Surendra Vallabhaneni v. Chari Chanley, Monroe Township Board of Education, Middlesex County, 3/8/2024, (#132-24SEC)

132-24SEC
New Jersey Commissioner of Education
Final Decision
Surendra Vallabhaneni,
Complainant,
v.
Chari Chanley, Monroe Township Board of
Education, Middlesex County,
Respondent.
Synopsis
Complainant alleged, inter alia, that respondent, the Superintendent of the Monroe Township
Board of Education, violated three sections of the School Ethics Act, N.J.S.A. 18A:12-21 et seq,
when she recommended the reappointment of her son to the position of substitute teacher in
the district. 	The School Ethics Commission (SEC) determined that the respondent’s actions
violated N.J.S.A. 18A:12-24(b) and N.J.S.A. 18A:12-24(c) of the Code of Ethics for School Board
Members and recommended a penalty of reprimand.
The case was forwarded to the Commissioner for final determination of the appropriate penalty
in this matter. Upon review, the Commissioner concurred with the penalty recommendation of
the SEC. 	Accordingly, the respondent shall be reprimanded as a school official found to have
violated the School Ethics Act.
This synopsis is not part of the Commissioner’s decision. It has been prepared for the convenience of
the reader. It has been neither reviewed nor approved by the Commissioner.

132-24SEC
SEC Dkt. No. C12-13
Agency Dkt. No. 15-1/24
New Jersey Commissioner of Education
Final Decision
Surendra Vallabhaneni,
Complainant,
v.
Chari Chanley, Monroe Township Board of
Education, Middlesex County,
Respondent.
The Commissioner has reviewed the record of this matter and the January 23, 2024
decision of the School Ethics Commission (Commission). The Commission found that
respondent Chari Chanley, Superintendent of the Monroe Township school district, violated
N.J.S.A. 18A:12-24(b) and N.J.S.A. 18A:12-24(c) of the School Ethics Act. The Commission
recommended a penalty of reprimand for the violation. The Commission’s decision was
forwarded to the Commissioner for final determination on the recommended penalty pursuant
to N.J.S.A. 18A:12-29(c). Respondent neither filed exceptions to the recommended penalty nor
instituted an appeal, pursuant to N.J.A.C. 6A:4-1 et seq., of the Commission’s underlying finding
of violation.
Upon review, the Commissioner concurs with the penalty recommended by the
Commission for respondent’s actions in recommending her son for reappointment in the
position of substitute teacher.

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Accordingly, respondent is hereby reprimanded as a school official found to have
violated the School Ethics Act.
IT IS SO ORDERED.1
ACTING COMMISSIONER OF EDUCATION
Date of Decision: March 8, 2024
Date of Mailing: March 8, 2024
1 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.

