Amicus Curiae Brief — School Bd. of Nassau Cty. v. Arline

Supreme Court brief1987

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HER AUTHORITIES:

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ISSUES PRESENTED FOR REVIEW

ARG MEN)

[| TUBERCULOSIS IS A “HANDICAP” UNDER

SECTION 504

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LI1. INFECTIOUSNESS OF THE EMPLOYEE’

DISEASE IS A LEGITIMATE JOB

UISQUALIFICATION.

A. An employer may consider an

individual's physical health in

determining whether the person

1S Qualified for a position.

The lower court takes the view that

because Ms. Ariine's handicapping

CONdition does not relate to her academic

qualifications for the job, that condition

Cannot be taken Into account in

determining whether she jis “otherwise

Qualified" for the position. The error of

this rationale is clear. Certainly no one

would seriously disagree that a teacher,

who intentionally assaults and batters her

Students, is unqualified for the position.

Similarly, dq teacher who transmits a

serious disease to her Students lacks a

crucial job qualification.

This Court has recognized that a

recipient of federal funds is justified in

taking the health of an applicant into

account tn determining whether the person

1s “otherwise qualified.” In Southeastern

Community College v. Davis, 442 U.S. 403

1979), this Court -upheld a ¢col

right to take physical limitations into

account in determining “qualification” for

admission to the college's nursing school:

"Taken literally, [the court

of appeals'] holding would

prevent an institution from

taking into account any

limitation resulting from the

Nandicap, however disabling.

It assumes, in effect, that a

person need not meet

legitimate physical

requirements in order to be

‘otherwise qualified.’...An

otherwise qualified person 1s

one who is able to meet ail of

a program's requirements in

spite of his handicap." Id. at

page 4U6,

Regulatory provisions inder the

Rehabilitation Act also provide support

for an employer's considering a person's

physical condition in making employment

decisions,

The pre-employment section of the

Department of Education regulation

authorizes employers to condition

et oe

employment on the results of a medical

examination. 34 C.F.R. section 104.14(c).,

Likewise, the Department of Labor

regulations under section 503 allow

federal contractors to apply physical or

mental job qualification requirements in

the selection of applicants for jobs or in

making other changes in employment status

such aS promotion, demotion or training.

The regulation recognizes that Such

requirements may “tend to screen out

qualified Nandicapped individuals" but

nonetheless permits contractors to use

them so long as the requirements can be

Shown to be job related and “consistent

with business necessity and Safe

performance of the job." Under the

regulation contractors may also require

comprehensive medical examinations prior

to employment. 4| Der om section

60-741.6(c)

Analogous to employees with

contagious diseases are employees who are

drug or alcohol abusers. In it discussion

of drug and alcoho! abusers in its Section

904 regulation, the Department of Healt

Education and Welfare's takes the position

that an employer may take into account the

fact that, because of his or her handicap,

an employee poses a danger to others.

"The fact that drug

addiction and alconolism may

be handicaps does not mean

that these conditions must be

ignored in determining whether

an individual is qualified for

services or employment

Opportunities. On the

contrary, a recipient may hold

a drug addict or alcoholic to

the same standard of

performance and behavior to

which it holds others, even if

any unsatisfactory performance

or behavior is related to the

person's drug addiction or

alcoholism. In other words,

while an alcoholic or drug

.e)

addict may not be denied

services or disqualified from

employment solely because of

N7S or ner condition, the

Denavioral manifestations of

tne condition may be taken

Into account in determining

whether he or she is

qualified,

With respect to the

employment of a drug addict or

alcoholic, if it can be shown

that the addiction or

alcoholism prevents Successful

performance of the job, the

person need not be provided

the employment opportunity in

question. For example, in

making employment decisions, a

recipient may judge addicts

and alcoholics on the same

Dasis it judges all other

applicants and employees.

Thus , a recipient may

consider - for all applicants

‘ncluding drug addicts and

alcoholics - past personnel

records, absenteeism,

disruptive, abusive, or

dangerous behavior...." 34

C.F.R. section 104, App. A,

Subpart A, section 4,

The Congress apparantly agreed with

HEW that drug and alcohol adDusers should

not be protected by the law to the extent

disability affects Job performance,

After the regulation was pub hed, the

-ongress amended the Jefinition f

nandicapped ndividua t @ x e r

and aicoho!l abusers ‘whose irrent use f

alcohol or drugs prevents such itndividua

rom performing the duties of the job in

question or whose employment, by reason of

such current alcohol or drug abuse, woul

constitute a direct threat to property or

the safety of others.” 29 U.S.C. section

B. An employer may consider whether

a person's disease will endanger

others in determining whether

the person is qualified for the

position.

