Board of Education of the Township of Neptune, Monmouth County v. Neptune Township Education Association, 5/30/25 (#281-25)

281-25Njcommned

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281-25
OAL Dkt. No. 04135-24
Agency Dkt. No. 63-3/24
New Jersey Commissioner of Education
Final Decision
Board 	of 	Education 	of 	the 	Township 	of
Neptune, Monmouth County,
Petitioner,
v.
Neptune Township Education Association,
Respondent.
The record of this matter, the Initial Decision of the Office of Administrative Law (OAL),
the exceptions filed by petitioner Neptune Township Board of Education (Board) pursuant to
N.J.A.C. 	1:1-18.4, 	and the 	replies 	thereto 	by 	respondent 	Neptune Township 	Education
Association (Association) and participant New Jersey Public Employment Relations Commission
(PERC) have been reviewed and considered.
This matter involves the Board’s removal of an employee, Thomasina Savage, for failing
to report to work after exhausting her leave time. The Association filed a grievance on Savage’s
behalf, alleging that the Board violated the parties’ collective negotiations agreement (CNA) by
denying Savage’s request for an extended unpaid leave of absence and terminating her
employment. The Board denied the grievance, and the Association filed an arbitration request
with PERC. The Board requested that PERC make a “scope of negotiations” determination and
restrain arbitration of the grievance. PERC issued a decision in December 2023, determining that
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the grievance is legally arbitrable and denying the Board’s request. In the Matter of Neptune
Twp. Bd. of Educ. and Neptune Twp. Ed. Ass’n, PERC Dkt. No. SN-2024-014 (Dec. 14, 2023). The
Board did not appeal PERC’s decision to the Appellate Division of the Superior Court.
In March 2024, the Board filed the petition of appeal with the Commissioner that is at
issue herein, challenging PERC’s determination as a usurpation of the Commissioner’s jurisdiction
over N.J.S.A. 18A:30-6, which deals with prolonged absences that exceed an employee’s annual
and accumulated sick leave. 	The Association filed a motion to dismiss, and PERC, which was
granted permission to participate in the matter, filed briefs in support of the Association’s
motion.
The Administrative Law Judge (ALJ) found that PERC has exclusive jurisdiction to make
scope of negotiations determinations, and that such decisions by PERC are appealable only to the
Appellate Division. 	The ALJ concluded that the Board’s petition, in essence, appealed PERC’s
decision to the Commissioner, which is not permissible because the Commissioner does not have
jurisdiction over an appeal of a decision by PERC and cannot grant the relief the Board seeks in
the form of an order overturning PERC’s decision or an order restraining arbitration between the
Board and the Association. The ALJ noted that a long line of cases affords PERC the authority to
interpret statutes outside of its jurisdiction – including Title 18A – in reaching its scope of
negotiations determinations. The ALJ also found that the Board fully litigated the N.J.S.A. 18A:30-
6 issue before PERC, and is prohibited by the doctrine of collateral estoppel from relitigating that
issue before the Commissioner. Finally, the ALJ held that the principles regarding predominant
interest determinations – which apply when two agencies transmit similar issues to the OAL – do
not apply to this matter, because PERC did not transmit any case to the OAL, and does not
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transmit scope of negotiations determinations to the OAL as contested cases. Accordingly, the
ALJ dismissed the petition.
In its exceptions, the Board argues that the ALJ erred by “unilaterally assuming that PERC
has exclusive jurisdiction over the dispute, without properly considering the risk that critical
educational interests may be mishandled.” 	According to the Board, the Commissioner has
jurisdiction and is in the best position to adjudicate this matter, because it involves interpretation
of a school law statute. The Board also contends that the ALJ failed to apply the consolidation
and predominant interest factors under N.J.A.C. 1:1-17.5(a), and that those factors weigh in favor
of the Commissioner exercising jurisdiction. The Board argues that the ALJ erroneously found
that PERC could not rule in the Board’s favor without construing Title 18A; the Board believes
that PERC could have decided the dispute under the CNA alone, without resorting to statutory
interpretation, or could have ruled on the labor law aspects of the dispute while deferring school
law interpretations to the Commissioner. 	Finally, the Board contends that the principle of
collateral estoppel cannot bar its petition because PERC is not the tribunal with competent
jurisdiction and, therefore, the Board has not had the opportunity to fully litigate the school law
issue.