Before the School Ethics Commission
Docket No.: C12-23
Final Decision
Summary Disposition
Surendra Vallabhaneni,
Complainant
v.
Chari Chanley,
Monroe Township Board of Education, Middlesex County,
Respondent
I. 	Procedural History
The above-captioned matter arises from a Complaint that was filed on January 25, 2023,
by 	Surendra 	Vallabhaneni 	(Complainant), 	alleging 	that 	Chari 	Chanley 	(Respondent),
Superintendent of the Monroe Township Board of Education (Board), violated the School Ethics
Act (Act), N.J.S.A. 18A:12-21 et seq. More specifically, the Complaint avers that Respondent
violated N.J.S.A. 18A:12-24(a), N.J.S.A. 18A:12-24(b) and N.J.S.A. 18A:12-24(c) in Counts 1
and 2.
At its meeting on July 25, 2023, the Commission considered Respondent’s Motion to
Dismiss in Lieu of Answer (Motion to Dismiss) and Complainant’s response thereto. Following
its discussion on July 25, 2023, the Commission adopted a decision at its meeting on August 22,
2023, granting the Motion to Dismiss as to the alleged violations of N.J.S.A. 18A:12-24(a),
N.J.S.A. 18A:12-24(b) and N.J.S.A. 18A:12-24(c) in Count 2, and denying the Motion to Dismiss
as to the alleged violations of N.J.S.A. 18A:12-24(a), N.J.S.A. 18A:12-24(b) and N.J.S.A.
18A:12-24(c) in Count 1. Based on its decision, the Commission also directed Respondent to file
an Answer to Complaint (Answer) as to the remaining allegations, which she did on September
11, 2023.
At its meeting on October 17, 2023, the Commission considered the filings and, at its
meeting on November 28, 2023, the Commission adopted a decision finding probable cause does
not exist for the alleged violation of N.J.S.A. 18A:12-24(a) in Count 1, but finding probable
cause for the alleged violations of N.J.S.A. 18A:12-24(b) and N.J.S.A. 18A:12-24(c) in Count 1.
Additionally, in accordance with N.J.A.C. 6A:28-10.7(c)(1),1 the Commission voted to decide
the above-captioned matter by summary decision, and directed Respondent to file a statement
setting forth the reasons she should not be found in violation of the Act. Respondent was advised
that if she disputes any of the facts determined by the Commission to be both material and
1 The regulations cited in this decision refer to the regulations that were in effect at the time the
Complaint was filed on January 25, 2023.

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undisputed, she should set forth the facts with which she disagrees, and why they are material to
the case. Finally, Respondent was advised that the Commission may then make a determination
of a violation on a summary basis. Ultimately, on December 5, 2023, Respondent submitted a
Position Statement/Statement of Reasons (Statement of Reasons) as directed.
Consequently, at its meeting on December 19, 2023, the Commission reviewed the record
in this matter and, at its meeting on January 23, 2024, adopted a decision finding that
Respondent violated N.J.S.A. 18A:12-24(b) and N.J.S.A. 18A:12-24(c), and recommending a
penalty of reprimand for Respondent’s violation of the Act.
II. 	Summary of the Pleadings
A. 	Remaining Allegations in the Complaint
According to Complainant, Respondent became Acting Superintendent of the Monroe
Township School District (District) in 2021. Respondent’s husband works as a teacher in the
District and her son works in the District as a substitute teacher. Complainant alleges that after
becoming Acting Superintendent, Respondent “recommended and approved actions that affected
her husband’s compensation.” Complainant asserts, after members of the public expressed
concerns 	about 	Respondent’s 	conflict 	of 	interest, 	the 	Assistant 	Superintendent 	started
recommending actions involving Respondent’s husband’s employment, beginning on May 11,
2022. As such, Complainant avers that precautions were implemented to ensure Respondent was
not involved in matters related to her spouse’s employment.
In Count 1, Complainant further alleges at the Board meeting on August 17, 2022,
Respondent’s son appeared in an agenda item involving a list of substitute teachers, which
Respondent 	recommended 	rather 	than 	the 	Assistant 	Superintendent. 	Complainant 	asserts
Respondent’s conduct on August 17, 2022, violated N.J.S.A. 18A:12-24(b) and N.J.S.A. 18A:12-
24(c) when she recommended her son 	for the position of substitute teacher, as school
administrators 	“should 	not 	be involved 	in 	recommendations, 	discussions, 	or 	negotiations
regarding employment of immediate family members.”
B. 	Answer to the Remaining Allegations in the Complaint
In her Answer, Respondent reiterated that her child (substitute teacher) and her husband
(teacher) were employed by the District prior to her appointment as Superintendent. Respondent
maintained she is “well aware of her ethical obligation to recuse herself from directly supervising
or evaluating her relatives, or in any other way influencing their employment relationship with
the 	District.” 	Further, 	Respondent 	notes, 	at 	Board 	counsel’s 	suggestion, 	the 	District
“implemented a procedure whereby any personnel actions involving [R]espondent’s son or
husband” were recommended to the Board by the Assistant Superintendent instead of her.
Specifically, all personnel recommendations to the Board would appear on the agenda under
section titled “Superintendent’s Report/Recommendations,” with each item prefaced with a note
that 	either 	the 	Superintendent 	or 	the 	Assistant 	Superintendent 	were 	recommending 	the
individual.

