Jason Camp v. Los Angeles Unified School District

Whether a school district’s deliberate manipulation of federal Title I enrollment counts to maximize funding allocations—while systematically diverting those funds from the disadvantaged students who generated them—violates Title I’s mandatory allocation requirements under 34 C.F.R. §§ 200.78(a)(1) and 200.78(b)(1), regardless of whether a regulation specifically prohibits the district’s precise manipulation scheme.

Whether the California Court of Appeal’s requirement that Title I violations can only occur when regulations specifically prohibit an employer’s exact manipulation scheme conflicts with this Court’s precedent in Bennett v. Kentucky Department of Education, 470 U.S. 656 (1985), which held Title I violations require repayment regardless of whether specific regulations prohibit the precise conduct.

Whether federal courts may effectively immunize systematic subversion of Title I’s fundamental regulatory framework—including the rank-order allocation requirement of 34 C.F.R. § 200.78(a)(1) and the per-pupil minimum of 34 C.F.R. § 200.78(b)(1)— by requiring identification of regulations that anticipate each specific method of manipulation, thereby creating a dangerous safe harbor for creative violations of Title I’s comprehensive regulatory scheme.