Latson W. Cockfield v. New Jersey Department of Education, State Board of Examiners, 3/11/26 (#87-26)

87-26
OAL Dkt. No. EDU 09401-25
Agency Dkt. No. 95-4/25
New Jersey Commissioner of Education
Final Decision
Latson W. Cockfield,
Petitioner,
v.
New Jersey Department of Education, State
Board of Examiners,
Respondent.
The record of this matter and the Initial Decision of the Office of Administrative Law (OAL)
have been reviewed and considered. The parties did not file exceptions.
By way of background, petitioner sought issuance of a Teacher of Business, Finance,
Economics, and Law Certificate of Eligibility (CE) from the Board. 	The Board determined that
petitioner has not satisfied the requirements for issuance of the CE because he has not completed
three (3) semester-hour credits in economics and three (3) semester-hour credits in business law
as required by N.J.A.C. 6A:9B-10.12. Moreover, the Board determined that certain supplemental
information petitioner submitted to the Board during the credentials review conducted pursuant
to N.J.A.C. 6A:9B-4.12 did not demonstrate a one-to-one relationship with the outstanding
regulatory requirement.
Petitioner appealed to the Commissioner, and the Board filed a motion to dismiss in lieu
of answer. The matter was transmitted to the OAL for further proceedings. In a submission to

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the OAL dated June 16, 2025, petitioner provided additional information, including a list of
business-related coursework purportedly constituting a coherent sequence totaling more than
30 credits, with at least 12 credits earned at an advanced level, and related transcripts; state-
issued insurance licenses from New Jersey and South Carolina; and written verification from
Passaic County Community College that he taught Business Law and Introduction to Business
courses at that institution.
The Administrative Law Judge (ALJ) granted respondent’s motion to dismiss the petition
upon concluding that the Board was “prohibited” from substituting petitioner’s alternative
education and/or workplace experience for the outstanding three (3) semester-hour credits in
economics and three (3) semester-hour credits in business law per N.J.A.C. 6A:9B-4.12. Initial
Decision at 6-7.
Upon review, the Commissioner rejects the ALJ’s conclusion and determines that a
remand to the Board is warranted. The Commissioner disagrees that the Board is barred from
considering alternative education and/or workplace experience to address the missing credits.
The Board may indeed consider whether alternative education and/or work experience
demonstrates a one-to-one relationship with the outstanding regulatory requirement as part of
the credential review process. N.J.A.C. 6A:9B-4.12(b); Brady v. N.J. Dep’t of Educ., State Bd. of
Exam’rs, Commissioner Decision No. 36-25, at 2 (Jan. 30, 2025).
If an application for certification is deemed deficient, the candidate may provide the
Board with “evidence of alternative education and/or experience that the candidate considers
equivalent to any area(s) of deficiency.” N.J.A.C. 6A:9B-4.12(b). “In this instance, the Board does
not waive requirements, rather, it determines if the experience and/or study presented is

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equivalent to the requirements for issuance of the [requested] certificate.” Hutchinson v. N.J.
State Bd. of Exam’rs, EDU 16373-12, Initial Decision at 13 (Apr. 5, 2013), adopted, Commissioner
Decision No. 177-13 (May 15, 2013). Specifically, the Board has discretion to determine whether
the alternative experience “establishes a one-to-one correspondence” with the requirements for
certification. 	Ibid. 	“The burden is on the applicant to present the information necessary to
establish the ‘one-to-one correspondence’ of experience/alternate education to the licensing
deficiencies.” Ibid.
The Commissioner finds that a remand to the Board is warranted for two reasons. First,
the Board has not had the opportunity to evaluate the additional information submitted to the
OAL by petitioner. Second, the Board has not explained which credits it has accepted toward the
regulatory requirement. While the Commissioner accepts that credits cannot be double counted,
without information as to which courses have already been credited by the Board, the
Commissioner 	cannot determine whether there 	are sufficient 	remaining 	credits among
petitioner’s other coursework to satisfy the requirements. See Eladio Conchas Guzman v. N.J.
Dep’t of Educ., State Bd. of Exam’rs, Commissioner Decision No. 513-25, at 5 (Oct. 31, 2025).
Accordingly, this matter is remanded to the Board for further proceedings consistent with
this decision.
IT IS SO ORDERED.
COMMISSIONER OF EDUCATION
Date of Decision: 	March 11, 2026
Date of Mailing: 	March 11, 2026