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Respondent contends that at the meeting in question, she was not aware that her child was
on the list of over 160 individuals being recommended as substitutes. Respondent admits she
should have “scrutinized the list more carefully” and she “accepts full responsibility for that
oversight on her part.” Respondent further contends this was the first time her child was on the
agenda since she became Superintendent. Respondent asserts she takes her recusal responsibility
“seriously” and reaffirms that she has a procedure in place to implement it. Respondent has
“pledged to take steps to assure [it] does not happen again.”
Respondent also offered three “Affirmative Defenses,” namely that her action was
unintentional, inadvertent and without any nefarious intent; she did not confer, or attempt to
confer, any unwarranted privileges or advantages on her child; and any “technical violation was
de minimis” and she does not deserve “any discipline.”
C. 	Statement of Reasons
In her Statement of Reasons, Respondent argues that the nepotism regulation, N.J.A.C.
6A:23A-6.2, “generally prohibits superintendents from recommending employment of their own
relatives, but allows for certain exceptions,” namely for continued employment or promotion of
previously-employed relatives. Additionally, the regulation provides that districts may exempt
per diem substitutes from the restrictions of the nepotism policy. Respondent contends that the
Commission found in Advisory Opinion A13-20 (A13-20) that even if the nepotism policy does
not prohibit it, a superintendent violates the Act when promoting a family member to a new
position, but does not provide guidance on approving grandfathered relatives “just to keep the
jobs they already have.”
Respondent 	maintains, 	“in 	order 	to 	avoid 	any 	question 	regarding 	[R]espondent’s
behavior, a formalized procedure was put in place to recuse [R]espondent from any personnel
agenda items involving her husband and her son.” Respondent asserts that there is no evidence
that her son, “who had been serving in the same position prior to [R]espondent becoming Acting
Superintendent, would not otherwise have continued to be appointed to that position had
[R]espondent not been Superintendent at the time,” and as such she was not in violation of
N.J.S.A. 	18A:12-24(b). 	As 	to 	N.J.S.A. 	18A:12-24(c), 	Respondent 	acknowledges 	that
Superintendents should not recommend appointments for their family members, “which is why a
procedure 	was 	put 	in 	place 	for 	the 	Assistant 	Superintendent 	to 	make 	any 	such
recommendations.” Given the procedure, Respondent contends that a reasonable observer would
recognize her “inadvertent failure to catch her son’s name on the lengthy list of substitutes, and
would not have inferred anything nefarious.” As such, Respondent contends that even if the
Commission finds a violation, such violation is de minimis and does not warrant a penalty.2
2 Respondent also argues her procedural due process rights have been denied by the Commission’s
allowance of ex parte oral argument on pending matters, which has “already infected the record in this
case with sufficient procedural error to warrant dismissal of the charge on that ground alone.” The
Commission notes that the minutes of its July 25, 2023, meeting demonstrate that a member of the public
referenced the docket number in this matter, as well as several other matters involving the same District,
but discussion of neither the facts nor legal issues of this matter occurred in public session. Additionally,
the Commission’s review of this matter is limited solely to the written submissions.

