2016, as determined under Section 1280c. 26-COUNT I REQUEST FOR DECLARATORY RELIEF ~ Act 192 Precludes Closure 151. Plainti hereby reaffirms and incorporates its previous allegations as if restated in full herein, 152. Act 192 states, in no uncertain terms, the SRO lacks the authority to close a DPSCD school until that school has been “operated by” DPSCD for at least three years, Specifically, “if a school operated by a community district is among the lowest achieving 5% of all public schools in this state for the immediately preceding 3 school years, as determined under section 1280c, the state school reform/redesign officer shall order the community district to close the school effective no later than the end of the current school year.” MCL 380.391(1). 153. Because the DPSCD is a brand new community school district and has operated schools since only July 1, 2016, there is no school operated by DPSCD among the lowest achieving 5% of all public schools for the immediately preceding 3 school years. 154, There exists an actual case in controversy between the parties in that they dispute, among other things, whether Defendants may close DPSCD schools under Act 192 where DPSCD has not operated schools among the lowest achieving 5% for the immediately preceding 3 school years. 155. WHEREFORE, Plain fF requests an Order from the Court declaring that: a DPSCD has not operated schools among the lowest achieving 5% of all public schools for the immediately preceding 3 school years because DPSCD only started operating schools in July 1, 2016; and b. That Defendants, therefore, do not have authority to close DPSCD schools under Act 192 until July 1, 2019 at the earliest. 27-COUNT REQUEST FOR DECLARATORY RELIEF — The Relevant Statutes Are An Unconstitutional Delegation of Legislative Authority 156, Plaintiff hereby reaffirms and incorporates its previous allegations as if restated in full herein. 157. Michigan's Constitution provides: “The powers of the government are divided into three branches: legislative, executive and judicial. No person exercising powers of one branch shall exercise powers properly belonging to another branch except as expressly provided in this constitution.” Const 1963, art 3, § 2. 158, Michigan’s Constitution also provides: “The legislative power of the State of Michigan is vested in a senate and a house of representatives.” Const 1963, art 4, § 1. 159. As agencies and officers within the Executive Branch of state government, Defendants have no inherent powers; rather, the only powers they have are those authorized by the Legislature. 160. Under principles of separation of powers and the non-delegation doctrine, the Legislature may not delegate its legislative responsibilities to a state agency or officer. This means, in part, that legislative standards must be as reasonably precise as the subject matter requires or permits 161. Section 1280c(1) of the School Code, in conjunction with EO 2015. , imposes on the SRO the responsibility to publish a list identifying the public schools “that the department has determined to be among the lowest achieving 5% of all public schools in the state.” MCL. 380.1280c(1). The Legislature failed to define “lowest achieving 5% of all public schools in the state,” failed to provide any standards or criteria by which the SRO is to make that -28-determination, and failed to authorize the SRO to promulgate rules to further define or implement Section 1280e(1). 162, Section 1280e(6) grants the SRO unlimited discretion to place schools in the Reform District, which carries with it the power to close public schools, if the SRO “determines that the redesign plan is not achieving satisfactory results.” MCL 380.1280¢(6). The Legislature failed to define “achieving satisfactory results,” failed to provide any standards or criteria by which the SRO is to make that determination, and failed to authorize the SRO to promulgate rules to further define or implement Section 1280c(6). 163. Act 192 grants the SRO unlimited discretion to decide not to close public schools if the SRO determines that it would cause an “unreasonable hardship to these pupils because there are insufficient other public school options reasonably available.” MCL 380.391(3). The Legislature failed to define “unreasonable hardship” or “insufficient other public school options: reasonably available,” failed to provide any standards or criteria within with the SRO is to make that determination, and failed to authorize the SRO to promulgate rules to further define or implement it. 164, Section 1280¢(7), in conjunction with EO 2015-9, grants the SRO unlimited discretion to appoint a CEO to take control of multiple public schools if the SRO “determines that better educational results are likely to be achieved.” MCL 380.1280c(7). The Legislature failed to define “better educational results are likely to be achieved,” failed to provide any standards or criteria by which the SRO is to make that determination, and failed to authorize the SRO to promulgate rules to further define or implement Section 1280c(7). The SRO has indicated she may appoint a CEO to take control over any school for which it determines closure ‘would create an “unreasonable hardship.” -29-165. The SRO, however, has herself stated that some of the schools she has identified for closure have been struggling “for 10 years, 12 years, 13 years, regardless of the management of the schools.” Higgins, Reform officer defending closings, Detroit Free Press (February 10, 2017), p Ad. The SRO's own statements thus indicate that management changes have not worked. 166. These powers delegated to the SRO are completely open-ended, leaving the SRO’s administration of those sections of the statute susceptible to arbitrary and capricious enforcement. 167, There exists an actual case in controversy between the parties in that they dispute, ‘among other things, whether Sections 12800(6)-(7) and Act 192 (MCL. 280.391(3)) constitute unconstitutional delegations of legislative authority. 168, WHEREFORE, Plaintiff requests an Order from the Court declaring that: a, Sections 1280c(6)-(7) of the School Code, MCL 380.1280c(6)-(7), constitute unconstitutional delegations of legislative authority: b. Sections 1280e(6)-(7) of the School Code, MCL 380.1280c(6)-(7), are, thus, unconstitutional and voids MCL. 380.391(3) constitutes an unconstitutional delegation of legislative authority; and 4. MCL 380.391(3) is, thus, unconstitutional and void. COUNT IV REQUEST FOR DECLARATORY RELIEF — Executive Order 2015-9 Is Unconstitutional 169. Plaintiff hereby reaffirms and incorporates its previous allegations as if restated in full herein. -30-snes. caren nt004 a0 StH 2 170. The Michigan Constitution mandates that “[IJeadership and general supervision over all public education” be “vested” in the SBE, and that the State Superintendent be charged with executing its policies and serving as principal executive of the MDE, Const. 1963, art 8, §3. 171. Consistent with these constitutional mandates, the Legislature vested certain powers under Section 1280c with the State Superintendent, including the obligation to publish annual Bottom 5% Lists. 172, EO 2015-9 stripped the State Superintendent of its powers, without justification, by transferring the Reform Office and the SRO out of the MDE into the DTMB, and therefore outside the purview of the SBE. 173. BO 2015-9 therefore violates the plain language of the Michigan Constitution 174, WHEREFORE, Plaintiff requests an Order from the Court declaring that: a. EO 2015-9" transfer of the Reform Office and the SRO out of the MDE and into the DTMB is unconstitutional; b. All actions the SRO has carried out or threatened to carry out by virtue of powers purportedly granted to it y EO 2015-9, including but not limited to identifying schools, for closure, appointing CEOs to take control of schools and placing schools in the Reform District, are void and invalid. cou REQUEST FOR DECLARATORY RELIEF ~ The Business Rules Violate the APA 175, Plaintiff hereby reaffirms and incorporates its previous allegations as if restated in full herein. I176. The SRO Bottom Five Business Rules were first made publicly available on September 1, 2016 ~ the same day that the 2015 Bottom 5% List it generated was published. 177, Thus, the criteria the SRO used to create the 2015 Bottom 5% List was kept secret from DPSCD and other school districts until the 2015 Bottom 5% List was announced, 178. Defendants are not authorized by the Legislature under either Section 1280c of the School Code or Act 192 to promulgate rules under the APA. 179, Nevertheless, the SRO created the 2015 Bottom 5% List based on the criteria and formula detailed in the SRO Bottom Five Business Rules. 180, ‘The SRO Bottom Five Business Rules have the force and effect of law, in that they, according to the SRO and the Reform Office, dictate which schools will appear on the 2015 Bottom 5% List. 181, The SRO Bottom Five Business Rules meet the definition of “Rule” under Section 7 of the APA, MCL 24.207. 182. Even if Defendants have statutory authority to promulgate rules to implement Section 1280c or Act 192, the SRO Bottom Five Business Rules were not promulgated in compliance with the notice and hearing rule-making requirements of Sections 41 and 42 of the APA, MCL 24.241 and MCL 24.242. 183. Therefore, the SRO Bottom Five Business Rules are invalid. 184, There exists an actual case in controversy between the parties in that they dispute, among other things, whether the SRO Bottom Five Business Rules utilized by the SRO to develop the 2015 Bottom 5% List are invalid because they are a “Rule” under Section 7 of the APA, MCL 24.207. Neither the SRO nor the DTMB followed the APA’s rule-making process before utilizing them as required under Section 43 of the APA, MCL 24.243. 32.185. To create the 2016 Bottom 5% List, the SRO may have relied on the MDE Top- to-Bottom Business Rules, which were first made publicly available on or around December 12, 2016, The SRO has not, however, publicly identified the business rules, if any, it relied on to create the 2016 Bottom 5% List, 186. The MDE Top-to-Bottom Business Rules were not designed to serve as a basis for creating the SRO’s Bottom 5% List. 187. The MDE Top-to-Bottom Business Rules have the force and effect of law, in that they, according the SRO and Reform Office, dictate which schools will appear on the 2016 Bottom 5% 188. The MDE Top-to-Bottom Business Rules, as applied by the SRO to create its Bottom 5% List, meet the definition of “Rule” under Section 7 of the APA, MCL 24.207. 189. Any other criteria the SRO used to identify schools for closure meet the definition of “Rule” under Section 7 of the APA, MCL 24.207. 190. Even if Defendants have statutory authority to promulgate rules to implement Section 1280c or Act 192, the SRO did not adopt or otherwise promulgate the MDE Top-to- Bottom Business Rules in compliance with the notice and hearing rule-making requirements in Sections 41 and 42 of the APA. MCL 24.241 and MCL 24,242, 191, The MDE itself did not promulgate the MDE Top-to-Bottom Business Rules in compliance with the notice and hearing rule-making requirements in Sections 41 and 42 of the APA. MCL 24.241 and MCL 24.242, 192, Therefore, the SRO’s adoption of the MDE’s Top-to-Bottom Business Rules to develop the 2016 Bottom 5% List violated the APA. 193. Properly promulgated business rules are a condition precedent to closing schools under Act 192. -33-194. There exists an actual case in controversy between the parties in that they dispute, among other things, whether the MDE Top-to-Bottom Business Rules utilized by the SRO to develop the 2016 Bottom 5% List are invalid because they are a “Rule” under Section 7 of the APA, MCL 24,207, Neither the SRO nor the DTMB followed the APA’s rule-making process before utilizing them as required under Section 43 of the APA, MCL 24.243, 195. WHEREFORE, Plaintiff requests an Order from the Court dectaring that: a, The SRO Bottom Five Business Rules amount to a “Rule” under Section 7 of the APA, MCL 24.207; b. The SRO Bottom Five Business Rules used by the SRO to ereate the 2015 Bottom 5% List are void and invalid because they were not promulgated under the rule-making processes required by the APA. €. The MDE Top-to-Bottom Business Rules, as applied by the SRO to create its Bottom 5% List, amount to a “Rule” under Section 7 of the APA, MCL 24.207; 4. ‘The MDE Top-to-Bottom Business Rules used by the SRO to create the 2016 Bottom 5% List are void and invalid because they were not promulgated under the rule- making processes required by the APA. COUNT VI REQUEST FOR DECLARATORY RELIEF ~ The Exit Criteria Violate the AP. 196, Plaintiff hereby reaffirms and incorporates its previous allegations as if restated in full herein, 197. Defendants are not authorized by the Legislature under either Section 1280c of the School Code or Act 192 to promulgate rules under the APA. 198, Nevertheless, on September 1, 2016, the Reform Office also announced the “exit criteria” that it would use to release schools from the Priority School designation, which included 3d.a new criterion: “ranking above 15th percentile two straight years and meeting the other requirements.” 199. On September 1, 2016, the Reform Office also announced that other considerations not publicized will be considered in determining Priority status and the next level of accountability, including unidentified “historical data as far back as 15 years.” ia” and the other, secret considerations have the force and effeet of law in that they dictate the fate of whether DPSCD schools are subject to closure. 201. The “exit criteria” and the other, seeret considerations meet the ds “Rule” under Section 7 of the APA, MCL 24.207. 202. Even if Defendants have statutory authority to promulgate rules to implement Section 1280e or Act 192, neither the “exit criteria” nor the other considerations were promulgated in compliance with the notice and hearing rule-making requirements in Section 41 and 42 of the APA. MCL. 24.241 and MCL 24.242. 203. Therefore, the “exit criteria” and other considerations are invalid. 204. There exists an actual case in controversy between the parties in that they dispute, among other things, whether the “exit criteria” and other considerations are invalid because they are a “Rule” under Section 7 of the APA, MCL 24.207; however, neither the SRO nor the -d under Section DTMB followed the APA’s rule-making process before utilizing them as requ 43 of the APA, MCL 24.243. 208. WHEREFORE, Plaintiff requests an Order from the Court declaring that a. The “exit criteria” and other considerations to be used by the SRO to determine Priority School status and potential release therefrom, including unidentified “historical data” from the last 15 years, amount to a “Rule” under Section 7 of the APA, MCL 24.207; -35-it criteria” and these other considerations are void and invalid because they were not promulgated under the rule-making processes required by the APA. COUNT VII REQUEST FOR PRELIMINARY AND PERMANENT INJUNCTIVE RELIEF 206. Plaintiff hereby reaftirms and incorporates its previous allegations as if restated in full herein, 207. Plaintiff has no adequate remedy at law. 208. A preliminary and permanent injunction would be in the public’s interest because the public — including, most importantly, DPSCD students ~ has an interest in maintaining the status quo and stability within DPSCD and its schools, and in ensuring that Defendants are following state law. 209. Plaintiff and the 45,000 students it educates face a real and imminent danger of irreparable harm if an injunetion is not issued enjoining Defendants from closing DPSCD schools, otherwise placing DPSCD schools into the Reform Dis , oF appointing a CEO to take control of DPSCD schools. Specifically: a. Studies have shown that stability is vital to academic success, but most current DPSCD students have already switched schools at least once for non-promotional reasons. Forcing DPSCD students to change schools once more will only aggravate the negative consequenees of instability many are already experiencing, b. The percentage of students who have experienced such forced transfers is especially high in the schools the SRO has slated for closure. c. Consistent with national studies linking educational instability with poor academic performance and absenteeism, Detroit students perform worse than their peers on academic measures and have higher rates of absenteeism, -36-d. There are very few high-quality educational institutions with available seats in the near vicinity of most of the DPSCD schools the SRO slated for closure. Only 20 schools in Detroit are ranked at or above the 25" percentile of schools in the State, and most of those are already at eapacity. €. High-quality schools are predominantly located at great distances away from Detroit and are inaccessible by public transportation. £ Between 20% and 40% of households in most Detroit neighborhoods that will be affected by school closures lack any access to an automobile, making it :possible for those families to drive long distances every day to take children to school. The affected neighborhoods also have extremely high levels of families living in poverty, making it highly likely that many parents would be unable to drive their children 25, 50 or 100 miles to and from school every day, both because of the costs of gasoline and car maintenance, and because many such parents do not have flexible work, schedules. 