# Phillis v. Board of School Directors of Mechanicsburg Area School District

> Commonwealth Court of Pennsylvania · November 17, 1992 · 151 Pa. Commw. 497

URL: https://www.frixlaw.com/law-library/cases/6374476

## Case

- **Full name:** Debra PHILLIS v. BOARD OF SCHOOL DIRECTORS OF MECHANICSBURG AREA SCHOOL DISTRICT
- **Court:** Commonwealth Court of Pennsylvania
- **Decided:** November 17, 1992
- **Citations:** 151 Pa. Commw. 497; 617 A.2d 830; 1992 Pa. Commw. LEXIS 696
- **Precedential status:** Published
- **Opinion:** Dissent by Kelley
- **Judges:** Colins, Craig, Doyle, Friedman, Kelley, Pellegrini, Smith
- **Cited by:** 2 later opinions in the Frix Law Library

## Citator (automated)

- No negative treatment found by the automated citator. That is not the same as a confirmation that the case is good law; read the citing cases.
- Full citator and citing cases: https://www.frixlaw.com/law-library/cases/6374476

## Opinion text

KELLEY, Judge,
dissenting.
I respectfully disagree with the majority. I believe the language of 22 Pa.Code § 351.26 clearly requires that anecdotal records are essential to support an unsatisfactory rating. Accordingly, where the unsatisfactory rating is challenged, the absence of an anecdotal record into the record establishes an insufficient record for substantial evidence on appeal. This provision of the Code necessitates the introduction and record of an anecdotal record to establish substantial evidence. Without anecdotal records there cannot be substantial evidence, as a matter of law.
Accordingly, I would reverse.

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/6374476. Public record. Not legal advice.