New Jersey is an Equal Opportunity Employer
INITIAL DECISION GRANTING
MOTION TO DISMISS
OAL DKT. NO. EDU 09401-25
AGENCY DKT. NO. 95-4/25
LATSON W. COCKFIELD,
Petitioner,
v.
NEW JERSEY DEPARTMENT OF EDUCATION,
STATE BOARD OF EXAMINERS,
Respondent.
Frances E. Barto, Esq., for petitioner (Barto & Barto, LLC, attorneys)
David Kalitsky, Deputy Attorney General, for respondent (Matthew J. Platkin,
Attorney General of New Jersey, attorney)
Record Closed: November 14, 2025 Decided: December 16, 2025
BEFORE WILLIAM T. COOPER III, ALJ:
STATEMENT OF THE CASE AND PROCEDURAL HISTORY
Petitioner Latson W. Cockfield appeals respondent New Jersey Department of
Education, State Board of Examiners’ (Board’s), December 6, 2024, denial of the
issuance of a Teacher of Business: Finance/Economics/Law Certificate of Eligibility (CE).
State of New Jersey
OFFICE OF ADMINISTRATIVE LAW

OAL DKT. NO. EDU 09401-25
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The denial noted that petitioner satisfied the requirements toward a certification except
for the completion of three semester-hour credits in economics and three semester-hour
credits in business law.
On May 28, 2025, the Department of Education transmitted the matter to the Office
of Administrative Law (OAL), where on May 29, 2025, it was filed as a contested case
pursuant to N.J.S.A. 52:14F-1 to -13 and N.J.S.A. 52:14B-1 to -15.
In lieu of filing an answer to the petition, respondent filed a motion to dismiss.
Petitioner responded to the motion on November 10, 2025.
This case does not present divergent facts. Respondent argues that the Board
properly denied the issuance to petitioner of a Teacher of Business:
Finance/Economics/Law CE. Petitioner, however, argues that his resumé, together with
his work background and history of teaching, supports the issuance of a CE. The issue
to be determined in this appeal is whether respondent properly denied petitioner’s request
that his background in finance, prior completed course work, and prior work history be
accepted in lieu of the certification requirements for a CE.
FINDINGS OF FACT
Having reviewed the briefs submitted in support of and in opposition to the motion
to dismiss, I FIND the following as FACTS:
Petitioner applied for a CE, and on December 6, 2024, respondent denied
petitioner’s application. In its decision, respondent noted that under N.J.A.C. 6A:9B-
9.1(a)(1)(iii), candidates for an instructional certificate must complete at least thirty
semester-hour credits “in a coherent sequence of courses appropriate to the subject area
as documented by an official transcript from an accredited college or university,” of which
twelve semester-hour credits must be “at the advanced level of study, including junior-,
senior-, or graduate-level study as documented by the official transcript of an accredited
college or university.” Respondent also noted that under N.J.A.C. 6A:9B-10.12, for the
finance, economics, and law certificate of eligibility, at least six semester-hour credits

OAL DKT. NO. EDU 09401-25
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must be in economics, three semester-hour credits must be in finance, and three
semester-hour credits must be in business law.
Petitioner acknowledges that he has not earned a degree in finance, economics,
or law. In light of this, respondent evaluated courses appropriate to those subject areas
based on petitioner’s transcripts from the American College of Financial Services, where
he earned a master’s degree in financial services in 2001, and Morris College, where he
earned a bachelor’s degree in organizational management in 2010. Based upon a review
of those transcripts, respondent determined that petitioner satisfied the requirements
toward certification except for the completion of three semester-hour credits in economics
and three semester-hour credits in business law.
Petitioner admitted that he has not met the statutory requirements, but requested
that respondent accept, in lieu of those requirements: (1) his experience as a substitute
teacher in South Carolina, where he taught business law, business management,
entrepreneurship, accounting, and marketing; (2) his experience as an adjunct professor
at Passaic County Community College, where he taught business management and
business law; (3) his experience as an insurance instructor at the Cape School in
Buckingham, Virginia; and (4) his receipt of an Army Achievement Medal.
CONCLUSIONS OF LAW
“Specific pleading requirements are governed by the agency with subject matter
jurisdiction over the case.” N.J.A.C. 1:1-6.1(a). The rules require that a “petition shall
include . . . a statement of the specific allegation(s) and essential facts supporting the
specific allegation(s) that have given rise to a dispute pursuant to the school laws.”
N.J.A.C. 6A:3-1.4(a). When deficient or inadequate petitions are presented to the
Commissioner, at any time prior to transmittal of the pleadings to the OAL—either in the
Commissioner’s discretion or upon a motion to dismiss filed in lieu of answer—the
Commissioner may dismiss the petition on the grounds that the petitioner has not
advanced any cause of action, even if the petitioner’s factual allegations are accepted as
true. See N.J.A.C. 6A:3-1.10.