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III. 	Findings of Fact
Based on its thorough and independent review of the record, the Commission finds the
following facts to be undisputed:
1. 	Respondent became the Acting Superintendent of the District in 2021. Complaint
at page 2; Answer at 1.
2. 	At the time Respondent was promoted to Acting Superintendent, her son was
employed as a substitute teacher in the District. Complaint at pages 2-3; Answer at 2.
3. 	The Board had a meeting on August 17, 2022. Complaint at pages 2-3; Answer at
4.
4. 	At the Board meeting on August 17, 2022, Respondent recommended approval of
a list of substitute teachers for appointment or reappointment that included Respondent’s son.
Complaint at page 3; Answer at 5.
IV. 	Analysis and Conclusions of Law
Complainant 	argues 	that 	Respondent 	violated 	N.J.S.A. 	18A:12-24(b) 	and 	N.J.S.A.
18A:12-24(c) when she recommended her son for the position of substitute teacher. Respondent
counters that the approval was inadvertent and unintentional. Those provisions of the Act state:
b. 	No school official shall use or attempt to use his official position to
secure unwarranted privileges, advantages or employment for himself, members
of his immediate family or others;
c. 	No school official shall act in his official capacity in any matter
where he, a member of his immediate family, or a business organization in which
he has an interest, has a direct or indirect financial involvement that might
reasonably be expected to impair his objectivity or independence of judgment. No
school official shall act in his official capacity in any matter where he or a
member of his immediate family has a personal involvement that is or creates
some benefit to the school official or member of his immediate family;
In A13-20, the Commission issued clear and unequivocal guidance that a Superintendent
would violate the Act by recommending a family member for a promotion, and that while such
action may not violate the Nepotism policy, it does not relieve a school official of their ethical
obligations pursuant to the Act. The Commission noted that “there is no question that the public
would perceive” the promotion of a family member “as securing an unwarranted privilege,
advantage or employment” for the family member, which “create[s] a justifiable impression
among the public that their trust was being violated.” Additionally, the Commission made clear
that a promotion is not the only employment action that a Superintendent may not make
involving a family member, stating that as the Superintendent supervises all staff in the District,

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he or she “must recuse [himself or herself] from any and all discussions” regarding the family
member’s employment, “including [the] evaluation, retention, and possible future promotions,”
and the Superintendent “may not make any recommendations relative to these issues.” A13-20
(emphasis added). Accordingly, the Commission advised that a Superintendent may violate the
Act by recommending a family member’s retention or reappointment to a position.
With the above in mind, the Commission finds that although Respondent’s son was one
of 160 individuals who were being recommended for employment as substitute teachers and
despite Respondent’s admittance that she did not realize her son’s name was included on that list
of substitute teachers, Respondent’s failure to recuse herself on the recommendation of her
child’s employment constitutes using her position as Superintendent to secure an unwarranted
privilege, advantage, or employment for her child, in violation of N.J.S.A. 18A:12-24(b).
Respondent admits that she recommended her child for the position of substitute teacher,
even if she did so unintentionally and/or inadvertently. Although Respondent contends the
recommendation of her child on a list of 160 individuals was an oversight, the Commission finds
that Respondent nevertheless acted in her official capacity in a matter where her child had a
financial involvement, 	which might reasonably be expected to impair her objectivity or
independence of judgment, and also acted in her official capacity in a matter where she had a
personal 	involvement 	that 	created 	a 	benefit 	for 	her 	son. 	Accordingly, 	Respondent’s
recommendation to approve the list of substitute teachers, which included her child, at the Board
meeting on August 17, 2023, violates N.J.S.A. 18A:12-24(c).
Accordingly, 	and 	based 	on 	a 	complete 	and 	thorough 	review 	of 	the 	record, 	the
Commission finds, based on the undisputed evidence as set forth herein, that Respondent
violated N.J.S.A. 18A:12-24(b) and N.J.S.A. 18A:12-24(c) when she recommended her son for
reappointment in the position of substitute teacher.
V. 	Recommended Penalty
Having found that Respondent violated N.J.S.A. 18A:12-24(b) and N.J.S.A. 18A:12-
24(c), 	the 	Commission 	is 	authorized 	to 	recommend 	to 	the 	Commissioner 	of 	Education
(Commissioner) an appropriate penalty, which may range from reprimand to removal. 	N.J.S.A.
18A:12-29(c).
In its review, the Commission finds that reprimand is the most appropriate penalty. In
reaching this determination, the Commission finds that, based on the record, Respondent did not
act deliberately or intentionally, and she did not realize her son’s name was on the list of
substitute teachers. The Commission genuinely appreciates Respondent’s admission that she
should have “scrutinized the list more carefully” and that she “accepts full responsibility for that
oversight on her part.” However, the Commission notes that it is Respondent’s responsibility as
the Chief School Administrator to carefully examine all agenda items prior to Board meetings to
ensure that she abstains from all matters in which she has a conflict of interest in order to
preserve the public trust.