210. There is no likely harm to Defendants if a preliminary or permanent injunetion were to issue, in that Plaintiff is simply asking Defendants to comply with the law and maintain the status quo. 211. A preliminary and permanent injunction in this matter is necessary to stop the Defendants’ action, which the Court should declare unlawful and void 212. WHEREFORE, Plaintiff requests: a. Asspeedy hearing and advancement of this matter on the Court's calendar under MCR 2.605(D). 37-b. Orders preliminarily and permanently enjoining Defendants from closing DPSCD schools under Act 192 based, in whole or in part, on the invalid 2014, 2015, 2016 Bottom 5% Lists, as Defendants have threatened; c. Orders preliminarily and permanently enjoining Defendants’ use of the ‘SRO Bottom Five Business Rules, the “exit criteria,” or other considerations and criteria that have not been properly promulgated under the APA; 4. Orders preliminarily and permanently enjoining Defendants from closing DPSCD schools under Act 192 and Section 1280c of the School Code: e. Orders preliminarily and permanently enjoining Defendants from transferring DPSCD schools to the Reform District or appointing a CEO to take control of DPSCD schools under Section 1280¢ of the Schoo! Code; ‘An award to Plaintiff of reasonable attorneys’ fees and costs incurred; and . An Order granting Plaintiff other relief that this Court deems equitable and just under the circumstances presented. Respectfully submitted, Terome R. Watson (P27082) Scott R. Eldridge (P6452) MILLER, CANFIELD, PADDOCK. AND STONE, P.L.C. Counsel for Plaintiff Detroit Public Schools Community Distriet 150 West Jefferson, Suite 2500 Detroit, MI 48226 (313) 963-6420 watson @millercanfield.com Dated: March 17, 2017 -38-VERIFICATION STATE OF MICHIGAN) dss. COUNTY OF WAYN! Alycia Meriweather, being first duly sworn, states: 1, She is the Interim Superintendent of the Detroit Public Schools Community District and is authorized to verify this formal complaint; and She has read the foregoing complaint and the averments contained therein are true and correct to the best of her information, knowledge, and bel Interim Superintendent Detroit Public Schools Community District Subscribed and sworn to before me, a Notary Public in and for said County, this | T"Xiay of Mesa g 2017, i ~ A. 4h Ved de De Ae ~ Notary Public Wayne County, Michigan My Commission expires: €f - 6-9 oi Acting in \wlssse_.. County, Michigan 27726590 1:152498-00006 MY COMSSION EXPIRES A 16,208 ACTING COUNTY OFEXHIBIT 1‘THE REVISED SCHOOL CODE (EXCERPT) ‘Act 451 0f 1976 380.1280c Identification of lowest achieving 5% of public schools; list; placement under ‘supervision of reformiredesign officer; submission of redesign plan; implementation; creation of state school reformiredesign school district; appointment of chief executive officer to control multiple schools; implementation of restart, turnaround, or transformation models; release of public school from measures imposed by subsection (6) or (7); report; posting of certain information; issuance of order placing school under supervision of state school reformiredesign officer; prohibition. ‘See, 1280¢. (1) Beginning in 2010, not later than September | of each year, the superintendent of public instruction shall publish a list identifying the public schools in this state that the department has determined t0 be among the lowest achieving 5% of all public schools in this state, as defined for the purposes ofthe federal incentive grant program ereated under sections 14005 and 14006 of title XIV of the American recovery and reinvestment act of 2009, Public Law 111-5 10) Except as otherwise provided in subsection (16), the superintendent of public instruction shall issue an order placing each public school that is included on the list under subseetion (1) under the supervision of the State school reform/redesign officer described in subsection (9). Within 90 days after a public school is placed tinder the supervision ofthe state school reformiredesign officer under this section, the school board or board Of directors operating the public school shall submit a redesign plan to the state school reform/redesign bfficer. For a public school operated by a school board, the redesign plan shall be developed with input from {he local teacher bargaining unit and the local superintendent. The redesign plan shall require implementation OF L ofthe 4 school intervention models that are provided for the lowest achieving schools under the federal incentive grant program created under Sections 14005 and 14006 of title XIV of the American recovery and feinvestment act of 2009, Public Law 111-5, known as the "race to the top" grant program. These models are the tumaround model, restart model, school closure, and transformation model, ‘The redesign plan shall include an executed addendum to each applicable collective bargaining agreement in effect for the public school that meets the requirements of subsection (8). 1G) Within 30 days after receipt ofa redesign plan for a public school under subsection (2), the state school reformiredesign officer shal issue an order approving, disapproving, oF making changes tothe redesign plan Ifthe order makes changes to the redesign plan, the school board or board of directors has 30 days after the fder to change the redesign plan to incorporate those changes info the redesign plan and resubmit it to the State school reform/redesign officer for approval or disapproval {4 The state school reformiredesign officer shall not disapprove a redesign plan that includes all of the ‘elements required under federal law for the school infervention mode! included in the redesign plan. A school board or board of directors may appeal disapproval of a redesign plan on this basis to the superintendent of public instruction. The decision ofthe superintendent of public instruction on the appeal is final 13) Ifthe state school reform/redesign officer approves a redesign plan under this section, the school board cor board of directors shall implement the redesign plan for the public school beginning with the beginning of fhe next school year that begins after the approval. The school board or board of directors shall regularly Submit monitoring reports to the state school reformiredesign officer on the implementation and results of the plan in the form and manner, and according to a schedule, as determined by the state school reform/redesign officer. M6) The state school reformiredesign school district is created. The state school refom/tedesign school district isa school district for the purposes of section 11 of article IX of the state constitution of 1963 and for feceiving site school aid under the state school aid act of 1979 and is subject to the leadership and general supervision of the state board over all public education under section 3 of article VIII ofthe state constitution Sf'1963. The state school reform/redesign school district is a body corporate and is a governmental agency’ Except as otherwise provided in subsection (7), if the state school reform/redesign officer does not approve the redesign plan, of if the state school reformitedesign officer determines that the redesign plan is not achieving satefactory results, the state school reform/tedesign officer shall issue an order placing the public School in the state school reform/redesign school district, imposing for the public schoo! implementation of 1 ‘Sf the 4 school intervention models described in subsection (2) beginning with the beginning of the next School year, and imposing an addendum to each applicable collective bargaining agreement in effect for the public school as necessary 10 implement the school intervention model and that meets the requirements of Subsection (8). All ofthe following apply tothe state school reformiredesign schoo! district: ‘a The state school reformitedesign school district shall consist of schools that are placed in the state Rendered Fay, Febrany 17.2017 page 1 Michigan Corte Laws Compl Though PAA? of 2016 © Lagistative Council, State of Michigan Courtesy of www-legisiature.mi govschoo! reform/redesign school district, (b) The state school reform/redesign officer shall act as the superintendent of the state school reformiredesign school district. With respect 10 schools placed in the state school reform/redesign school distrit, the state school reform/redesign officer has all of the powers and duties described in this section; all of the provisions ofthis act that would otherwise apply to the school board that previously operated a school placed in the state school reform/redesign school district apply to the state school reform/redesign officer with Fespeet to that school, except those relating to taxation of borrowing: except as otherwise provided in this section, the state school reform/edesign officer may exercise all the powers and duties otherwise vested by law in the school board that previously operated a school placed in the state school reform/tedesign school district and in its officers, except those relating to taxation or borrowing, and may exercise all additional Powers and duties provided under this section; and, except as atherwise provided in this section, the state School reform/redesign officer accedes to all the rights, duties, and obligations of the school board with respect to that school. These powers, rights, duties, and obligations include, but are not limited to, all of the following {@) Authority over the expenditure of all funds atributable to pupils at that school, including that portion of proceeds from bonded indebtedness and other funds dedicated to capital projects that would otherwise be ‘apportioned to that schoo! by the schoo! board that previously operated the school according to the terms of the bond issue or financing documents. (Gi) Subject 10 subsection (8), rights and obligations under collective bargaining agreements and ‘employment contracts entered into by the school board for employees atthe school {iti) Rights to prosecute and defend litigation, (iv) Rights and obligations under statute, rule, and common lew, (¥) Authority to delegate any of the state school reform/tedesign officers powers and duties to 1 or more Uesignees, with proper supervision by the state school reformiredesign officer (0) Power to terminate any contractor portion of contract entered into by the school board that applies to that school. However, this subsection does not allow any termination or diminishment of obligations to pay debt service on legally authorized bonds and does not allow a collective bargaining agreement to be affected except as provided under subsection (8). A contract terminated by the state school reformiredesign officer under this subsection is void (7) Ifthe state schoo! refonm/tedesign officer determines that better educational results are likely 10 be achieved by appointing a chief executive officer to take control of multiple public schools, the state school reformiredesign officer may make a recommendation to the superintendent of public instruction for appointment of a chief executive offer to take control over those multiple schools, If the superintendent of public instruction appoints a chief executive officer to take control of multiple public schools under this Subsection, the chief executive officer shall impose for those public schools implementation of | of the 4 school intervention models deseribed in subsection (2) and impose an addendum to each applicable collective bargaining agreement in effect for those public schools as necessary to implement the school intervention ‘model and that meets the requirements of subsection (8). With respect to those public schools, the chiet executive officer has all of the same powers and duties thatthe state school reform/tedesign officer has for Public schools placed in the state school reform/redesign school district under subsection (6). The chief «executive officer shall regularly submit monitoring reports to the state school reform/redesign officer on the implementation and results of the intervention model in the form and manner, and according to a schedule, as determined by the state school reform/tedesign officer. The chief executive officer shall exercise any other powers or duties over the public schools as may be directed by the superintendent of public instruction (8) ‘An addendum to a collective bargaining agreement under this section shall provide for any of the following that are necessary for the applicable school intervention model to be implemented at each affected public schoo: {a) That any contractual or other seniority system that would otherwise be applicable shall not apply at the public school. This subdivision does not allow unilateral changes in pay seales or benefits (b) That any contractual or other work rules that are impediments to implementing the redesign plan shall not apply at the public school. This subdivision does not allow unilateral changes in pay scales or benefits. (c) That the state school reformiredesign officer shall direct the expenditure of all funds attributable to pupils at the public school and the principal or other school leader designated by the state school reform/redesign officer shall have full autonomy and control over curriculum and discretionary spending at the publie school (9) The superintendent of public instruction shal hire a state school refomitedesign officer to carry out the functions under this section and as otherwise prescribed by law. The state school reform/redesign officer shal be chosen solely on the basis of his or her competence and experience in educational reform and redesign, Rendered Fay, Febery 17,2017 Page 2 Madigan Complad Laws Compa Trough PA 71 of 2015 © Legislative Council, State of Michigan Courtesy of wow legisiature.migov‘The state school reformiredesign officer is exemps from civil service The state school reformitedesign officer is responsible directly tothe superintendent of public instruction to ensure that the purposes ofthis section are carried out, and accordingly the postion of state school reformvredesign officer should be a postion within the department that i exempt from the classified state civil service. The department shall request thatthe evil service commission establish the postion of state school reformitedesign officer asa position that is exempt from the classified state civil service (10) IF the state school reformiredesign officer imposes the restart model fora public school in the state school reformredesign schoo! district, ora chief executive officer under subsection (7) imposes the restart model for multiple public schools unde that subsection all ofthe following apply (a) The state school reform/redesign officer or chief executive officer shall enter into an agreement with an educational management organization to manage and operate the public school or schools. The state schoo! reformitedesign officer of chief executive officer shall provide sufficient aversight co ensure that the public school or schools wil be operated according to all ofthe requirements fora restart mod () There shall be considered to be no collective bargaining agreement in effect that applies to employees ‘working at the publie school or schools under this model at the time oF imposition ofthe model. (11) I the state school reformiredesign officer imposes the tumaround model fora public school in the stale school reform/tedesign school district, or a chief executive officer under subseoton (7) imposes the {umaround model for multiple public schools under that subsection, all of the following apply (a) A collective bargaining agreement that applies 10 employees Working atthe public school or schools unde this model atthe time of imposition of the model, and any successor collective bargaining agreement, continues to apply with respect pay scales and