Chartiers Valley Joint Schools v. County Board of School Directors of Allegheny County

In Chartiers Valley Joint Schools v. County Board of School Directors of Allegheny County, 418 Pa. 520, 529, 211 A.2d 487, 493 (1965), school districts and taxpayers challenged what was commonly known as the "School Reorganization Act of 1963" (Act of August 8, 1963, P.L. 564, as amended, 24 P.S. 2-202) on the ground that it unconstitutionally delegated legislative authority to the State Board of Education. With respect to whether the School Reorganization Act of 1963 contained sufficient guidelines and limitations on the authority granted to the State Board of Education, the Supreme Court stated: More specifically, in Section 293, which, inter alia, provides that the Council of Basic Education is to approve such organization plans "as it deems wise", the Act is most specific in revealing its purpose and the results which the Legislature sought to accomplish. The Section sets up two bases for approval by the Council of Basic Education, one primarily within the discretion and judgment of the Council and the other essentially mandatory if specified conditions exist. Both these bases reflect the primary legislative objective of reorganization in the direction of fewer and larger units. The "mandatory" approval requirement is only applicable under conditions explicitly barring any reduction in the size of individual administrative units or any increase in the total number of units. The "discretionary" approval provision is even more explicit in setting forth the Legislature's norm as to the minimum appropriate size of a school district for efficient and effective education under ordinary conditions. No plan is to be approved in which any proposed school district contains "a pupil population of less than four thousand (4,000)" unless unusual, special factors require it. To achieve the Legislature's announced objectives, the Act establishes a detailed procedure which utilizes local school officials and other experts in the field of education at various local, district, and county levels in the review and final approval of reorganization plans as well as in the initial formulation of those plans. That procedure makes it clear that the legislative objective embodied in the Act is the prompt and expeditious reorganization of the Commonwealth's public school system in order to accomplish fewer and larger administrative units. Chartiers Valley, 418 Pa. at 531-32, 211 A.2d at 493-94.