In response, the Association argues that the ALJ properly found that the Commissioner
cannot grant the relief sought by the Board, as the Commissioner cannot make or overturn a
scope of negotiations determination or restrain a labor arbitration. The Association notes that
the Board had recourse to the Appellate Division if it was dissatisfied with PERC’s decision, but
the Board failed to file an appeal. 	The Association contends that PERC is required to interpret
other statutes in making a scope of negotiations determination, in order to determine whether
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a subject is preempted; in fact, in the proceedings before PERC, the Board invited PERC to
interpret N.J.S.A. 18A:30-6 by claiming that the statute preempted the grievance. 	PERC’s
response to petitioner’s exceptions raises similar points, and adds that the Appellate Division has
previously held that scope of negotiations proceedings that involve an interpretation of school
law do not invoke the Commissioner’s jurisdiction.
Upon review, the Commissioner concurs with the ALJ that the petition must be dismissed
because the Board has failed to state a claim on which the Commissioner may grant relief. The
petition specifically requests as relief an order “setting aside the Decision of [PERC]” and an order
“restraining the arbitration.” As the ALJ concluded, the Commissioner does not have jurisdiction
to do either of these things. 	PERC’s decision in this matter was appealable to the Appellate
Division, and it can only be reversed by that court; there is no provision in administrative law
allowing one State agency to “set aside” the decision of another. The Commissioner also notes
that the Board cites no legal authority for the proposition that the Commissioner can restrain a
labor arbitration proceeding. Furthermore, an order restraining the arbitration is precisely the
relief that the Board sought before PERC, and which PERC denied, making this request
functionally a request to set aside PERC’s decision. Additionally, the Board seeks an order “in
which the Commissioner of Education assumes jurisdiction of the underlying dispute and
interpretation of N.J.S.A. 18A:30-6.” 	But once again, PERC has already determined that this
matter falls within its jurisdiction, making this request merely a re-worded version of the Board’s
other requests to set aside PERC’s decision.
In the PERC matter, the Board made essentially the same argument that it makes here –
that N.J.S.A. 18A:30-6 preempts negotiations. 	PERC found that it did not, reasoning that the
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grievance sought an unpaid leave of absence, while N.J.S.A. 18A:30-6 addresses the salary of an
employee who exhausts all accumulated sick leave. PERC Decision, at 9-10.1 The New Jersey
Supreme Court has made clear that PERC’s expertise can and should be applied to interpret
various statutes:
In carrying out its duties, PERC will at times be required to interpret statutes other
than the Employer-Employee Relations Act. Indeed, in no other way could that
body implement our holding . . . that the terms of a collective agreement cannot
contravene a specific legislative enactment. To therefore hold that PERC is ousted
of jurisdiction in any controversy involving an asserted conflict between a
collective agreement and a statute not part of the Employer-Employee Relations
Act would deprive our courts of that body’s expertise in a large class of scope of
negotiations disputes. . . . Consequently, we conclude that PERC’s primary
jurisdiction does extend to controversies involving asserted conflicts between the
Employer-Employee Relations Act and other statutory schemes.
Bd. of Educ. of the Twp. of Bernards v. Bernards Twp. Ed. Ass’n, 79 N.J. 311, 316-17 (1979).
Notably, the Bernards matter also involved an interpretation of a provision of Title 18A.
The issues presented by the Board in this matter fall squarely within PERC’s authority, as
defined by the Supreme Court, and the Commissioner concludes that there is no basis to exercise
jurisdiction over these issues. 	For the same reason, petitioner’s argument that collateral
estoppel cannot bar its claim because PERC is not the tribunal with competent jurisdiction is
rejected. Additionally, petitioner’s argument regarding consolidation and predominant interest
is rejected. As the ALJ found, there was only one case transmitted to the OAL, so the regulations
regarding consolidation and predominant interest are inapplicable.
1 PERC also found that Savage’s termination was disciplinary in nature, making it subject to arbitration
pursuant to N.J.S.A. 34:13A-29. The Board does not suggest that the Commissioner has jurisdiction to
construe Title 34.
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Accordingly, the Initial Decision is adopted as the final decision in this matter, and the
petition of appeal is hereby dismissed.