benefits. (b) Subject to any addendum tothe collective bargaining agreement that applies to the public school or schools, an employee who is working at the public school or schools and who was previously employed in the same school ditt that previously operated that schoo! shall continue to retain and acerue seniority right in that school distriet aecording to the collective bargaining agreement that applies to employees of that school district, (12) If more than 9 public sthools operated by a sehoo! district are onthe list under subsetion (1), the teansformation model may not be implemented for more than 50% of those schools (13) Ifthe state school reforn/tedesizn officer determines that a public school that is subject to the measures under subsection (6) oF (7) has made significant improvement in pupil achievement and should be released from the measures that have been imposed under subsection (6) or (7), the state school reformvredesign officer may recommend this to the superintendent of public instruction. If the superintendent (of public instrution agrees with the determination and recommendation, the superintendent of public instruction may release the public school from the measures that have been imposed under subsection (6) or 0), (14) At leat annually, the state school reformiredesign officer shall submit a report to the standing committees of the senate and house of representatives having jurisdiction ever education lexslation on the progress being made in improving pupil proficiency due to the measures under this section. (5) As soon a practicable after the federal department of education has adopted the final work rues and formula for identijing the lowest achieving 5% of all publi schools in this state forthe purposes of the federal incentive grant programm created under sections 14005 and 14006 of title XIV of the American recovery and reinvestment act of 2009, Public Law 111-5, known asthe "race to the top" grant program, the department shall post al of the following on its website: (a) The federal work rules and formula, {b) A list ofthe public schools inthis state that have been identified for these purposes as being among the lowest achieving 5% ofall public schools in this state. The department shall update this ist as it considers appropriate (16) Ifa school that i included on the list under subscetion (1) is operated by a school district in which an ‘emergency manager is in place under the local government and school district fiscal accountability act, then the superintendent of public instruction shall not issue an order placing the school under the supervision ofthe state school reformitedesign officer. History: A200, At 206, EM fn 4, 2010-—Am 201, Ae AFM. 6, 2001 Poplar ame: A451 Renee Fiay, Fabra 17,2017 Pege3—ehigan Compe Laws Complete Thauph PAA of 2018 © Legislative Council, State of Michigan Courtesy of ww legislature.mi.govEXHIBIT 2State oF Micmaan AICK SNYDER EXECUTIVE OFFICE BRIAN CALLEY EXECUTIVE ORDER No. 2015-9 CREATION OF THE STATE SCHOOL REFORM/REDESIGN SCHOOL OFFICE DEPARTMENT OF EDUCATION DEPARTMENT OF TECHNOLOGY, MANAGEMENT, AND BUDGET EXECUTIVE REORGANIZATION WHEREAS, Section 1 of Article V of the Michigan Constitution of 1963 vests the ‘executive power of the state of Michigan in the Governor; and WHEREAS, Section 2 of Article V of the Michigan Constitution of 1963, ‘empowers the Governor to make changes in the organization of the Executive Branch or in the assignment of functions among its units that he considers necessary for efficient administration; and WHEREAS, Section 8 of Article V of the Michigan Constitution of 1963 provides that each principal department shall be under the supervision of the Governor unless otherwise provided by the Constitution; and WHEREAS, Section ¢ of Article Vill of the Michigan Constitution of 1963, provides in part that schools and the means of education shall forever be encouraged; and WHEREAS, Section 2 of Article VIII of the Michigan Constitution of 1963 provides in part that the legislature shall maintain and support a system of free public elementary and secondary schools as defined by law; and WHEREAS, Section 3 of Article VIII of the Michigan Constitution of 1963 vests leadership and general supervision over all public education, including adult education and instructional programs in state institutions, except as to institutions of higher education granting baccalaureate degrees, in the State Board of Education; and WHEREAS, there is a continued need to reorganize functions among state departments to ensure efficient administration; and GEOHGE W. ROMNEY BUILOING + 111 SOUTH CAPITOL AVENUE * LANSING, MICHIGAN 46900 ‘wuneichigan.govWHEREAS, the economic success of our state is dependent on having an educated and skillad citizenry that begins with every student having a quality education that prepares them for career and college readiness and success; and WHEREAS, the State School Reform/Redesign Officer and State School Reform/Redesign School District were created to advance dramatic improvement in Michigan's lowest achieving public schools, as defined under state law; and WHEREAS, by September ‘st of each year, the Superintendent of Public Instruction is required to publish a list identifying the public schools in this state that the Michigan Department of Education has determined to be among the lowest achieving 5% of all public schools in this state, as defined under state law; and WHEREAS, except public schools under the supervision of an emergency manager, the Superintendent of Public Instruction is required to issue an order placing each public school included on the list under the supervision of the State School Reform/Redesign Officer, and the governing board of each identified public school is required to submit a redesign plan to the State School Reform/Redesign Officer implementing a school intervention model, as defined under state law; and WHEREAS, if the State School Reform/Redesign Officer does not approve the redesign plan or determines that the redesign plan is not achieving satisfactory results, the State School Reform/Redesign Officer shall issue an order placing the public school in the State School Reform/Redesign School District, imposing for the public school implementation of a schoo! intervention model, as defined under state law; and WHEREAS, since the oreation of the State School Reform Officer in 2010, the State School Reform/Redesign Officer has approved redesign plans for 212 public schools; and WHEREAS, 54 public schools have operated under a redesign plan for more than 3 years; and WHEREAS, despite not achieving satisfactory outcomes, the current structure has neither implemented the rigorous supports and processes needed to create positive academic outcomes nor placed any of the identified low achieving schools in the State School Reform/Redesign School District; and WHEREAS, many schools continue to perform at levels that hamper the ability of students to receive an education that prepares them for career and college readiness and success; andWHEREAS, the state’s lowest performing schools are in the greatest need of rigorous support structures and interventions in order to prevent further academic decline; and WHEREAS, there is an immediate need to bring together the necessary school improvement resources within this state and utilize all the necessary school improvement models and strategies available for schools, to ensure that all students aro given the opportunity to success in the classroom; NOW, THEREFORE, |, Richard D, Snyder, Governor of the state of Michigan, by Virlue of the powers and authority vested in the Governor by the Michigan Constitution of 1963 and Michigan law, order the following I DEFINITIONS: As used in this Order: A. “Department of Education” means the principal department of state government created under Section 300 of the Executive Organization Act of 1965, 1965 PA 380, MCL 16.400. B. "Department of Technology, Management, and Budget" or "Department" means the principal department of state government created by Section 124 of The Management and Budget Act, 1984 PA 431, MCL 18.1121, and renamed the Department of Technology, Management, and Budget under Executive Order 2009-55, MCL 18.441, C. “State” means the state of Michigan. D, “State Board of Education” means the board created under Section 3, Article VIII, of the Michigan Constitution of 1963. E, “State Budget Director” means the individual appointed by the Governor pursuant to Section 321 of The Management and Budget Act, 1984 PA 431, MCL. 18.1921, and Executive Order 2009-55, MCL 18.441. F. “State Budget Office” or “Office” means the office created under Section 321 of The Management and Budget Act, 1984 PA 431, MCL 18.1321 G. "State School Reform/Redesign School District’ or “District” means the school district created under Section 1280c(6) of the Revised School Code, 1976 PA 451, MCL 380.1280c. H. "State School Reform/Redesign Office” means the office created within the Department of Technology, Management, and Budget under Section II of this Order. 3| "State Schoo! Reform/Redesign Officer” or “Officer” means the officer described in Section 1280c(9) of the Revised School Code, 1976 PA 451, MCL 380.1280¢, and authorized to act as the superintendent of the State School Reform/Redesign District under Section 1280c(6)(b) of the Revised School Code, 1976 PA 481, MCL 380.1280c, J. “Superintendent of Public Instruction” means the principal executive officer of the Department of Education required under Section 3, Article VIII, of the Michigan Constitution of 1963, Il, CREATION OF STATE SCHOOL REFORMIREDESIGN OFFICE A. The State School Reform/Redesign Office is created as an autonomous entity within the Department of Technology, Management, and Budget. B. The Office shall exercise its statutory powers, duties, and functions, including but not limited to rule-making, licensing, and registration, including any prescription of rules, rates, regulations, and standards, and adjudication independently of the Director of the Department. All budgeting, procurement, and related management functions of the Office shall be performed under the direction and supetvision of the Director of the Department. C. The Director of the Department shall be the appointing authority for employees of the Office. Ill, STATE SCHOOL REFORM/REDESIGN SCHOOL DISTRICT AND STATE SCHOOL REFORM/REDESIGN OFFICER A. The State School Reform/Redesign School District is transferred from the Department of Education to the State School Reform/Redesign Office. B. The State School Reform/Redesign Officer is transferred from the Department of Education to the State School Reform/Redesign Office. The Officer shall be the head of the Office and shall carry out the functions vested in the Officer in this Order and as otherwise prescribed by law, including, but not limited to, acting as the superintendent of the State School Reform/Redesign District and performing functions and responsibilities vested in the State School Reform/Redesign Officer under Section 16(5) of 1947 PA 336, MCL 423.215. The authority to hire the Officer is transferred from the Superintendent of Public Instruction to the Direotor of the Department of Technology, Management, and Budget, who shall be the appointing authority for the Officer. The Officer shall be chosen solely on the basis of his or her competence and experience in educational reform and redesign. The Officer shall be exempt from and not within the classified state civil service. The Department of Technology,Management, and Budget shall request the Civil Service Commission to establish the Officer's position as an exempt position of a policy-making nature within the Department. C. —_Allauthority, powers, duties, functions, and responsibilities of the Department of Education under Section 1280c of the Revised School Code, 1976 PA 451, MCL 380.1280c, are transferred to the State School Reform/Redesign Office, including, but not limited to, all of the following authority, powers, duties, functions, and responsibilities: 1. Determining under Section 1280¢(1) of the Revised School Code, 1976 PA 451, MCL 380.1280c(1), which public schools in this state are among the lowest achieving 5% of all public schools in this state, as defined for the purposes of the federal incentive grant program created under sections 14005 and 14006 of title XIV of the American Recovery and Reinvestment Act of 2009, Public Law 111-6. 2. Posting on a website the federal work rules and formula for identifying the lowest achieving 5% of all public schools in this state for the purposes of the federal incentive grant program created under sections 14005 and 14006 of ttle XIV of the American Recovery and Reinvestment Act of 2009, Public Law 111-5, known as the “race to the top” grant program and a list of public schools in this state that have been identified for these purposes as being among the lowest achieving 5% of all public schools in this state, and updating the list as considered appropriate under Section 1280¢(15) of the Revised Schoo! Code, 1976 PA 451, MCL 380.1280c. 3. Except as prohibited by federal law, administration of any federal waivers granted by the United States Department of Education relating to the authority, powers, duties, functions, and responsibilities of the Department of Education, relating to the District, or the Officer under Section 1280c of the Revised School Code, 1976 PA 451, MCL 380.1280c. D. Except as provided in Section IILE, all authority, powers, duties, functions, and responsibilities of the Superintendent of Public Instruction under Section 1280c of the Revised School Code, 1976 PA 451, MCL 380.1280c, and Section 15(6) of 1947 PA 336, MCL 423.215, are transfered to the State School Reform/Redesign Office, inoluding, but not limited fo, all of the following authority, powers, duties functions, and responsibilities: 1. Publication of a list identifying the public schools in this state that are determined to be among the lowest achieving 5% of all public schools in this state, as defined for the purposes of the federal incentive grant program created 5under sections 14005 and 14006 of title XIV of the American Recovery and Reinvestment Act of 2009, Public Law 111-5, under Section 12800(1) of the Revised School Code, 1976 PA 451, MCL 380.1280c. 2. Issuance of orders placing each school that is included on the list under Section 12800(1) of the Revised School Code, 1976 PA 451, MCL 380.1280c, under the supervision of the State School Reform/Redesign Officer. 3. Appointing a chief executive officer to take control over multiple public schools and directing the chief executive officer to exercise other powers or duties over the public schools under Section 1280c(7) of the Revised School Code, 1976 PA 451, MCL 380.1280c, and powers or duties under Section 15(5) of 1947 PA 336, MCL 423.215. 4, Releasing a public school from measures imposed under Section 1280¢(6) or 1280¢(7) of the Revised School Code, 1976 PA 451, MCL 380.1280c, under section 1280c(13) of the Revised School Code, 1976 PA 451, MCL 380.1280c. 5. Except as prohibited by federal law, administration of any federal waivers granted by the United States Department of Education relating to the authority, powers, duties, functions, and responsibilities of the Superintendent of Public Instruction relating to the District or the Officer under Section 1280c of the Revised School Code, 1976 PA 451, MCL 380.1280c. E. The Superintendent of Public instruction shall retain the authority, powers, duties, functions, and responsibilities to hear and decide appeals from a school board or a board of directors under Section 1280c(4) of the Revised School Code, 1976 PA 451, MCL 380.1280c. F. _Allof the following authority, powers, duties, functions, and responsibilities of the Superintendent of Public Instruction are transferred to the State School Reform/Redesign Office: 4, Determining that a public school academy that has been operating for at least 4 years is among the lowest achieving 5% of all public schools in this state, as defined for the purposes of the federal incentive grant program created under sections 14005 and 14006 of title XIV of the American Recovery and Reinvestment Act of 2009, Public Law 111-6, is in year 2 of restructuring sanctions under the No Child Left Behind Act of 2001, Public Law 107-110, not to include the individualized education plan subgroup, and is not currently undergoing reconstitution under Section 507 of the Revised School Code, 1976 PA 451, MCL 380.507, and notifying the public school academy's authorizing 6body under Section 507(6) of the Revised School Code, 1976 PA 451, MCL. 380.507, of that determination. 