OAL DKT. NO. EDU 09401-25
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In fulfilling their quasi-judicial responsibilities, State agencies look to judicial
principles for guidance. Hackensack v. Winner, 82 N.J. 1, 28–30 (1980). “[C]ourt-
fashioned doctrines for the handling of litigation do in fact have some genuine utility and
relevance in administrative proceedings.” Id. at 29. The New Jersey Supreme Court
further held,
many principles and rules that govern judicial proceedings
and determinations can be applied to an agency’s quasi-
judicial or adjudicative function. Judicial rules of procedure
and practice are transferable to administrative agencies when
these are conducive to ensuring fairness, independence,
integrity, and efficiency in administrative adjudications.
[In re Tenure Hearing of Onorevole, 103 N.J. 548, 554–55
(1986).]
Thus, the principles that govern a motion to dismiss for failure to state a claim under R.
4:6-2(e) apply equally to a motion to dismiss for failure to advance a cause of action under
N.J.A.C. 6A:3-1.10.
In deciding a motion to dismiss for failure to state a claim upon which relief can be
granted under R. 4:6-2(e), “the inquiry is confined to a consideration of the legal
sufficiency of the alleged facts apparent on the face of the challenged claim.” Rieder v.
State, Dep’t of Transp., 221 N.J. Super. 547, 552 (App. Div. 1987) (citation omitted). The
court may not consider anything beyond whether the complaint states a cognizable cause
of action. Ibid. For purposes of determining the motion, the court must “assume the facts
as asserted by [petitioners] are true and give [them] the benefit of all inferences that may
be drawn in [their] favor.” Velantzas v. Colgate-Palmolive Co., 109 N.J. 189, 192 (1988).
If the complaint states no basis for relief and discovery would not supply one, dismissal
is the appropriate remedy. Banco Popular N. Am. v. Gandi, 184 N.J. 161, 166 (2005). If
the factual allegations are “palpably insufficient to support a claim upon which relief can
be granted,” the court must dismiss the complaint. Rieder, 221 N.J. Super. at 552.
Moreover, it “runs against the grain of public policy to force a public entity to incur the cost
of defending an action that ultimately and undoubtedly will be dismissed on the merits.”
Tryanowski v. Lodi Bd. of Educ., 274 N.J. Super. 265, 268–69 (Law Div. 1994).

OAL DKT. NO. EDU 09401-25
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In New Jersey, respondent has been designated as the body responsible for the
issuance of and revocation of appropriate certificates to teach, as well as the supervision
of the teaching, instruction, or educational guidance of students in public schools.
N.J.S.A. 18A:6-38.
The general requirements for any certificate are found at N.J.A.C. 6A:9B-8.3(a),
which states in relevant part:
1. Hold a bachelor’s or an advanced degree from an
accredited college or university; [and]
. . . .
4. Satisfy the endorsement requirements and exceptions
pursuant to N.J.A.C. 6A:9B-9, 10, and 11, including, but not
limited to, passing the appropriate State test(s) of subject
matter knowledge and completing the required subject-
area course requirements.
[Emphasis added.]
To fulfill the endorsement requirements necessary for an instructional certificate
under N.J.A.C. 6A:9B-9.1(a), a candidate shall:
Complete one or more of the following coursework
requirements for the subject area in which the candidate is
seeking the endorsement:
(i) Complete an undergraduate major in the subject
area as documented by an official transcript from an
accredited four-year college or university;
(ii) Hold a graduate degree in the subject area; or
(iii) Complete at least 30 credits in a coherent
sequence of courses appropriate to the subject area as
documented by an official transcript from an accredited
college or university, of which 12 semester-hour credits
must be at the advanced level of study, including
junior-, senior-, or graduate-level study as documented
by the official transcript from an accredited four-year
college or university . . . .

