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Palms v. the School District of Greenville County

Court of Appeals of South Carolina

May 30, 2014

Lee C. Palms and Nelle S. Palms, as Guardians ad Litem for L.P., a minor, Respondents,
v.
The School District of Greenville County, Appellant

Heard May 20, 2014

Appeal From Greenville County. Appellate Case No. 2013-002232. Edward W. Miller, Circuit Court Judge.

Thomas Kennedy Barlow and Kenneth L. Childs, Childs & Halligan, PA, both of Columbia, and Rodney Douglas Webb, of Greenville, for Appellant.

Carl F. Muller, of Greenville, for Respondents.

J. Theodore Gentry and Wade S. Kolb III, Wyche, P.A., both of Greenville, for amici curiae GeriAnn Bell and David Bell, as Guardians ad Litem for J.B., a minor, and Susan Stall and Russell Stall, as Guardians ad Litem for H.S., a minor.

FEW, C.J. SHORT and GEATHERS, JJ., concur.

OPINION

[408 S.C. 577] FEW, C.J.

In this appeal, we hold it is not appropriate for courts to review the decisions of school

Page 920

administrators and school districts regarding how a student's grade point average (GPA) and class rank should be calculated, except on allegations of corruption, bad faith, or a clear abuse of power. We reverse.

[408 S.C. 578]I. Facts and Procedural History

In the fall of 2012, L.P. transferred from Riverside Military Academy in Georgia to Southside High School in Greenville County to begin his junior year. School administrators at Southside calculated L.P.'s GPA using the grades shown on his transcript from Riverside. According to this initial calculation, L.P. was the highest ranked student in Southside's junior class. Another student's mother expressed concern to Southside's administrators tat Riverside's grading policy required some of L.P.'s grades to be inflated, and thus Southside incorrectly calculated L.P.'s GPA. Southside's administrators initially informed the student's mother they calculated L.P.'s GPA according to the School District's grading policy, and they would not change the calculation. Eventually, however, Southside recalculated L.P.'s GPA from 5.215 to 5.048, which reduced his class rank from first to sixth.

L.P.'s parents met with school administrators at Southside and expressed their dissatisfaction with the recalculation, but Southside refused to restore L.P.'s original GPA and class rank. L.P.'s parents then filed this lawsuit, asserting the School District violated South Carolina law and its own grading policy in recalculating L.P.'s GPA. They sought a writ of mandamus directing the School District to restore L.P.'s GPA and class rank to their original values, and an injunction prohibiting the School District from ...


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