2. Determining that an urban high school academy that has been operating for at least 4 years is among the lowest achieving 6% of all public schools in this state, as defined for the purposes of the federal incentive grant program created under sections 14005 and 14006 of title XIV of the American Recovery and Reinvestment Act of 2009, Public Law 111-5, is in year 2 of restructuring sanctions under the No Child Left Behind Act of 2001, Public Law 107-110, not to include the individualized education plan subgroup, and is not currently undergoing reconstitution under Section 528 of the Revised School Code, 1976 PA 451, MCL 360.528, and notifying the urban high school academy's authorizing body under Section 528(5) of the Revised School Code, 1976 PA 451, MCL 380.528, of that determination. 3. Determining that a school of excellence serving a special student Population that has been operating for at least 4 years is among the lowest achieving 5% of all public schools in this state, as defined for the purposes of the federal incentive grant program created under sections 14005 and 14006 of title XIV of the American Recovery and Reinvestment Act of 2009, Public Law 111-5, is in year 2 of restructuring sanctions under the No Child Left Behind Act of 2001, Public Law 107-110, not to include the individualized education plan subgroup, and is not currently undergoing reconstitution under Section 561 of the Revised School Code, 1976 PA 451, MCL 380.561, and notifying the school of excellence's authorizing body under Section 561 of the Revised School Code, 1976 PA 451, MCL 380.561, of that determination IV. IMPLEMENTATION A. Nothing in this Order should be construed to diminish the role of the State Board of Education under Section 3 of Article VIII of the State Constitution of 1963 in providing leadership and general supervision over all public education, including adult education and instructional programs in state institutions, except as to institutions of higher education granting baccalaureate degrees, to serve as the general planning and coordinating body for all public education, including higher education, or to advise the Legislature as to the financial requirements in connection therewith. B. _Allrecords, personnel, property, unexpended balances of appropriations, allocations, or other funds used, held, employed, available, or to be made available to the State School Reform/Redesign Schoo! Office for the authority, powers, duties, functions, and responsibilities transferred under this Order are transferred to Office.C. The State School Reform/Redesign Officer shall administer functions and responsibilities assigned under this Order in such a way as to promote efficient administration, The Director of the Department of Technology, Management, and Budget and the State School Reform/Redesign Officer shall make internal organizational changes as may be administratively necessary to complete the realignment of functions and responsibilities by this Order pursuant to MCL 16.107. D. The Director of the Department of Technology, Management, and Budget shall provide executive direction and supervision for the Implementation of the transfers under this Order E. The Director of the Department of Technology, Management, and Budget and the Superintendent of Public Instruction shall immediately initiate coordination to facilitate the transfers under this Order and shall develop a memorandum of record identifying any pending settlements, issues of compliance with applicable federal and state laws and regulations, or other obligations to be resolved by the Department of Education. F. The State Budget Director shall determine and authorize the most efficient manner possible for the handling of financial transactions and records in the state's financial management system for the remainder of the current state fiscal year for transfers made under this Order. G. _ Allrules, orders, contracts, plans, and agreements relating to the functions and responsibilities transferred by this Order lawfully adopted prior to the effective date of this Order shall continue to be effective until revised, amended, or rescinded H. Any suit, action, or other proceeding lawfully commenced by, against, or before any entity transferred by this Order shall not abate by reason of the taking effect of this Order. Any lawfully commenced suit, action, or other proceeding may be maintained by, against, or before the appropriate successor of any entity affected by this Order.In fulfillment of the requirements of Section 2 of Article V of the Michigan Constitution of 1983, this Order shall be effective on 60 days after the filing of this Order. Given under my hand and the Great Seal of the state of Michigan this_ JQ... day of March, in the Year of our Lord Two Thousand Fifteen. 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DEPARTMENT OF TECHNOLOGY, MANAGEMENT & BUDGET ——pavioB. BE HEN oven Taxsin pees REVISED" September 23, 2016 Mrs. Alycia Meriweather, Superintendent Detroit Public Schools Community District 3011 West Grand Bivd Detroit, Ml 48202 Dear Mrs. Meriweather: As required by state statute, MCL. 380.1280c, Section 1, a list identifying the public schools in the state that are among the lowest achieving five percent ofall public schools must be published by September 1 of each year. The schools in your district listed below are naw to the Priority School list or have retained Priority Schoo! status. By order of the State School Reform/Redesign Officer these schools are under the supervision of the State School Reform Office (SRO) effective Thursday, September 1, 2016. 41. Academy of The Americas, 2015 Priority; 2.Bagley Elementary School, 2015 Priority; 3.Blackwell Institute, 2015 Priority; 44. Cody Academy Of Public Leadership, 2015 Priority; 5. Cooke Elementary School, 2015 Priority; 6. Detroit international Academy For Young Women, 2016 Priority; 7.Dixon Elementary School, 2015 Priority; 8. Dossin Elementary-Middle School, 2015 Priority; 9.East English Village Proparatory Academy, 2015 Priori 410. Edison Elementary School, 2015 Priority: 41. Edward “duke” Ellington @ Beckham, 2015 Priority; 12, Emerson Elementary-Middle School, 2015 Priority; 413, Mackenzie Elementary-Middle School, 2018 Priority; 44, Mann Elementary School, 2015 Priority; 418. Medicine And Community Health Academy At Cody, 2016 Priority; 48, Neines Dual Language Laming Academy, 2015 Pio 17. Noble Elementary-Middle School, 2016 Pri 418. Schulzo Elomentary-Middle School, 2018 Prion; 48. Spain Elementary-Middle School, 2015 Priority; 20. Wayne Elementary School, 2015 Priority; 21. Ann Arbor Trail Magnet School, 2014 Priority; 22. Clark, J.E. Proparatory Academy, 2014 Priority; 23. Detroit institute Of Technology At Cody, 2014 Priority; 24, Durfee Elementary-Middle School, 2014 Priori 25. Osborn Academy Of Mathematics, 2014 Priority; 26. Mason Elementary School, 2013 Priority; 27. Osborn College Proparatory Academy, 2013 Priority; 28. Osborn Evergreen Academy Of Design And Alternative Energy, 2013 Priority; 28, Brewer Elementary-Middle School, 2012 Priority; 30. Brown, Ronald Academy, 2012 Priority; 31. Douglass Academy For Young Men, 2012 Priority; 32. Fisher Magnet Lower Academy, 2012 Priority STATE SCHOOL REFORM/REDESIGN OFFICE (GEORGE W, ROMNEY BUILDING * 111 SOUTH CAPITOL AVENUE * PO BOX 30026 * LANSING, MICHIGAN 48909 (517) 284-6972 (517) 284-6979 (FAX) ysv9,michiaan aov/s33. Gardner Elementary School, 2012 Priority; 34. Gompers Elomentary-Middle School, 2012 Priority; 35, Greenfield Union Elementary-Middle School, 2012 Priority; 36. Henderson Academy, 2012 Priority; 37. King, John R. Academic And Performing Arts Academy, 2012 Priority; 38, Marquette Elementary-Middle School, 2012 Priority; 38. Marshall, Thurgood Elementary School, 2012 Priority; 40. Sampson Academy, 2012 Priority; 41. Thirkell Elementary School, 2012 Priori 42. Young, Coleman A. Elementary, 2012 Priority; 43. Bow Elementary-Middle School, 2011 PLAVPriority; 44, Carstens Elementary-Middle School, 2011 PLAVPriority; 45, Detroit City West Side Academy For Leadership Development, 2011 PLAVPriority; 46. Fisher Magnet Upper Academy, 2011 PLAPriority; 47. Palmer Park Preparatory Academy, 2011 PLA/Priority; 48, Pulaski Elementary-Middle School, 2011 PLAVPriority; 49. Detroit Collegiate Preparatory High School @ Northwestern, 2010 PLA/Priorit 50. King High School, 2010 PLA/Priority; 51. Western International High School, 2010 PLAVPriority This year, every Priority Schoo! is required to submit a revised or new Reform/Redesign Plan using the attached template. Your more detailed plans should be kept on fle. For assistance, please contact Jil Baynes, Department Manager, at (517) 284-6972 or baynes|@michigan. gov. Please submit reform plans to DTMB-SROplans@michigan gov by Friday, September 30, 2016. 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Priority Schools are those identified for improvement due to low achievement. “For the first time in the history of the SRO, more schools are being released from Priority School status than are being identified,” said School Reform Officer Natasha Baker. “It is our mission to turn Priority Schools into the highest performing schools in the state. We do this through academic accountability because every child ~ regardless of their demographics -- deserves access to quality educational opportunities. When kids are well educated, they can go to college or access a high-wage job or career after high school.” Today's release includes schools identified between 2010 and 2014. Each year, schools in the bottom 5 percent of all public schools in Michigan are identified as Priority Schools and monitored for turnaround in subsequent years. Schools are eligible to exit Priority School status if they meet the three exit criteria after four years of implementing their redesign plans. The plans include support and additional resources from the U.S. Department of Education, Michigan Department of Education (MDE), and local Intermediate School District (ISD) State law requires that schools identified in the bottom 5 pereent write plans and receive support services. The SRO’s vision is for every kid in Michigan to have access to a globally competitive education “Many times the additional resources from the MDE and ISDs improve conditions; other times, more action is necessary so kids can be prepared for @ good life after high school,” Baker said. “Because we want all kids to have a good life after high school, our office is responsible for taking action when schools have been chronically failing for several years.” Over the next 30 to 45 days the SRO will examine the geographic, academic, and enrollment capacity of other public school options for children attending one of the 38 failing schools. It is possible that closing a school is not feasible due to unreasonable hardship for the children attending that schoo! because no better options are available, If that is determined, the SRO will rescind the closure notice for that school and implement a different turnaround option. The other options include naming a CEO, changing the redesign plan, or placement into the State School Reform District. HtEDITOR'S NOTE: The list of schools being released from Priority School status, the 38 schools identified for a next level of accountability, as well as schools in the bottom 5% are provided here butp:ivww.micEXHIBIT 11Stati or Micmoay: DEPARTMENT OF TECHNOLOGY, MANAGEMENT & BUDGET DAVID 8. BEHEN ick SNYDER vowernci Lavine January 20, 2017 The ParentiGuardian of A Dear Parent/Guardian of Eee You are receiving this letter because Detroit Collegiate Preparatory High School @ Northwestern is at June 30, 2017 due to academic failurtsfoorbamyelased by We are working to improve the opportunities for all children to get a good education. Part of that process may include offering your child the opportunity to attend a higher-performing school. All students in Michigan deserve great schools. When schools struggle to educate a child, itis that child that suffers most. Teachers and principals write plans while schools receive more money or other help to improve. Sometimes more help makes things better; other times, something else must be done to help prepare children for life after high school The State School Reform Office (SRO) wants all children to have a good life after high school. Therefore, our office is working to offer your child the opportunity to enroll in a higher performing school For the next 30 days we will work with your local school district and community to finalize this decision. We will be looking at other public schoo! options for your child. If we determine that Closing your school would create a hardship because there are no better options at this time, we will not close the school, You will receive an update about the decision by the end of February/beginning of March. Ifinterested, you can use the information on the next page to enroll your child in a better option for the 2017-2018 school year. For more information, go to ww.michigan.aov/sro and click the ‘For Parents’ tab. We trust you will make the best decision for you and your family. We look forward to working with you and other parents so all children get a great education, Sincerely, NBG Natasha Baker State School Reform Officer STATE SCHOOL REFORM/REDESIGN OFFICE GEORGE W. ROMNEY BUILDING * 111 SOUTH CAPITOL AVENUE * PO BOX 30026 * LANSING, MICHIGAN 48909 (517) 284-6972 (517) 284-6979 (FAX) ichigan.aov/sr9Resident District Information ‘Name Website ‘Telephone Number Detroit Public Schools Community Disvil | Hip Geren orglenat ia) 240-4377 Additional District's Within the Area ‘Name Website Telephone Number | Airport Community Schoots wows airporischools com > i) 654-2474 | ‘Allen Park Public Schools : '3) 827-2150) | Anchor Bay School District Z (586) 725-2861 ‘Ann Atbor Public Schools hit:www.aaps.k12,mi. ust (734) 984-2930 ‘Armada Area Sch http:/iwww armadaschools.org7 (588) 784-2112 Brandon Schoo! Di ihe Counties of | Oakland and Lape (248) 627-1802 Brighton Area Schools (810) 209-4040 ‘larenceville School District. wow. clarencevilleschools org (248) 318.0400 Clarkston Community School Distt ‘ww clarkston k12.mi.us = { (248) 623-5408 Clintondaie Community Schools hitpi//seatwaitingforyou,com! i= (588) 791-6300 Crestwood Schoo! District htipwwna.csdm.k12.m.us Dearbom Heights School Distict #7 ‘ww distrit7 net Detroit Public Schools Community District | www detroit 2. of (813) 873-7902 East China Schoo! District ww.ocsd.us (810) 676-1018 East Detroit Public Schoois wiv eastdetoi og (686) 533-3024 Femdale Public Schools wie ferndaleschools.org (248) 586-2651 Fitzgerald Public Schools itv fitz k12.mius! (586) 757-1750 Flat Rock Community Schools www latrockschoos.org (734) 535-8500 ‘Garden City Public Schools ww qardencityschools.com (734) 762-5311 Gibraltar School District ‘www gibdist net = (734) 379-6350 Grosse lle Township Schools hitpulwwww gischools orgy (734) 362-2581 Harper Woods, The School Distict of he Gity of nv hschools.o7g I ind Consolidated Schools hit Ihaniandschoois.us rk, School District ofthe Cily of | waww.hazelparkschools.o7@ ea School District www has-k12.01g (248) 328-3147 Huron School Di ‘ynww.huronschools com ~ (734) 782-2441 Huron Valley Schools ‘nw huronschools.com Jefferson Schools (Monroe) __| htipvwwwe jeffersonschools.org? - Lake Orion Community Schools “vaww.lakeorion.kT2.ni.u5, ‘wnww lincoink 12.019) Lincoln Park, School District of the Cily of | vaww.lincoinparkpublicschools com — (313) 388-0200Name Website Telephone Number Livonia Public Schools School District | wan ivoniapulbieschools.or (734) 744-2595 Melvindale-North Allen Park Schools p.K1Z.mi.us t (313) 388-3300, ‘Milan Area Schools areaschools.573 I ‘Monroe Public Schools \wwew monroe k12.mi.us New Haven Community Schools htpy/inewhaven.misd.neU ‘Oxford Community Schools ‘new oxfordschools.org Plymouth-Canton Community Schools ‘wwew pees K12.mius (734) 416-2700 wew redfordu.k12,mius (313) 242-6000 ‘wow richmond. misd.net (686) 727-3565 ‘Romeo Community Schools Romulus Community Schools Saline Area Schools. ‘South Lyon Community Schools ‘South Redford School District ‘ww southrediord.org_ ‘Southgate Community Schoo! District { Www troy K12.mi.us www uticak 12, orgiucsmain asp ‘Van Buren Public Schools www. vanburenschools.net ‘Van Dyke Public Schools www. vdps.net (586) 758-8334 ‘Waterford School District wwew waterford R12. mni.uS (248) 706-4860, ‘Wayne-Westiand Community School District wwesd.net 19.2000, ‘Whitmore Lake Public School District tip: www wips.net 149-4464 ‘Woodhaven-Brownstown Schoo! District | waw.woodhaven k 12.mius! — 789-2357, ‘Wyandotte, School Distrit