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VI. 	Decision
For the reasons set forth above, the Commission recommends that the Commissioner
impose a penalty of reprimand for the violation of N.J.S.A. 18A:12-24(b) and N.J.S.A. 18A:12-
24(c).
Pursuant to N.J.S.A. 18A:12-29(c), this decision shall be forwarded to the Commissioner
for review of the Commission’s recommended penalty. The parties may either: 1) file exceptions
to the recommended sanction; 2) file an appeal of the Commission’s finding of a violation; or 3)
file both exceptions to the recommended sanction together with an appeal of the finding of a
violation.
Parties taking exception to the recommended sanction of the Commission but not
disputing the Commission’s finding of a violation may file, within thirteen (13) days from the
date the Commission’s decision is forwarded to the Commissioner, written exceptions regarding
the recommended penalty to the Commissioner. The forwarding date shall be the mailing date to
the parties, as indicated below. Such exceptions must be forwarded to: Commissioner of
Education, c/o Bureau of Controversies and Disputes, P.O. Box 500, Trenton, New Jersey 08625,
marked 	“Attention: 	Comments 	on 	Ethics 	Commission 	Sanction,” 	as 	well 	as 	to
(ControversiesDisputesFilings@doe.nj.gov). A copy must also be sent to the Commission
(school.ethics@doe.nj.gov) and all other parties.
Parties seeking to appeal the Commission’s finding of a violation must file an appeal
pursuant to the standards set forth at N.J.A.C. 6A:4:1 et seq. within thirty (30) days of the filing
date of the decision. The filing date shall be three (3) days after the date of mailing to the parties,
as shown below. In such cases, the Commissioner’s review of the Commission’s recommended
sanction will be deferred and incorporated into the Commissioner’s review of the finding of
violation on appeal. Where a notice of appeal has been filed on or before the due date for
exceptions to the Commission’s recommended sanction (thirteen (13) days from the date the
decision is mailed by the Commission), exceptions need not be filed by that date, but may be
incorporated in the appellant’s briefs on appeal.
Robert W. Bender, Chairperson
Mailing Date: January 23, 2024

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Resolution Adopting Decision
in Connection with C12-23
Whereas, 	at 	its 	meeting 	on 	December 	19, 	2023, 	the School 	Ethics 	Commission
(Commission) considered the entirety of the record in this matter; and
Whereas, at its meeting on December 19, 2023, the Commission discussed finding a
violation of N.J.S.A. 18A:12-24(b) and N.J.S.A. 18A:12-24(c); and
Whereas, 	at 	its 	meeting 	on 	December 	19, 	2023, 	the 	Commission 	discussed
recommending a penalty of reprimand for the violations of N.J.S.A. 18A:12-24(b) and N.J.S.A.
18A:12-24(c); and
Whereas, at its meeting on January 23, 2024, the Commission reviewed and voted to
approve the within decision as accurately memorializing its actions/findings from its meeting on
December 19, 2023; and
Now Therefore Be It Resolved, that the Commission hereby adopts the decision and
directs its staff to notify all parties to this action of its decision herein.
Robert W. Bender, Chairperson
I hereby certify that the Resolution was duly
adopted by the School Ethics Commission at
its public meeting on January 23, 2024.
_____________________________
Brigid C. Martens, Director
School Ethics Commission