IT IS SO ORDERED.2
COMMISSIONER OF EDUCATION
Date of Decision: 	May 30, 2025
Date of Mailing: 	June 2, 2025
2 This decision may be appealed to the Appellate Division of the Superior Court pursuant to N.J.S.A. 18A:6-
9.1. Under N.J.Ct.R. 2:4-1(b), a notice of appeal must be filed with the Appellate Division within 45 days
from the date of mailing of this decision.
New Jersey is an Equal Opportunity Employer
State of New Jersey
OFFICE OF ADMINISTRATIVE LAW
INITIAL DECISION
SUMMARY DECISION
OAL DKT. NO. EDU 04135-24
AGENCY DKT. NO. 63-3/24
NEPTUNE TOWNSHIP
BOARD OF EDUCATION,
Petitioner,
v.
NEPTUNE TOWNSHIP
EDUCATION ASSOCIATION,
Respondent.
Stephen J. Edelstein, Esq., for petitioner (Weiner Law Group, LLP, attorneys)
Keith Waldman, Esq., for respondent (Selikoff and Cohen, P.A., attorneys)
William J. Campbell, IV, Esq., for other participant, New Jersey Public
Employment Relations Commission (Christine Lucarelli-Carneiro, General
Counsel)
Record Closed: February 25, 2025 Decided: March 19, 2025
BEFORE DEAN J. BUONO, ALJ:
OAL DKT. NO. EDU 04135-24
2
STATEMENT OF THE CASE AND PROCEDURAL HISTORY
Petitioner Neptune Township Board of Education (Board) seeks to challenge by
way of a petition of appeal to the Commissioner of Education (Commissioner) a
determination by the Public Employment Relations Commission (PERC) concluding that
a grievance filed by respondent Neptune Township Education Association (Association)
on behalf of a former Board employee who was terminated for failing to return to work
after she exhausted her leave time is legally arbitrable under a collective negotiations
agreement (CNA) and not governed by school law.
The Board contends that PERC usurped the Commissioner’s jurisdiction over the
school laws by concluding that N.J.S.A. 18A:30-6, under which a school board may pay
an employee for prolonged absences beyond her available sick leave, did not preempt
collective bargaining over extended unpaid leaves of absence. The Board asks the
Commissioner to overturn PERC’s decision, assume jurisdiction over the dispute under
N.J.S.A. 18A:30-6, and issue an order restraining arbitration of the grievance.
In response to the Board’s petition of appeal, the Association filed a motion to
dismiss in lieu of an answer due to the Board’s failure to state a claim upon which relief
may be granted. The Association asserts that the Commissioner does not have
jurisdiction over the employment dispute, the petition is barred under the entire
controversy or collateral estoppel doctrine, and the Commissioner does not have the
authority to reverse a final decision by another agency. PERC has submitted a brief in
support of the Association’s motion.
For the reasons argued by the Association and PERC in their briefs, the
Association’s motion must be granted, and the Board’s petition must be dismissed.
FACTUAL DISCUSSION
In March 2023, the Board removed from employment a longtime
paraprofessional, Thomasina Savage, for failing to report to work after exhausting her
leave time. In response, the Association, of which Savage is a member, filed a
OAL DKT. NO. EDU 04135-24
3
grievance alleging that the Board violated the parties’ CNA by denying Savage’s request
for an extended unpaid leave of absence and terminating her employment.
After the Board denied the grievance, the Association filed an arbitration request
with PERC under N.J.S.A. 34:13A-29. The Board countered by asking PERC to make a
“scope of negotiations” determination under N.J.S.A. 34:13A-5.4(d) and N.J.A.C. 19:13-
1.1 and restrain arbitration of the grievance filed by the Association.
The Board argued in part that “its decision not to extend [Savage’s] unpaid leave
of absence was a non-negotiable exercise of its statutorily compelled discretion
pursuant to N.J.S.A. 18A:30-6,” which “preempts any negotiated rule on extended
leaves of absence and instead [the Board] must make those determinations on a case-
by-case basis.”1
On December 14, 2023, PERC issued a written decision denying the Board’s
request and determining that the grievance is legally arbitrable. In doing so, PERC
concluded that “N.J.S.A. 18A:30-6 addresses the salary of an employee who exhausts
all accumulated sick leave” and “does not ‘expressly, specifically and comprehensively’
preempt the issue of [Savage’s] request for an extended unpaid leave of absence.”
Thus, “[t]he statute does not address the Board’s individual discretion when determining
whether or not to extend an unpaid absence after the exhaustion of sick leave,” and that
issue is legally arbitrable under the parties’ CNA.