of the City of | waw.wyandotte.org ~ (734) 759-6002 ‘Ypsilanii Community Schools www. yeschools us, ~(734) 221-1218 Additional Resources ‘Name. Website [Telephone Number ‘Michigan Association of Public School ‘Academies (MAPSA) hitpiliwww charterschools org (17) 999-4426 Enroll Detroit —Thitps:iivnmeenrolidetroit org [(es8) 308-1534EXHIBIT 12DETROIT PUBLIC SCHOOLS COMMUNITY DISTRICT Office of the Interim General Superintendent Alycia Meriweather Fisher Building, 14" Floor 3011 West Grand Boulevard Detroit, MI 48202 February 20, 2017 Natasha Baker State School Reform/Redesign Office George W. Romney Building 111 South Capitol Ave. P.O, Box 30026 Lansing, MI 48909 Dear Ms. Baker, I write to supplement my February 1, 2017 letter in which we provided information concerning the 16 Detroit Public School Community District (DPSCD) Next Level of Accountability schools slated for closure by the State School Reform Office (SSRO). We remain concerned that closing these schools will lead to adverse—and possibly catastrophie— educational consequences for students, As you know, MCL 380.391 (3) requires your office to determine whether closure of DPSCD public school “would result in an unreasonable hardship to . .. pupils because there are insufficient other public school options reasonably available for these pupils.” We believe that a school closure necessarily imposes “an unreasonable hardship” if it inflicts educational injury on students. And we are concemed that many DPSCD students will be affirmatively harmed by school closures. If your office moves ahead with closures, many students will be uprooted from their current environment, and forced to enroll at a new school that is not significantly better than their old school. This proposed action is a recipe for failure, Studies have repeatedly shown that when students are forced to change schools unexpectedly, their academic performance suffers, their risk of chronic absenteeism increases, and they are less likely to graduate from high school Stability, in other words, is a crucial factor in student success, Thus, unless students have “reasonably available” a significantly better schoo! option than their current placement, the disruption caused by closures will almost certainly impose “unreasonable hardship” on them, And for students at the 16 schools slated for closure by your office, there are vanishingly few high-quality educational options “reasonably available.” That is particularly true given that (1) there are no high-quality schools with available seats in the immediate vicinity of many schools slated for closure; and (2) many families served by the targeted schools lack reliable access to transportation,For the reasons that follow, therefore, we respectfully submit that closure of the 16 DPSCD schools would impose “unreasonable hardship” on students, 1. Foreing Students to Switch Schools Disrupts their Educati Learning Outeomes and Harms As an initial matter, when making your “unreasonable hardship” determination, we urge you to consider the many studies demonstrating that students are affirmatively harmed when they are forced to switch schools. One study (using data fom the Milwaukee Public School District) showed that students whose schools were closed tend to struggle when they enroll in their new school, During the 1-2 years immediately “after closure, students’ GPA. and attendance are negatively impacted." Moreover, “students who experience a closure while in high school are less likely to graduate high school and less likely to attend college.”* ‘That conclusion is consistent with repeated studies demonstrating that students’ academic performance suffers when they “unexpectedly” switch schools—that is, when they switch schools for reasons other than grade promotion. A 2004 meta-analysis of 26 studies, for example, indicated that students who change schools at any point during their elementary school career tend to be about four months behind their peers in both reading and math when compared to students who did not change schools.’ Those findings were echoed by a 2009 meta- analyses, which found statistically significant evidence that non-promotional school transfers lead to significant decreases in academic performance in both literacy and math.’ And a 2015 meta-analysis again confirmed these findings, concluding that even one non-promotional school move reduces elementary school achievement in reading and math. What is more, students who “unexpectedly” switch schools have higher absenteeism and dropout rates than other students, Data from the National Educational Longitudinal Study (NELS) shows that students who changed schools between the eighth and twelfth grades are more than twice as likely to drop out, or enroll in an alternative educational program, than students who did not change schools.’ The adverse effects of non-promotional transfers on dropout rates were again confirmed by a 2015 meta-analysis.’ And the NELS data further demonstrates that non-promotional school transfers are associated with chronic absenteeism among high school students, even controlling for variables such as family structure, socio- economic status, race, and school setting.” "Matthew F. Larsen, Does Closing Schools Close Doors? The Effect of High School Closings on Aldievement and Attainment avs. Tulane University. ° Majida Mchana and Arthur Reynolds, School Mobility and Achievement: A Meta-Analysis, 26 Children and Youth Services Rev. 1, 93 (2004). * anthur J. Reynolds, Chin-Chih Chen, and Janette E. Herbers, School Mobility and Educational Success: 4 Research Synthesis and Evidence on Prevention, University of Minnesota (June 22, 2009) 5 Russell Rumberger, Student Mobility: Causes, Consequences, and Solutions, National Education Policy Center (June 2015), © RAW. Rumberger and K.A, Latson, Student mobility and the increased risk of high school dropout, 107 American Journal of Education I-35 (1998). 7 Rumberger, supra n. 5. * Rumberger & Larson, supra n. 6.Finally, it bears emphasis that the adverse effects of multiple non-promotional school transfers are cumulative. Every time a student is forced to switch schools for non-promotional reasons, it exacerbates the academic damage that was caused by previous transfers. Multiple studies have demonstrated that the adverse effects of non-promotional transfers on student achievement’ and dropout rates are particularly pronounced for students who have been forced to switch schools multiple times.'” I. Many Detroit Students Have Already Been Subjected to Educational Injury Due to School Closings The foregoing studies are particularly relevant to your “unreasonable hardship” determination, because many Detroit students have already been forced to change schools for non-promotional reasons. From 2009 through the present—during which time the Detroit public schools were under State control—the number of school openings and closings in Detroit has dwarfed the number of openings and closings in other municipalities. Over the course of that eight-year period, approximately 150 schools in Detroit have closed—about 3.5 times the number that have closed in Grand Rapids, the Michigan municipality with the second-highest number of closings.'' And over that same time period, approximately 125 schools opened in the City—nearly three times the number that have opened in Grand Rapids. Predictably, the chaotic educational landscape in Detroit has disrupted many of its students’ educational careers. A 2014 academic study concluded that in Detroit, “48% of elementary students, 42% of middle school students, [and] 48% of high school students have attended more than one school. This compares with the statewide average of 21%."'* Internal DPSCD data shows that those numbers have grown in recent years. Of the students currently enrolled in DPSCD, over 53% have switched schools at least once for non-promotional reasons. The adverse effects of educational instability are all too clear in Detroit. Consistent with national studies linking educational instability to poor academic performance, Detroit students perform worse than their peers on virtually every academic measure. For example: in 2015, the National Assessment of Educational Progress (NAEP) determined that 93% of Detroit eighth- ° Judy A. Temple and Arthur J. Reynolds, Schoo! Mobility and Achievement: Longitudinal Findings From «an Urban Cohort, 37 J. of School Psychology 355 (1999) (longitudinal study on 1,000 Chicago students of low socioeconomic status; concludes that the loss of academic growth in both reading and math is most pronounced where students move 2 or more times); Russell Rumberger, Student Mobility: Causes, Consequences, and Solutions, National Education Policy Center (June 2015) (declines in elementary school achievement in reading and math most pronounced among students who made 3 or more moves), "Rumberger & Larson, supra n. 6. (1998) (effects on dropout rates most pronounced when students switch schools 2 times or more); Rumberger, supra n, 5 (effects on dropout rates particularly pronounced When students switch schools 3 times or more). "' Center for Educational Performance and Information, Educational Entity Master, available at hutp:/Avww.cepi.state.mi.us/eemi#mainMenu. ® Liyang Mao and Bettie Landauer-Menchik, Mobility of Students in Detroit's Charter Schools 2 (April 2014), available at https:/Avww.michigan.gov/documents/mde/Student_Mobility_in_PSAs_January_21_2014_445767_7.pdf © Soe Appendix A, Transient vs. Stable Students in DPSCD, Tables 1, 2.graders lacked proficiency in reading, and 96% lacked proficiency in math.'* What is more, Detroit students score worse on assessment tests than students in every other urban district in the United States. In 2009, 2011, 2013, and 2015—the last four years in which the NAEP was administered—Detroit fourth and eighth-graders had lower math and reading scores than students any other city, and often by a significant margin.'* Further (and again, consistent with national studies highlighting the adverse effects of instability), Detroit has been beset by sky-high dropout rates and chronic absenteeism rates. Detroit's dropout rates in recent years have hovered around 20%;'* in 2013, nearly one quarter of Detroit public school high schoolers dropped out prior to graduation.'” Chronic absenteeism, moreover, is virtually endemic in Detroit. Over half of DPSCD students (51.3%) have been chronically absent from class already this school year.'* Nearly half of those students suffer from “severe” chronic absentecism (defined as missing 20% or more of total school days)."” Lest there be any doubt, DPSCD is not contending that its historic shortcomings have been caused entirely by student transiency. But—particularly in light of the academic research discussed above—it is illogical to think that Detroit schoolchildren have not been harmed by the instability imposed upon them. And, indeed, all of the relevant data indicates that those harms exist, and that they have been severe. HI. ‘The Students at Schools Slated for Closure are Particularly Vulnerable to the Adverse Effects of Educational Instabi All of the above outlined factors culminate in a position of unique vulnerability. for Detroit students. An absolute majority of DPSCD students (53%) have already experienced at least one unexpected transfer over the course of their educational carcers, The adverse effects of forced transfers are compounded when students are forced to change schools multiple times. ‘There is, therefore, a significant risk that many Detroit students will suffer severe educational injury if they are forced to change schools once again. Considering these cumulative facts, the prospect of any school closure in Detroit is problematic, That includes the 16 DPSCD schools you have identified for closure, as well as the eight schools identified for closure that are currently operated by the Education Achievement Authority (EAA), Students in those EAA schools—which are slated to be returned to DPSCD at the end of this school year, and for whom DPSCD therefore has special responsibility—are just as vulnerable to the adverse effects of non-promotional transfers as other students "* Nat'l Ctr for Educ. Statisties, 20/5 Reading Grades 4 and 8 Assessment Report Cards: Summary Data Tables for National and State Average Scores and Achievement Level Results (2016), https:/igoo.gl/YBNvOq; Nat'l Ctr for Educ. Statistics, 20/5 Mathematics Grades 4 and 8 Assessment Report Cards: Summary Data Tables for National and State Average Scores and Achievement Level Results (2016), https://goo.g/DvVUPS. 'S Shawn Lewis, Detroit Worst in Math, Reading Scores Among Big Cities, Detroit News (Oct. 28, 2015). '® CBS Detroit, Detroit Praised For 65 Percent Graduation Rate, Increase Echoed Across The State hitp://detroit.cbslocal.com/20 13/02/13/detroit-praised-for-65-percent-graduation-rale-increase-echoed- ‘actoss-the-state/ (Feb. 13, 2013) " See Appendix B, DPSCD 2014-2015 Graduation/Dropout Snapshot. “* See Appendix C, Absenteeism & Chronic Absenteeism Rates at Schools Slated for SRO Closure. id.Yet the risk to students is especially acute in the 16 particular DPSCD schools you have identified as subject to closure. At the schools identified for closure, “transiency rates"—ice, the percentage of students who have experienced at least one non-promotional transfer over the ‘course of their educational careers—are sky-high. Thirteen of the 16 schools slated for closure have transiency rates that exceed the already-stratospheric 53% rate for DPSCD students as a whole.”” Six of the schools slated for closure have transiency rates that exceed 80%.°' And many students in the 16 schools slated for closures have already been forced to transfer schools multiple times.”” Indeed, at the schools slated for closure, 1,101 students—14.9% of their total population—have already experienced at least four non-promotional transfers.” Were these schools to close, it would put those students at risk of their fifth such transfer. Closing these schools would thus only impose further instability on a population of students that has already experienced a tragically volatile educational career. And that, in turn, ‘would likely impose further devastating educational injuries on vulnerable students, IV, Students Displaced by the Proposed Closures Lack High-Quality Educational Options Perhaps some of the educational injury associated with these forced transfers could be alleviated if high-quality educational options were realistically accessible to the affected students. Unfortunately, for the vast majority of students affected by these closures, such options are simply not available. As outlined in my February | letter to you, only 20 schools in Detroit have a top-to-bottom ranking in the 25" percentile or higher. Most of those schools are already at capacity, meaning that they will be unable to take in any students from the 16 schools you have identified for closure. Further (and again, as outlined in my February 1 letter) closing the 16 DPSCD schools you have identified will force most students to travel far outside their neighborhoods to attend school—even though those schools are unlikely to be markedly better than the school they formerly attended. Recognizing, perhaps, that there are few high-quality schools available in Detroit, the letter that you sent to the parents of DPSCD schools slated for closure listed 58 districts in which parents could purportedly enroll their child “in a higher performing school.” Those “additional districts” included Ann Arbor Public Schools (a 50-minute drive from Detroit) and East China Public Schools (over an hour's drive from Detroit). Even putting aside the fact that many families may not want their children to endure two hours of commuting time per day, such districts are absolutely inaccessible to many of the Detroit families whose schools are slated to close, United States Census data shows that a significant fraction of households in the affected Detroit neighborhoods—between 20% and 40%, in most neighborhoods—lack any access to an automobile.* For those students, educational options are limited to schools that they can access ‘See Appendix A, Transient vs, Stable Students in DPSCD, Table 1, The remaining three schools also have high transiency rates: 50.8%, 49.7%, and 39.1%. 2d. ® See Appendix A, Transient vs, Stable Students in DPSCD, Table 3. Bid: % See Appendix D, Demographic Data: Detroit Census Tracts Within J-Mile Radius of Affected Schools.s by foot, by DPSCD “yellow bus,” or by public transportation.”