OAL DKT. NO. EDU 09401-25
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Here, petitioner admittedly never completed an undergraduate major in finance,
economics, and law, nor did he hold a graduate degree in the subject area. He was
required to complete at least thirty semester-hour credits in the subject area, of which at
least twelve semester-hour credits were at the advanced level of study, as documented
by an official transcript from an accredited college or university. Under N.J.A.C. 6A:9B-
10.12(a), of those thirty credits, a candidate for the finance, economics, and law
endorsement must complete at a two- or four-year accredited college or university:
1. At least six semester-hour credits in economics;
2. At least three semester-hour credits in finance; and
3. At least three semester-hour credits in business law.
In lieu of the aforementioned requirements, petitioner provided this tribunal with
evidence of alternative education and/or workplace experience that he considers
equivalent to the admitted deficiencies. Petitioner argues that he is qualified to teach in
the areas of finance and economics as evidenced “by his resumé, his background, and
his history of teaching as outlined” in respondent’s motion to dismiss. This argument fails
to recognize the limitations placed on respondent under the regulations.
N.J.A.C. 6A:9B-4.12, Appeals of Office certification decisions, states in relevant
part:
(a) A candidate for certification may appeal to the Board of
Examiners an adverse decision of the Office regarding the
candidate’s eligibility.
1. The appeal shall be filed with the Board of
Examiners within 60 days of the date of the decision at
issue. For good cause shown, the Board of Examiners
may relax the 60-day requirement.
(b) If a candidate receives an evaluation that identifies
areas of deficiency in the certification requirements, pursuant
to N.J.A.C. 6A:9B-5.3(c), the candidate may provide the
Board of Examiners with evidence of alternative education

OAL DKT. NO. EDU 09401-25
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and/or experience that the candidate considers equivalent to
any area(s) of deficiency.
(c) The Board of Examiners shall not:
1. Waive any test, GPA, degree completion, or
approved educator preparation program
completion requirements;
2. Permit a candidate to substitute education
and/or experience for any test, GPA, degree, or
approved educator preparation program
completion requirements; or
3. Issue a certificate that is expired and/or is not a
type of certificate endorsement set forth at N.J.A.C.
6A:9B-9 through 11A.
[Emphasis added.]
Respondent correctly noted in its decision denying the CE that it was prohibited
from substituting petitioner’s work experience for the three semester-hour credits in
economics and three semester-credits in business law. Applying the law to the
undisputed facts as detailed, I CONCLUDE that petitioner’s application was properly
denied.
For purposes of this motion, this tribunal assumes that the facts asserted by
petitioner are true and gives petitioner the benefit of all inferences that may be drawn in
his favor. However, the factual allegations raised by petitioner are palpably insufficient to
overcome the edict of N.J.A.C. 6A:9B-4.12, which prohibits petitioner’s request for relief.
I CONCLUDE that the petition fails to state a claim upon which relief can be granted and
must be dismissed.
ORDER
Based on the foregoing, respondent’s motion to dismiss the petition is GRANTED.

OAL DKT. NO. EDU 09401-25
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I hereby FILE this initial decision with the COMMISSIONER OF THE
DEPARTMENT OF EDUCATION for consideration.
This recommended decision may be adopted, modified or rejected by the
COMMISSIONER OF THE DEPARTMENT OF EDUCATION, who by law is authorized
to make a final decision in this matter. If the 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.
Within thirteen days from the date on which this recommended decision was
mailed to the parties, any party may file written exceptions with the 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.
December 16, 2025
DATE WILLIAM T. COOPER III, ALJ
Date Received at Agency: December 16, 2025
Date Mailed to Parties: December 16, 2025
WTC/am

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APPENDIX
Exhibits
For petitioner:
Response to Motion to Dismiss
For respondent:
Motion to Dismiss with attached exhibits