The Board did not appeal PERC’s determination to the Appellate Division as
provided under N.J.S.A. 34:13A-5.4(d). Instead, in March 2024, the Board filed with the
1 Under N.J.S.A. 18A:30-6:
When absence, under the circumstances described in section 18A:30-1
of this article, exceeds the annual sick leave and the accumulated sick
leave, the board of education may pay any such person each day’s
salary less the pay of a substitute, if a substitute is employed or the
estimated cost of the employment of a substitute if none is employed, for
such length of time as may be determined by the board of education in
each individual case. A day’s salary is defined as 1/200 of the annual
salary.
[Ibid.]
OAL DKT. NO. EDU 04135-24
4
Commissioner a petition of appeal challenging PERC’s determination as a usurpation of
the Board’s authority under, and the Commissioner’s jurisdiction over, N.J.S.A. 18A:30-
6.
The Association responded by filing with the Commissioner a motion to dismiss
the Board’s petition in lieu of an answer under N.J.A.C. 6A:3-1.5(g) and N.J.A.C. 6A:3-
1.10. The Commissioner subsequently transmitted the Board’s petition and the
Association’s motion to the Office of Administrative Law (OAL) as a contested case
under the Administrative Procedure Act, N.J.S.A. 52:14B-1 to -15, the act establishing
the OAL, N.J.S.A. 52:14F-1 to -23, and the Uniform Administrative Procedure Rules
(UAPR), N.J.A.C. 1:1-1.1 to -21.6. The record was reopened to conduct a status
conference call with the parties on February 25, 2025, at that time the record closed.
The Association’s Motion to Dismiss
The Association argues that the Board’s petition must be dismissed for these
reasons: (1) the Commissioner does not have jurisdiction because “the present matter
is not a dispute arising under the school laws” but “a contractual dispute arising under
the parties’ [CNA]”; (2) the petition is barred under the entire controversy or collateral
estoppel doctrine because the Board fully litigated its claim under N.J.S.A. 18A:30-6
before PERC; and (3) the Commissioner cannot grant the Board’s requested relief in
the form of overturning a final decision by another agency.
PERC, which is not a party in this case, supports the Association’s motion.
According to the agency, “PERC issued a decision that determined the grievance
involved in this case could proceed to arbitration” and “PERC, and only PERC, has
exclusive jurisdiction to make this arbitrability determination.” PERC’s arbitrability
determination is appealable to the Appellate Division under N.J.S.A. 34:13A-5.4(d), and
not the Commissioner of Education, even if PERC’s decision involved an interpretation
of a school law. As such, the Board’s petition must be dismissed.
In opposition, the Board argues that its petition is properly before the
Commissioner due to that agency head’s primary jurisdiction over the school laws,
OAL DKT. NO. EDU 04135-24
5
including N.J.S.A. 18A:30-6. In the Board’s view, the Commissioner, and not PERC,
has the authority to interpret N.J.S.A. 18A:30-6.
The Board cites N.J.A.C. 1:1-17.5, which governs predominant interest
determinations when consolidated contested cases before the OAL involve multiple
agencies, for the proposition that the Commissioner has the predominant interest over
this dispute, that the “scope of negotiations” issue is separate and severable from the
N.J.S.A. 18A:30-6 issue, and that the Board is not asking the Commissioner “to rule on
the negotiability of the cessation of Ms. Savage’s employment, but only on the scope of
a board of education’s discretion to grant or deny an extended unpaid leave of absence
under [N.J.S.A. 18A:30-6].”
LEGAL ARGUMENT AND CONCLUSION
The rules of procedure governing petitions of appeal filed with the Commissioner
permit a respondent to submit a motion to dismiss in lieu of an answer “on the grounds
that the petitioner has advanced no cause of action even if the petitioner’s factual
allegations are accepted as true or for lack of jurisdiction, failure to prosecute, or other
good reason.” N.J.A.C. 6A:3-1.5(g); N.J.A.C. 6A:3-1.10. However, these education
rules do not offer any guidance on the standards by which such motions should be
assessed.
The UAPR also do not include such standards but provide that, “[i]n the absence
of a rule, a judge may proceed in accordance with the New Jersey Court Rules,
provided the rules are compatible with” the UAPR, which are designed “to achieve just
results, simplicity in procedure, fairness in administration and the elimination of
unjustifiable expense and delay,” N.J.A.C. 1:1-1.3(a).