* Schools in Ann Arbor, for example, are simply out of reach, What is more, even families who have access to a car are unlikely to be able to drive their children miles to and from school each day. The affected neighborhoods have extremely high rates of families living in poverty. In the Detroit census tracts surrounding the 16 affected schools, poverty rates for families with children under the age of 18 range from 30% to 46.5%." For those families, the gasoline and car maintenance costs associated with driving 40, 60, or 100 miles per day are likely to be prohibitive. Further, poorer parents—particularly those who work defined shifts, or for an hourly wage—are unlikely to be able to take time off work cach day to transport their child to and from school.” In short: if you move forward with closures of the 16 DPSCD schools, many of the affected students—most of whom have already experienced at least one non-promotional transfer—are likely to move into yet another Detroit school. Given Detroit’s current educational landscape, that school is unlikely to be significantly superior than the school from which they transferred. In fact, the transfer alone is likely to impede students’ academic performance, place them further behind their peers, and increase their dropout risk and their risk of chronic absenteeism, That, we submit, is “unreasonable hardship.” Nothing in this letter should be read to suggest that DPSCD believes the schools slated for closure are of acceptable quality. They are not. To that end, DPSCD is in the process of finalizing a plan, grounded in research, which will transform the 16 affected schools into world- class institutions. Crucially, DPSCD’s plan will transform those schools without imposing further turmoil on the academic careers of already-vulnerable students. For the first time in nearly a decade, Detroit’s public schools have a fresh start, unencumbered by crippling debt. For the first time in nearly a decade, Detroit's schools have lected, empowered local leadership, We know that we have a significant task ahead of us, and we will not shy away from addressing the District's educational challenges head-on. However, it is crucial that DPSCD’s local leadership be given a fair opportunity to address those challenges in the first instance, unencumbered by additional difficulties imposed by State-mandated closures * A side note: ifthe sixteen schools are closed, DPSCD will have to dramatically ramp up the transportation services it provides, because many students who previously were able 10 walk to school will now require DPSCD-provided transportation. Preliminary estimates indicate thatthe total transportation costs associated with closure will be $4,237,178. That is money that DPSCD will be unable to spend on teachers, textbooks, and supplies—exacerbating the “unreasonable hardship” imposed on DPSCD students. See Appendix E, Preliminary DPSCD Estimates Regarding Increased Transportation Costs Associated with Potential Closures. ® See Appendix D, Demographic Data: Detroit Census Tracts Within I-Mile Radius of Affected Schools Tp light ofthese factors, the letter sent to parents atthe 16 schools slated for closure has already caused ‘a great deal of turmoil. Families—many of whom have few retlistic educational options— have been scrambling to determine where their child will attend school next year, and how their child will get there. This ongoing uncertainty, we submit, is yet another reason for your office to quickly determine that closing the 16 schools would impose unreasonable hardship.(or by other State-mandated reforms).”* In the final analysis, then, we ask only that we be permitted to do the hard work with which Detroiters have entrusted us—and that your office refrain from destabilizing DPSCD through counterproductive closures before we have had an ‘opportunity to begin that work in earnest. Sincerely, (Woriweathe Alycia Meriweather Interim General Superintendent CC: DPSCD Board of Education Members Randy Liepa, WRESA Superintendent Brian Whiston, Superintendent, State of Michigan Michael Zimmer, Office of the Governor > This leer is focused on the unreasonable hardship that would be caused by school closures specifically. I note, however, that other courses of action—if imposed on DPSCD by the State—could have an equally destabilizing effect on the affected schools, students, and families. Such potentially destabilizing actions include, but are not limited to, placing the 16 affected schools inthe state school reform/redesign district under MCL 380.1280e(6), ot appointing a chief executive officer to take control ‘of DPSCD schools under MCL 380.1280c(7). DPSCD reserves all rights to object to any future actions taken by the SRO or the State,EXHIBIT 13Tawsine January 25, 2017 Mrs, Alycia Meriweather, Superintendent Detroit Public Schools Community District, 3011 West Grand Bivd Detroit, Mi 48202 Dear Mrs. Meriweather, On January 20, 2017, the following school(s), wastivere identified as being among the lowest achieving 5% of all public Schools in this state as determined under MCL 380.1280c forthe immediately preceding three school years. Therefore, these school(s) is/are receiving a next level of accountabilty. 4. Ann Arbor Trail Magnet School, 2014 Priority 2, Bow Elementary-Middle School, 2011 PLA 3. Clark, J.. Preparatory Academy, 2044 Priority 4. Detroit Collegiate Preparatory High Schoo! at Northwestern, 2010 PLA 5. Detroit Institute of Technology at Cody, 2014 Priority 6. Durfee Elementary-Middle School, 2014 Priority 7. Fisher Magnet Upper Academy, 2011 PLA 8. Gompers Elementary-Middle School, 2012 Priority 9. Henderson Academy, 2012 Priority 10. Marquette Elementary-Middle School, 2012 Priority 44. Mason Elementary School, 2013 Priority 42, Osborn Academy of Mathematics, 2014 Priority 43. Osborn College Preparatory Academy, 2013 Priority 14. Osborn Evergreen Academy of Design and Alternative Energy, 2013 Priority 15, Sampson Academy, 2012 Priority 46. Thirkell Elementary School, 2012 Priority Over the next 45 days, the SRO will be completing an in-depth analysis of this/these schools) to determine if the proposed next level of accountability action will impose an unreasonable hardship on the impacted pupils Assessing Unreasonable Hardship. The SRO will consider other public schoo! options available to students in the grade levels offered and geographic area served by the public schoo! identified for closure to determine if closing the identified school(s) would result in an unreasonable hardship for the impacted students. The SRO is committed to ensuring that the closure of a failing school does not necessitate the enrollment of a displaced student in another failing school, ‘The SRO's Unreasonable Hardship Review will consist of three parts: 1. A comprehensive review of all available data related to the past and current performance of the identified school(s) 2. An academic and an operational on-site review (a half day site visit to each schoo!) {A detailed examination of other public school options available to students in the grade levels offered and geographic area served by the public school identified for closure. STATE SCHOOL REFORM/REDESIGN OFFICE GEORGE W, ROMNEY BUILDING * 111 SOUTH CAPITOL AVENUE * PO BOX 30026 * LANSING, MIC (517) 284-6972 (517) 284-6979 (FAX)‘A separate notification regarding the determination of unreasonable hardship will be provided by the end ‘of February/beginning of March In order to conduct the Unreasonable Hardship Review, the SRO is requesting specific data that will inform the review process. The formal data request is provided in writing below and in the attached Data Request Form. The SRO is committed to collecting as much information as possible to determine unreasonable hardship and to ensure that students are not displaced to low-performing schools. However, should the SRO be precluded from obtaining any of the requested data, or from completing any of the proposed reviews, the SRO's unreasonable hardship analysis will consist ‘of only the legally reauired examination of other public schoo! options available fo students in the ‘grade levels offered and geographic area served by the public school identified for closure. Data Request: Attached as Appendix A is the data packet that the SRO requests to be completed in its entirety ‘and submitted via email to dtmb-schoolreformoffice@michigan.gov, in ts completed form, on oF before Wednesday, February 1, 2017. ‘On Site Review: Academic ‘A representative from the SRO will be contacting building principals directly to schedule the Academic On-Site Review. The window for this review will be: Monday, January 30 ~ Friday, February 21, 2017, The review will be structured around a set of research-based Turnaround Practices that are based on both academic and practice-based research on the common characteristics of successful tumaround schools. These practices are organized into five different domains: Domain 4: Leadership, Shares Responsibility, and Professional Collaboration Domain 2: Intentional Practices for Improving Instruction Domain 3: Providing Student-Specific Supports and Instruction to All Students Domain 4: Schoo! Climate and Culture Domain 5: District System: Districts develop systems to support, monitor, and sustain turnaround efforts By structuring the SRO's Unreasonable Hardship Academic On-Site Review around these domains the SRO is acknowledging that in determining unreasonable hardship one must not only examine historic performance but must also work intimately with local community members and educators to determine if the academic and operational realities of the identified schoo! reflective of a school poised for rapid turnaround. Therefore, the On-Site Review will be structured as follows: + SRO Representatives Interview Building Leadership 2 SRO Representatives and Building Leadership Complete a Building Wak-Through with Classroom Observations + SRO Representatives host a teacher focus group “a The teacher focus group is comprised of 4-5 teachers from the identified school that are nominated by the building leadership + SRO Representatives host a student focus group “The student focus group is comprised of 4-6 students from the identified schoo! that are nominated by the building leadership + SRO Representatives host a parenticommunity focus group ‘>The parenticommunity focus group is comprised of 8-10 parents/community leaders that are nominated by the building leadership On Site Review: Operational To complete an operational on-site review, the SRO has partnered with OTMB's Facilities & Business Services Administration Office (SFA) to determine a facility conditions index (FCI) for school buildings that have been identified by the SRO as at-risk for closure. The FCI will measure maintenance and repair costs against current replacement cost of the building. To Page 2 of 6calculate the FCI for a building, we will divide the total estimated cost to complete deferred Mnaintenance projects for the building by ts estimated replacement value. ‘Allingpections will be designed to be non-intrusive and the results will be based on observations ‘and assumptions given the factual knowledge provided. A representative from DTMBISFA will be Contacting you directly to schedule the Operational On-Site Review for schoo! (or schools) \Gentified for closure, The window for this review will be: Monday, January 30 ~ Friday, February 24, 2017, ifthe SRO determines that an unreasonable hardship does exist for pupils served by a specifi schools), the SRO may rescind this order and allow forthe school(s) to continue to operate. Should the SRO thosse to rescind the closure notification, the district and school leadership must submit a school improvement plan to the SRO that includes measures to increase pupil growth and improve pupil proficiency, with growth and proficiency measured by performance on state assessments, Ifthe SRO determines that closure of the public school would not result in an unreasonable hardship to these pupils the community district and school leadership should be prepared to immediately notity impacted students, parents, staff and stakeholders of the identified school(s) closure effective at the end Of the current school year. Community district and school leadership should also be prepared to begin assisting impacted students with the enrollment processes based the wishes of those affected parents. If you have additional questions, please contact Jil Baynes at (517) 264-6972 or baynes\@michigan gow Sincerely, NB EK Natasha Baker State School Reform Officer Ce: Iris Taylor, Schoo! Board President Randy Liepa, Superintendent, Wayne RESA Page 3 of 6APPENDIX A: SRO Unreasonable Hardship Data Request Packet ‘The SRO is committed to ensuring that the Unreasonable Hardship Determination required under MCL 380.391(3), MCL 280.507(6), MCL 380.528(6), MCL 380.561(6) 380.1280c is as informed as possible. Therefore, the SRO is requesting the fol ), oF optionally adopted under MCL. lowing information be ‘emailed to dimb-schoolreformoffice@michigan gov on or before Wednesday, February 1, 2017, ‘On-Site Review Participants: Please complete the following table below or in the attached spreadsheet with the contact the individuals who will be participating in the on-site reviews at each site, 2 information for ‘Reademic Review: Bui ing Leadership Interviews, Title ‘Name Phone. Email Principal [Assistant Pancipal_ Bulng Leader [ Building Leader ‘Academic Review! Teacher Focus Group ‘Subject Name Phone. Email ELA ‘Mathematics ‘Science Social Studies [Elective ‘Reademic Review: Name fudent Focus Group Grade Level ‘Academie Review! ParentiCommunity Focus Group ‘Organization Duals (W aopicabe) Phone Email Parent Parent Parent Parent Parent ‘Community | ‘Communit ‘Community ‘Communit ‘Communit T ‘Operational Review: FCI Liaisons/Representatives: Title Name Phone. Email ‘Dratie Representative Site Representative Page 4 of 6Academic Data Use the space provided or in the attached spreadsheet (o respond to each statement. Curricula + ELA: Please identify the ELA Curricula that is being utllzed for the current school year (2016- 2017) + Math: Please identily the Mathematics Curricula that is being utlized for the current school year (2016-2017) + Science: Please identity the Science Curricula that is being utilized for the current school year (2016-2017) + Social Studies: Please idenify the Social Studies Curricula that is being utilized for the current school year (2016-2017) ‘Academic Intervention Systems used: ‘+ Please identify all Academic Intervention Systems that are being used currently (2016-2017 school year) Social/Emotional/Behavioral Intervention Systems used: ‘+ Please identify all SociaEmotional/Behavioral Intervention Systems that are being used currently (2016-2017 school year) Page 5 of 6Operational Data Use the space provided or in the attached spreadsheet (0 respond fo each statement. Additional Information to be provided for each identified schoo! + Year Built * Major Renovation Year, in any ‘+ Square Footage of Building + Code Compliance Record(s), if available + Safety Record(s), if available + Maintenance Report(s), if available + Site Assessment Report(s), if available * Floor Plan Drawing(s), if available Page 6 of 6EXHIBIT 14STATE OF MICHIGAN STATE BOARD OF EDUCATION RICK SNYDER ; BRIAN J. WHISTON. GovERNoR STATE SUPERINTENDENT STATE BOARD OF EDUCATION STATEMENT ON. ‘SCHOOL CLOSURES AND DEFINITION OF HARDSHIP On January 20, 2017, the Michigan Department of Education published the annual “top to bottom list.” This list was largely derived from scores on high stake standardized tests taken over the past three to five years. Based on this, and the School Reform Officer's interpretation of PA 192, subsection 391(1), (2) and (3), the Office immediately announced 38 schools at risk of closure, all located in majority African American schools with 25 in Detroit Subsection 391(3) of 2016 PA 192 states, in part, "if the state schoo! reform/redesign officer determines that closure of the public schoo! would result in an unreasonable hardship to these pupils because there are insufficient other public school options reasonably available for these pupils, the state school reform/redesign officer may rescind the order subjecting the public school to closure.” Consequently, itis the intent of the Schoo! Reform Office (SRO) to examine each school to determine the “feasibility” of the closure based on “unreasonable hardship.” The State Board of Education (SBE) is advising the School Reform Office to rescind ALL school closures at this time based on the following: 1. No clear definition for "Unreasonable Hardship” exists 2, There is a potential for disruption and harm to students, as school clasure is a state-created form of student mobility and a large body of research finds that student mobility can have harmful effects on student performance. This includes a greater likelihood of increased drop out rates’, lowered achievement, increased chance of substance abuse”, lower levels of occupational prestige, increased symptoms of depression, and greater likelihood to be arrested as adults! 