Here, the court rule that fills the void is R. 4:6-2, which, like N.J.A.C. 6A:3-1.5(g)
and N.J.A.C. 6A:3-1.10, allows for motions to dismiss. And since R. 4:6-2 serves the
interests of time and expense and may help achieve just results, it is compatible with
the UAPR’s purposes, and thus it is appropriate to assess the Association’s motion to
OAL DKT. NO. EDU 04135-24
6
dismiss in lieu of an answer under the standards used by the courts in applying R. 4:6-
2.
Under these standards, if the basis for a motion to dismiss is that the petition has
advanced no cause of action, or failed to state a claim upon which relief may be
granted, “the test for determining the adequacy of [the] pleading [is] whether a cause of
action is ‘suggested’ by the facts,” such that the “inquiry is limited to examining the legal
sufficiency of the facts alleged on the face of the complaint.” Printing Mart-Morristown v.
Sharp Elecs. Corp., 116 N.J. 739, 746 (1989) (citing R. 4:6-2(e); Velantzas v. Colgate-
Palmolive Co., 109 N.J. 189, 192 (1988); Rieder v. Dep’t of Transp., 221 N.J. Super.
547, 552 (App. Div. 1987)).
I. The Association’s motion must be granted, and the Board’s petition must
be dismissed, because the Board has failed to state a claim upon which the
Commissioner may grant relief.
For substantially the same reasons stated in the Association’s and PERC’s briefs,
the Board’s petition must be dismissed.
First, the Commissioner does not have jurisdiction over an appeal of a final
decision by PERC and cannot grant the relief the Board seeks in the form of an order
overturning PERC’s decision or an order restraining arbitration between the Board and
the Association. Simply put, this is not how administrative law works.
Under N.J.S.A. 34:13A-5.4(d), PERC has the exclusive jurisdiction over a public
employer’s request “to make a determination as to whether a matter in dispute is within
the scope of collective negotiations” and “[a]ny [such] determination made by [PERC] . .
. may be appealed to the Appellate Division of the Superior Court.” Ibid.
Here, the Board—a public employer—asked PERC to make a scope of
negotiations determination. And that is what PERC did, ruling that the employment
dispute between the Board and the Association was legally arbitrable under the CNA
and that the issue regarding extended unpaid leaves of absence was not preempted by
OAL DKT. NO. EDU 04135-24
7
N.J.S.A. 18A:30-6. Although dissatisfied with PERC’s determination, the Board did not
follow the statutory appeal procedure by appealing the determination to the Appellate
Division; instead, the Board, in essence, appealed PERC’s decision to the
Commissioner of Education because PERC’s decision implicated a school law over
which the Board contends the Commissioner has exclusive jurisdiction under N.J.S.A.
18A:6-9.
While it is true that, under N.J.S.A. 18A:6-9, the Commissioner “shall have
jurisdiction to hear and determine . . . all controversies and disputes arising under the
school laws,” this dispute arose under N.J.S.A. 34:13A-5.4(d), which is part of the New
Jersey Employer-Employee Relations Act, N.J.S.A. 34:13A-1 to -64, not the school
laws. Yes, PERC interpreted a school law—N.J.S.A. 18A:30-6—in reaching its scope of
negotiations determination. But as PERC rightly argues here, the courts have long held
that PERC is authorized “to interpret statutes outside of its jurisdiction, including Title
18A.”
Indeed, as the Supreme Court explained in Board of Education of the Township
of Bernards v. Bernards Township Education Ass’n, 79 N.J. 311 (1979), “PERC has
been designated by the Legislature as the forum for initial determination of scope of
negotiations matters because of its special expertise in this area.” Id. at 316 (citation
omitted). And “[i]n carrying out its duties, PERC will at times be required to interpret
statutes other than the Employer-Employee Relations Act.” Ibid. The Court remarked
that to “hold that PERC is ousted of jurisdiction in any controversy involving an asserted
conflict between a collective agreement and a statute not part of the Employer-
Employee Relations Act would deprive our courts of that body’s expertise in a large
class of scope of negotiations disputes.” Id. at 317. To avoid this unrealistic and
unwanted consequence, the Court held that “PERC’s primary jurisdiction does extend to
controversies involving asserted conflicts between the Employer-Employee Relations
Act and other statutory schemes.” Ibid.