3. Research that is supportive of school closings indicates that closures may be helpful if students attend higher performing schools.® However, one of the issues in assessing school closings is whether there is. sufficient stock of substantially higher performing schools. 4. There is great potential for negative effects on students where threats of schoo! closure themselves can have a negative impact on students.® Research further tells us that school closings can inflict trauma on a community and that students feel the loss in a manner similar to mourning. 5. Considerable changes to test content and delivery have occurred over the last four years and. to change again to address the newly authorized federal law, “Every Student Succeeds Act.” * htto://vw sciencedirect,com/science/article/pi/S0049089x05000700?np=y 2 hetpi//imwa-sciencedirect.com/science/article/pi/S0190740903001191 ® https://Awww.ncbi nlm.nih.gov/pmefarticles/PMC5115879/ * https www. cambridge.org/core/ournals/development-and-psychopathology/artice/civ-classitleschool- ‘mobility-and-developmental-outcomes-in-young-adulthooddiv/22969866D2203F307AB261C7AA724799, * http://educationresearchalliancencla.org/iles/publications/Bross-Harrs-Liu-The-Effects-of Performance-Based- School-Ciosure-and-Charter-Takeover-on-Student-Performance.pdf ® hetp//files.eric.ed.gov/fulltext/£0510792,pdf STATE BOARD OF EDUCATION ikely (CASANORA E, ULBRICH ~ CO-PRESIDENT + RICHARO ZEILE - CO-PRESIDENT MICHELLE FECTEAU~ SECRETARY + TOM MCMILLIN ~ TREASURER, NIKKI SNYOER - NASBE DELEGATE = PAMELA PUGH LUPE RAMOS-MONTIGNY + EILEEN LAPPIN WEISER 608 WEST ALLEGAN STREET + P.0, 20X 20008 + LANSING, MICHIGAN 4asveIn order to determine what isin the best interest of students in targeted schools, the State Board of Education strongly recommends that no schools be closed this year in order for: 1 More time to be devoted to fully research the possible hardship and harm closures may have on students Governor Rick Snyder to reconsider and reverse Executive Order 2015-9 that removed the State Superintendent of Public Education’s authority over the School Reform Office and authority to develop the list of priority schools, ‘The Michigan Department of Education and its education experts to be involved in school turnaround, efforts at every level. ‘The State Superintendent to fully implement the “partnership” model to assist local schools. ‘The State Board to exercise its constitutional authority to provide leadership by further developing a means to measure “unreasonable hardship” that: ‘a Is based upon evidence and research, b. Considers the short and long term impacts, ‘c. Applies to subgroups of students including those with special education and/or transportation needs, and cultural and/or language differences. d, Measures the overall Impact on students, e. Includes the financial and academic viability to the district, f. Assesses the potential negative consequences for the students’ home communities. Furthermore, the State Board of Education would like to: 1 Make note of the board's Policy on State School Turnaround that was developed in May of 2015 and the action taken by the State Board of Education Legislative Committee on August 23, 2016. ‘Acknowledge that as a bipartisan body, the SBE supports $B27 and replacing 1280c with new legislation that aligns with the accountability system developed under the Every Student Succeeds ‘Act’s Plan while emphasizing school assistance and reform through MDE's "Partnership Model." Emphasize that the SRO's initial handling of this matter created substantial anxiety, frustration, anger ‘and distrust among the children and families at schools being considered for closure. School personnel are demoralized, and are struggling to continue ongoing reform efforts, which only damages children more. We implore the SRO to recognize its actions have substantial impact and ask that the SRO proceed with higher professionalism than has been evident so far. Reiterate that any new legislation created to replace 380.1280c should restore the Schoo! Reform Office to the MDE, With intermediate school districts, MDE is currently the agent providing school reform guidance through its Partnership Model. It isin the best position to support change, demand performance and evaluate whether schools are able to educate their students. Emphasize that threatened school closures in several Michigan school districts are a credit negative, according to Moody's Investors Service (MCO}. ‘Adopted February 14, 2017EXHIBIT 15SRO ‘STATE SCHOOL REFORM/REDESIGN OFFICE Business Rules Lowest Achieving 5% School Ranking Priority Schools Identification STATE SCHOOL REFORM / REDESIGN OFFICE SEPTEMBER 1, 2016Lowest Achieving 5% Business Rules Overview The Michigan State School Reform/Redesign Office (SRO) Bottom Five Percent is a list of public schools in Michigan ranked according to student achievement and student growth on state assessments and, if applicable, graduation rates. All tested academic content areas are eligible to be included, and for schools that graduate students, graduation rate is included. Schools that do not meet student size minimums, subject area minimums, or schools that serve specialized populations of students will be excluded. School-level values are calculated by aggregating student performance on statewide tests, including both general assessments and those based on alternate standards as described in the section on eligibility. All valid tests are included for eligible students Please note that all student level values (Student level Z-Scores, Student Growth Percentiles, Full-Academic-Year (FAY) status) are calculated by the Michigan Department of Education (MDE). More detailed information can be found belo sat Sheet 37: 7 390088, les 475671 Z.p4f STATE SCHOOL REFORM / REDESIGN OFFICE, 9/1/201 1of13Lowest Achieving 5% Business Rules Table of Contents Topic Page Overview 1 Acronyms and Definitions 3 Narrative Description 4 Eligibility 6 Calculation Methodology 8 Resource Information 13 STATE SCHOOL REFORM / REDESIGN ( E, 9/1/2016 20f13Lowest Achieving 5% Business Rules Common Acronyms and Abbreviations Term MDE CEPI FAY SGP MGP ELA MEAP MME M-STEP SEE act Definitions Term ZScore MEAP-Access MI-Access Graduation Rate Feeder School Cohort Center Based Program Detail Michigan Department of Education Center for Educational Performance and information Full Academic Year Student Growth Percentile Mean Growth Percentile English Language Arts Michigan Educational Assessment Program Michigan Merit Examination Michigan Student Test of Educational Progress Shared Educational Entity College admissions test that made up a portion of the MME Meaning A measurement of a value's relationship to the average (mean) ina group. A Z-score of 0 (zero) means the value is equal to the average. A Z-score can be positive or negative, indicating whether it is above or below the average. MEAP Access was an alternate assessment that was based on modified achievement standards aligned to the state standards. Michigan's alternate assessment system, designed for students who have, or function as if they have, cognitive impairments. A percentage calculated by dividing the number of students who graduate by the number of students who began the cohort for that particular graduating class. The school where the student was enrolled and the school responsible for the content standards being assessed on the test. Students grouped together based upon grade, entry year, or expected graduation year. Schools that serve exclusively special education populations, Determination is completed by the Michigan Department of Education. STATE SCHOOL REFORM / REDESIGN OFFICE, 9/1/2016 30f 13Lowest Achieving 5% Business Rules Narrative Description ‘The Bottom Five Percent is a list of ranked schools based on student achievement and student growth as measured on academic content area state assessments over a two-year period as well as, in some cases, graduation rate. The content tested in the 2013-14 school year MEAP/MME were reading, mathematics, science, social studies, and writing. The content tested ‘on 2014-15 M-STEP are ELA, mathematics, science, and social studies. Student performance results on academic content area tests are further separated in grade span groupings, Specifically, content at the elementary/middle school (3-8) and the high school (9-12) levels are treated as distinct, In order to satisfy selection criteria, schools must have tested at least two subjects across both school years 2013-14 and 2014-15. For example, a school with grades K-3, may have tested only mathematics and ELA at the elementary/middle level. Alternately, a large K-12 school may have tested mathematics, science, and social studies at both elementary/middle and high schoo! levels resulting in up to six subjects included in the calculations. The Bottom Five Percent is generated through a serles of aggregations utilizing assessment results for only Full Academic Year (FAY) students. FAY students are those determined by the MDE to be enrolled for the entire school year. Student Z-Scores are aggregated to create a school level achievement score for each subject. At the same time, valid Student Growth Percentiles (SGPs) are aggregated into Mean Growth Percentiles (MGPs) to create an overall school level growth score for each subject. Next, the aggregated subject achievement and growth scores are converted into school-level 2-Scores placing each school’s score value on the same scale. These are then combined with equal weights of 50% achievement and 50% growth to create an overall subject value. Achievement alone is used if MGPs are not available or If the percent proficient is 90% or higher. Overall school subject scores are converted into Z-Scores and then combined into a weighted school score across all subjects, The number of students tested in each subject is used asa weighting factor for that subject when the school index is, calculated (See Example Table 1). For schools that graduate students, a graduation rate index is also calculated, comprising 10% of the overall school score, with the remaining 90% divided ‘among the appropriate subjects. Graduation rates are calculated by the Center for Educational Performance and information (CEPI). £, 9/1/2016 40f13 STATE SCHOOL REFORM / REDE IGN OFFILowest Achieving 5% Business Rules Table 1. Weighting Subjects by Full Academic Year (FAY) counts - an example Sample Schoo! has 600 total assessments given across all grades and subjects: A 200 students were tested © Mathematics 200 students were tested + Science 150 students were tested * Social Studies 50 students were tested Relative Weights for FAY tested students in each subject area are: * ELA 33.3% (200/600) + Mathematics 33.3% (200/600) Science 25.0% (150/600) Social Studies 8.3% — (50/600) STATE SCHOOL REFORM / REDESIGN OFFICE, 9/1/2016 5 of 13,Lowest Achieving 5% Business Rules Eligibility ‘Assessment score and Student Growth Percentile In order to be included in the overall Bottom Five Percent calculation, an assessment score or Student Growth Percentile must meet several requirements: Subject ‘Assessments must be from a general or alternate summative assessment. MEAP, Ml-Access, MEAP-Access, MME, and M-STEP are ll utilized. Scores are attributed to the school designated as the feeder school, The assessment score must be valid (ie, all rules for completing a test must be met; there must be no prohibited behavior, misadministration of test, etc). ‘The assessment must have been completed by @ public school/public school academy student, No scores from private school or home schooled students are included. ‘The assessment must have been completed by a student who has been determined to be Full ‘Academic Year (FAY). Scores from students who were enrolled for less than FAY will not be assigned to the feeder school. ‘The assessment must have been completed by a student who is not primarily educated by 2 Shared Educational Entity (SEE). Thus, scores from SEE students are not included. The Student Growth Percentile must be for a student who has been determined to be Full ‘Academic Year (FAY). ‘The Student Growth Percentile must be for @ student who is not primarily educated by a Shared Educational Entity (SEE). In order to be included in a schoo'’s overall Bottom Five Percent calculation, at least 30 FAY students must have been tested each year in the same subject for two consecutive years. ‘student Growth Percentiles are included in the subject value only if at least 20 FAY students have SGP values. Graduation Rate In order to be included as part of a school’s Bottom Five Percent calculation The school must graduate students. ‘The school has graduation rates calculated by CEPI for each of the two most recent years. ‘The graduation rate used is the best rate among two averages among the four five-, or si-year cohort rates. STATE SCHOOL REFORM / REDESIGN OFFICE, 9/1/2016 6 of 13,Schoo! Lowest Achieving 5% Business Rules {In order to be included in the list, 2 school must meet the following eligibility requirements: ‘Must have at least 30 FAY students, in at least two different two subjects, for the two most recent school years. Center-Based Programs are not eligible for inclusion in the Bottom Five Percent list. Center Based Program are schools that serve exclusively special education populations as determined by the Michigan Department of Education, Shared Educational Entitys (SEE) are not eligible for inclusion in the Bottom Five Percent calculation. All schools open as of June 30, 2015 and also which have data attributed from the most recent school year, will be included in the Bottom Five Percent calculations, even if the school is closed at the time of the release of the Bottom Five Percent lst. Final percentile ranks are only provided for to schools with rank 0, 1, 2, 3, of 4; or those schools currently under the authority of the State School Reform/Redesign Office. STATE SCHOOL REFORM / REDESIGN OFFICE, 9/1/2016 70f 13Lowest Achieving 5% Business Rules Calculation Methodology This procedure uses student Z-Scores, Student Growth Percentiles, and Full Acader Year (FAY) determinations that are maintained by the Michigan Department of Education (MDE) and are available for use by the State School Reform/Redesign Office in a database format. Calculation Conventions '¢ The definitive version of all calculations is based upon mathematical operations as performed by SAS Enterprise Guide 5.1. * According to the MDE, student Z-Scores satisfy three conditions: (1) calculated for FAY students only; (2) have a van der Waerdens transformation applied to put them into a more nearly- normal distribution; (3) are capped at a maximum of +2 and a minimum of -2. © Overall school percentile ranks are truncated to the integer level (the decimal portion is deleted and rounding is not completed.) ‘© Schools with a close date on or after June 30 of the final year of accountability (2015) will receive a ranking. Schools with a closed date prior to June 30 of the final year of accountability (2015) do not receive a rank. Initial student score aggregation. Calculate the following aggregates, split out by year, school, and subject: The count of FAY students with valid test scores. The mean of the Z-Scores of FAY students The mean of available SGPs of FAY students (MGP).. The percent proficient of FAY students. Subject-level table, Create a row for each subject in schools and indicating (including each value for the current and previous year}. ‘The count of FAY tested scores. The mean Z-Score. The MGp. The percent proficient. Subject-level calculations 2. Determine subject eligibility for achievement using the subject eligibility rules outlined above (ie, the value calculated in Ia above is greater than or equal 30 in each of the last two years). STATE SCHOOL REFORM / REDESIGN OFFICE, 9/1/2016 of 13,Lowest Achieving 5% Business Rules b. Calculate the total number of FAY tested for both years by summing both years of the number calculated in section 1.2. above that meet the minimum FAY count of 30. ©. Calculate the weighted (on student count) two-year averages for Ib, he, hd. i. Each calculation will take the form of: Walourrene * FA¥current) + Walprion * CAYeurrene + FAY prior) AYorior Where ‘Val’ is the value of interest, ‘FAY’ is the count of Full-Academic-Vear tested students, and ‘Current’ and ‘Prior’ refer to each of the two years of assessment results to be used in the application of the Bottom Five Percent lst. d. Calculate the Z-Score for each of the two-year averages: i. Calculate the statewide average and standard deviation for mean achievement (2- scores} and MGP, using only eligible subjects as described above in section Ilha Calculate the achievement and growth school Z-Scores for each subject using the following formula: i) (Aes Where fi,; is the two-year weighted statewide average of the value of interest for school j fig is the statewide average, and 6, is the statewide standard deviation. ©. Combine the achievement and growth Z-Scores into the subject index, based upon: i. Ifthe two-year weighted percent proficient is greater than or equal to 90%, or if growth is not available, use only the achievement score. ii, Otherwise, compute a value using half (50%) achievement and half (50%) growth. f. Caleulate the weighting of each subject in the final score based upon the number of student scores: i, Sum the total number of tests taken by eligible students in al eligible subjects. ji, The subject weight is ny Where n, is the count of tests taken by eligible students in the eligible subject and n, is the total number of tests taken by eligible students across all eligible subjects. &. Calculate the subject index -Score for each eligible subject: \. Determine the statewide average and standard deviation for the subject index, using only eligible subjects as described above ii, Calculate the subject 2-Score for each subject using the following formula (iy = bs) ‘Where fi, is the two-year weighted average of the subject index for school j, fiz is the statewide average, and dz isthe statewide standard deviation h. Greate final subject index values by applying the subject weight from section If. by multolying the subject 2Score section lt.) by the subject weight. STATE SCHOOL REFORM / REDESIGN OFFICE, 9 90f 13Lowest Achieving 5% Business Rules IV, Graduation rate calculations 1a. Determine graduation rate eligibility. b. Use the graduation rates for schools as calculated by CEP i. For each school, retrieve the graduation rate for years (n-1) to (n-5) where n is the current school year. Because the graduation rate is offset by a year, the most recent rate will be from the year prior to the current Bottom Five Percent calculation. li, Incases where a school has multiple graduation rate records (schools that have changed districts), only the rates that matches the current district code as recorded in CEPI's Education Entity Master are used. iii, Use only graduation rate records for the All Students group. iv. Retrieve graduation rates for the 4-, S-, and 6-year cohorts, where data is available. v. Only include graduation rates that have been calculated by CEPI. c. For each set of cohorts records in each school, calculate the following (these cohort means are unweighte i. The mean of the graduation rates for four years. ji, The mean of the “academic year id” value for four years. iil, The mean of the graduation rates for three years. iv. The mean of the “academic year id” value for three years. v. The mean of the graduation rates for two years. vi. The change in graduation rate between years (n-2) to (n-1}. d. Calculate improvement slopes for available rates from section IV.b. The improvement slope formula is: L@-H+0-7) Le Where x is the academic year id value, vis the graduation rate value, and @ and Fare the multi-year means of each, respectively. fe. Calculate the Z-Score for each graduation rate metric, for all cohorts, for all eligible schools. i. Determine the statewide average and standard deviation for 1) the four-year improvement slope; 2) the three-year improvement slope; 3) the two-year change; 4) the two-year mean graduation rate; and 5) the most recent graduation rate, Calculate the Z-Score for each metric using the following formula: (Gay = ite”) a” Where fgjis the two-year weighted average of the metric of interest for schoo! is the statewide average of the four-year cohort, and fi,” is the standard deviation of the four- year cohort. Note: 2-Scores for five- and six-year cohorts are calculated using the statewide mean and statewide standard deviation from the four-year cohort, STATE SCHOOL REFORM / REDESIGN OFFICE, 9/1/2016 10 of 13Lowest Achieving 5% Business Rules f. Determine the best cohort graduation rate: i. Determine which of the three cohorts (four, five-, or six-year) has the highest two-year mean graduation percentage rate. li, The graduation rate index calculated in section IV.e. that corresponds to this best” cohort rate will be used. iil, Likewise, the graduation rate improvement index calculated in section IV.e. that corresponds to this cohort will used. That is, the graduation rate improvement rate used will correspond with the graduation rate (4-, S-, or 6-year cohort) used. ‘Note: The improvement index that corresponds to the highest two-year mean graduation rate will be used, even if the overall index is not the highest value among the cohorts. & Calculate the graduation rate index: i. Ifthe two-year mean graduation rate is greater than or equal to 90%, use the only 2- Score of the two-year mean graduation rate calculated in section fi, li, Otherwise, calculate a composite value using the Z-Scores calculated in section f.i and fll, composed of: 1, Two-thirds (2/3) of the two-year mean graduation rate. 2. One-third (1/3) of the graduation rate improvement metric ~ preferentially use the four-year improvement slope; the three-year improvement slope; the two- year change, as available. fh, Calculate the 2-Score for the final graduation rate index for eligible schools: Determine the statewide average and standard deviation for the graduation rate index. Calculate the Z-Score for each metric using the following formula (Aj - te”) a Where fiz; is the graduation rate index for school j,ji,"” is the statewide average graduation rate index, and i,” is the statewide standard deviation of the graduation rate index. \V. School-level calculations 2. Determine school eligibility using the school eligibility rules outlined above in section Il. Calculate the overall combined performance index: i, Sum the weighted values (section Ill.h.) of each eligible subject performance index for each eligible school, ji, For schools that have a graduation rate Z-Score calculated in section IV.h., include the graduation rate index as 10% of the combined performance index, with the weighted subjects making up the remaining 90%. Rank the schools on the combined performance index, with a rank of 1 corresponding to the highest index valve d. Convert the ranking into a percentile rank; /2006 of 13 STATE SCHOOL REFORM / REDESIGN OFFICE,Lowest Achieving 5% Business Rules i. Provide schoo! percentile rankings that meet the following requirements: ‘a. Schools with rank 0, 1, 2,3,0r4 b, Schools currently under the authority of the State Schoo! Reform/Redesign Office. ii, Use the following formula: R 100 + R Where Ris the maximum rank value obtained in section V.c. and r; is the ranking of school jfrom section V.c. iii, Truncate any decimals, Note that this is not a rounding function; discard any decimals, leaving only the whole number. STATE SCHOOL REFORM / REDESIGN OFFICE, 9/1/2016 12 0f 13Lowest Achieving 5% Business Rules Resource Information MoE CEPI FAY SGP, MGP ELA MEAP Mme step SEE act 2Score MEAP-Access MlAccess Michigan Department of Education, www.michigan.gow/mde Center for Educational Performance and Information, www.michizan gov/cepi Full Academic Year Students, www. michigan gov/documents/mde/Full Academic Year Business Rules 516581 7.odf Student Growth Percentiles and Mean (Student) Growth Percentiles ws. michigan gov/documents/mde/Student Growth Percentiles 475671 7.pdt English Language Arts, www michigan,gov/mde/0,4615, Michigan Educational Assessment Program, used up to the 2013-14 school year sw michigan gov/meap Michigan Merit Examination, used up to the 2013-14 school year www.nichigan.gov/mme Michigan Student Test of Educational Progress, begun in the 2014-15 school year www.michigan gov/mstey 28753 6a Shared Educational Entity, aww michigan.gow/mde/0,4615,7-140-22709 §6877---,00.html ACT College Readiness Assessment, www michigan gov/mde/0,4635,7-140-22709 35150---,00.html Z Score methodology for assessments, ww michigan nov/documents/mde/2-5: Shes 72605 7 394088 7.ppt An alternative Assessment formerly used by MDE, wow michigan gov/mde/0,1607,7-140-22709 28463-20674. Michigan’s current alternative assessment system for individuals with disabilities, www michigan gov/mde/0,1607,7-140-22709 28463.--,00.html Graduation Rate Definition of and how to Improve graduation rates, Center Based wow 2.ed.gou/documents/college-completion/oractical retention-and-praduation-rates.doc Program Center Based Model as used in Special Education wwey.michigan gow/documents/mde/Center-based Model 408832 7.odf STATE SCHOOL REFORM / REDESIGN OFFICE, 9/1/2016 13 0f 13EXHIBIT 16MICHIGAN v= Kducation Top-to-Bottom School Rankings and Reward School Identification Business Rules Accountability Services | Last Updated: 12/12/2016Summary of Changes | ‘tor | vot ‘Managerial | Version Date Author/Editor pti Jerson tor Description ao [Draft [10/24/2016 | Matt Gleason _| Initial Document Created/Updated | “Final //42/15/2016 | Matt Gleason and] ‘Accountability Services Last Updated: 12/12/2016Table of Contents ‘Summary of Changes. Top-to-Bottom School Ranking and Reward School Identification Business Rules. Overview Narrative Description Eligibility Rules. Score eligibility rules Subject eligibility rules School eligibility rules... Graduation Rate eligibility rules... Accountability Services Last Updated: 12/12/2016Top-to-Bottom School Ranking and Reward School Identification Business Rules Overview The Michigan School Accountability School Ranking is alist of schools rank ordered by a combined performance metric. The ranking is based on student achievement and student growth. All tested subjects are included, and for schools that graduate students, graduation rate is also included as a ‘component. All public schools that meet the selection criteria are rank ordered to create the School Ranking list Schools must meet @ minimum size restriction and certain schools that serve specialized populations of students will be excluded. Please see school eligibility rules below for more details. School-level values are calculated by aggregating student performance on statewide tests, including general assessments and those based on alternate standards. All valid tests are included, provided that students are eligible for being included in accountability. Please see score eligibility rules below for more details, Subjects are academic content areas that are tested on standardized state tests. For purposes of the School Ranking, subjects taught at the presecondary (elementary/middle school) and secondary (high school) levels are treated as distinct. The subjects tested in years prior to 2014-15 were reading, mathematics, science, social studies, and writing. The subjects tested beginning in 2014-15 are English Language Arts (ELA), mathematics, science, and social studies. A small school may have as few as two subjects (for instance, a K-3 school may have only math and ELA at the elementary/middle level) while 2 larger school may have up to 8 (e.g, a large K-12 building may have math, ELA, science, and social studies at both elementary/middle and high school level}. For purposes of this document, the term subject's considered to refer to a given content area and the grade level at which itis taught. Thus, "EM Math’ is a distinct subject from “HS Math.” Schools indicates as Reward Schools are schools that have either 1) been ranked in the top 5% (at or above the 94" percentile); 2) ranked in the top 5% of 2 composite student growth index; 3) scored at least 85% proficient in all applicable subjects and have a positive proficiency improvement rate, Reward schools will be identified for the 2015-16 school year. Narrative Description ‘The School Ranking lists generated through a series of aggregations and rankings. First, subject test scores forall eligible students (see score eligibility rules below for more details) are converted into Z- ‘Scores (Help with Z-scores*), so that all scaled scores (and points, for some tests) are transformed into a * Go to wuw.michigan gov/ttb and click on the Help with Z-Scores under the Support and Documentation section Accountability Services Last Updated: 12/12/2016value indicating the distance from the statewide mean. These Z-Scores are then aggregated at the building level to create an achievement score for each applicable subject. At the same time, students who have a valid Student Growth Percentile (What is a Student Growth Percentile2”) are aggregated to create an overall growth score for each applicable subject. Next, the aggregsted subject achievement and growth scores are converted into 2-Scores and compared against all other eligible buildings to put each building's score value on the same scale. These are then + Happy valley Schoo has: ea otal test ven eros al grades /sblens ue 2H studenten tested + Relative weight for FAY tested are: en 33.3% (20/600) STEN ROARS Figure 1 = Example combined (with weights of 50% achievement and 50% growth; if growth is not available, then achievement alone will be used) to create a subject score. Subject scores are once again converted into, Z-Scores against the statewide average, then ‘combined into a building score. The number of students tested in each subject is used as a ‘weighting factor for that subject when the building, score is calculated (See Figure 1 - Example). For buildings that graduate students, a graduation rate index is also caleulated, which counts for 10% of the overall building score, with the remaining 90% divided among the appropriate subjects. Buildings are then ranked by their overall building score. The ranking is converted into a percentile rank, which is the final School Ranking value reported. ® Go to wanw michigan gov/ba-accountability and click on the What is Student Growth Percentile under the Resources for Educators. Accountability Services Last Updated: 12/12/2016Eligibility Rules Score eligibility rules In order to be included in the overall Schoo! Ranking calculation, a score must meet several requirements ‘© It must be from a general or alternate summative assessment. English Language Proficiency assessments, while valid for participation credit in certain circumstances, do not count toward achievement on the Schoo! Ranking. MEAP, MI-Access, MEAP-Access, MME, and M-STEP have all counted for School Ranking purposes. ‘© The score must be valid (ie., all rules for completing a test must be met; there must be no prohibited behavior, misadministration of test, etc.) ‘+ The test must have been completed by a public school/public school academy student. No scores from private school or home schooled students are included. ‘* The test must have been completed by a student who has attended the school for a Full ‘Academic Year (FAY). Scores from students who were enrolled for less than FAY will not be assigned to the school. ‘©The test must have been completed by a student who is not primarily educated by a Shared Educational Entity (SEE). Scores from SEE students are not included, ‘© The rules used for determining whether a score is eligible for inclusion are the same as those used for the Accountability Scorecard. Scores are attributed to the school designated as the Feeder school. In general terms, this is the schoo! where the student was enrolled and the school responsible for teaching the content standards being assessed on the test. (Business rules for the Full Academic Year Students*) Subject eligibility rules In order to be included in a schoots overall School Ranking, at least 30 FAY students must have been tested in the subject. In order to be included in the growth component of the subject index score, at least 20 FAY students must have SGP values. School eligibility rules In order to be included in the ranking, a school must meet the following eligibility requirements: © Must have at least 30 FAY students, in two subjects, for the two most recent school years. The subjects need not necessarily be the same in both years, but there must be at least two. © Must not be identified as @ Center-Based Program serving exclusively special education populations. CBP’s (buildings with 100% SE enrollment) are not eligible for ranking, > htpi//wnvw.michigan.gov/documents/mde/2015_Full Academic Year Business Rules_478768_7.pdf Accountability Services Last Updated: 12/12/2016