In short, PERC, not the Commissioner, has jurisdiction over the dispute between
the Board and the Association despite the fact that PERC’s decision touched upon a
OAL DKT. NO. EDU 04135-24
8
school law. As such, the Board’s petition must be dismissed. The Board should have,
but did not, appeal PERC’s decision to the Appellate Division.
Another reason for dismissing the Board’s petition is that, as the Association
argues, the Board is attempting to relitigate before the Commissioner the N.J.S.A.
18A:30-6 issue that was conclusively decided by PERC, a legal maneuver that is
forbidden under the doctrine of collateral estoppel. That doctrine may be applied “in an
administrative case to preclude parties from relitigating issues that have previously been
fully litigated in another administrative proceeding.” 37 New Jersey Practice, Admin.
Law & Practice, § 6.27 (Steven L. Lefelt, Anthony Miragliotta & Patricia Prunty) (2d ed.
2000). Here, as the Association points out, the Board fully litigated the N.J.S.A. 18A:30-
6 issue in the PERC proceeding and, thus, cannot now relitigate that issue before the
Commissioner. Again, the Board could have filed—but did not—an appeal of PERC’s
determination concerning N.J.S.A. 18A:30-6 to the Appellate Division under N.J.S.A.
34:13A-5.4(d).
And contrary to the Board’s assertion, this dispute does not implicate the
administrative rules concerning consolidation and predominant interest under N.J.A.C.
1:1-17.1 to -17.8. Under those rules “an agency head, any party or the judge may move
to consolidate a case which has been transmitted to the Office of Administrative Law
with any other contested case involving common questions of fact or law between
identical parties or between any party to the filed case and any other person, entity or
agency.” N.J.A.C. 1:1-17.1. And “[w]hen a motion to consolidate pertains to contested
cases filed with two or more State agencies which are asserting jurisdiction, the judge
shall determine which agency, if any, has the predominant interest in the conduct and
outcome of the matter.” N.J.A.C. 1:1-17.5.
The problem with the Board’s reliance on or reference to the OAL’s consolidation
and predominant rules is that they do not apply here. Only one agency head—the
Commissioner of Education—transmitted a contested case to the OAL. PERC does not
transmit “scope of negotiations” determinations to the OAL for contested case hearings.
So, there are not two contested cases to consolidate or for which there needs to be a
predominant interest determination. Instead, once again, PERC issued a final decision
OAL DKT. NO. EDU 04135-24
9
on the Board’s scope of negotiations determination request, and that decision was
appealable to the Appellate Division and the Appellate Division only.
Having reviewed the parties’ submissions in support of and in opposition to the
within motion, I CONCLUDE that the motion papers in this case support the conclusion
that the Association’s motion to dismiss must be granted, and the Board’s petition must
be dismissed.
ORDER
It is therefore hereby ORDERED that the Neptune Township Education
Association’s motion must be granted, and the Neptune Township Board of Education’s
petition must be dismissed. It is FURTHER ORDERED that this appeal be
DISMISSED.
I hereby FILE this initial decision with the ACTING COMMISSIONER OF THE
DEPARTMENT OF EDUCATION for consideration.
This recommended decision may be adopted, modified, or rejected by the
ACTING COMMISSIONER OF THE DEPARTMENT OF EDUCATION, who by law is
authorized to make a final decision in this matter. If the Acting Commissioner of the
Department of Education does not adopt, modify, or reject this decision within forty-five
days and unless such time limit is otherwise extended, this recommended decision shall
become a final decision in accordance with N.J.S.A. 52:14B-10.
OAL DKT. NO. EDU 04135-24
10
Within thirteen days from the date on which this recommended decision was
mailed to the parties, any party may file written exceptions with the ACTING
COMMISSIONER OF THE DEPARTMENT OF EDUCATION. Exceptions may be
filed by email to ControversiesDisputesFilings@doe.nj.gov or by mail to Office of
Controversies and Disputes, 100 Riverview Plaza, 4th Floor, PO Box 500, Trenton,
New Jersey 08625-0500. A copy of any exceptions must be sent to the judge and to
the other parties.
March 19, 2025
DATE DEAN J. BUONO, ALJ
Date Received at Agency: March 19, 2025
Date Mailed to Parties: March 19, 2025
DJB/onl

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