The Department also has taken the

position that characteristic or symptoms

1f diseases wnich may endanger others in

the workplace, may be taken into account

In determining whether a person 1s

qualified for the position. For example,

1n Appendix A to the Section 504

regulation in its discussion of

pre-employment inquiries, the Department

States:

"CE Jmployers may make

Inquiries about an applicant's

ability to perform a job

safely. Thus, an employer may

not ask if an applicant is an

epileptic but may ask whether

tne person can perform a

particular job without

endangering other employees,"

34 C.F.R. 104, App. A, Subpart

B, Section 18.

The Equal Employment Opportunity

Commission also demonstrated concern for

the health and Safety of other employees

In the regulations it promulgated under

section 501 of the Rehabilitation Act

which governs employment practices of the

federal government with regard to

Nandicapped individuals. The definition

of a “qualified nandicapped person" for

purposes of this Statutory provision

specifically states that in order t

qualified a handicapped individual! must be

able to “perform the essential functions

)f the position in question without

endangering the health and safety of the

individua| or 4 ge 29 Cot ote

Because of the infectious nature of

tuberculosis, an individual with the

disease may not be able to perform his or

her job without endangering the health of

others in the workplace.

Tuberculosis is an “airborne”

disease, Spread by a germ called the

“tubercle bacillus." Persons catch the

disease by inhaling the bacilli suspended

In droplets of moisture in the air from an

infected person's cough or Sneeze.

Infected persons often do not develop the

disease because their immune System

Pee tee a

prevents the bacilli from multiplying. In

4 small proportion of people (about 5%),

the germs immediately take hold and

multiply. The infection can last for life

and symptoms of the disease show up later

In life in an additional 5% of infected

persons. Infection from years earlier may

Progress to disease during periods of

Stress caused by other illnesses or

PMysical or emotional hardship, but often

for no apparent reason. |

The greatest danger to persons in

contact with an infectious “carrier” is

the long-term threat of tuberculous

infection. | Perhaps because young

Children, i.e. those less than 5 years of

age, nave a less wel] developed immune

System, they are more susceptible to

developing tuberculosis than are older

children and adults, Tuberculosis,

Department o f Health, Education and

Welfare, Public Heal

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Disease Control.

However, given the same duration and

ensity 2 f exposure, there 1s no

evidence that young children are at

greater risk of acquiring infection.

YJider children in a classroom situation

and other teachers or employees would be

expected to have the same risk of becoming

infected in Ms. Arline’s school as the

elementary age children, if they had been

exposed for the same length of time in the

ame classroom. The schoo] district

Should be concerned that students and

co-workers are not subjected to

tuberculosis infection, even thougn tne

Infection may never blioom into the disease

Itself, or may occur after the person has

left the school district.

Petitioners in the Reply Argument

note that persons with other communicable

disease such as AIDS, would be Subject to

the precedent set in this case. That is

true, However, AIDS jis a very different

disease from tuberculosis. Although far

more serious in consequence (over 55% of

reported cases have died), AIDS is

relatively difficult to catch. It is a

blood-borne disease spread by intimate

sexual contact or injection into the blood

stream, and not by casual contact in the

Classroom situation. Therefore, although

AIDS is a “communicable” disease, the near

Impossibility of casual transmission makes

1t likely that a teacher with AIDS would

be considered “otherwise qualified” to

teach young children.

In any case, the determination of

whether the person is “otherwise

qualified” for the position should be

determined by the school district, based

upon the medical advise of public health

officials.

[V. COURTS AND LAWMAKERS RECOGNIZE

LIMITATIONS ON THE ADMISSION TO

PUBLIC SCHOOLS OF STUDENTS AND

EMPLOYEES WITH COMMUNICABLE

DISEASES.

A. State laws regulate the presence

of persons with communicable

diseases in the public schools.

In deciding whether to hire or retain

a teacher with a communicable disease,

school district officials must also take

into account state communicable disease

Statutes.

Virtually every state in the- country

regulates those with “communicable

diseases," The Statutes designate

certain diseases which may require

Tsolation of "“carriers", see e.g., N.Y.

Public Health Law

wor

—_

— |

Instances

to public health

certain diseases,

Stat. Ann. §§ 36.621

Code Ann.

§ 6-119.

States have also

enacted directly

health

related to the

children, All states

require

Immunization of public

Students.

Mont. Rev. Codes

§ 40-5-408:

According

Stat. § 433.267.

See Appendix.

Study by the

are enforced

notwithstanding compulsory attendance laws

which are in effect in all the states.

The wording of the statutes varies

from state to state. Indiana, for

example, requires the board of health to

certify that a person with a communicable

disease is no longer infectious to others.

Other statutes, such as that in Virginia,

do not discuss “infectiousness” but merely

prohibit school officials from admitting

to school persons with diseases which have

been declared by the State to be

communicable.

Among the States with Statutes

regarding the health of school employees,

a continuing requirement for certification

of good health and freedom from disease 15

commonplace. Valente, Education Law

Public and Private, 234 (1985). Generally

this type of provision has been upheld by

378 (3rd Cir. 1975); Board of Trustees v.

! the courts. King-Smith v. Aaron, 455 F.2d

Porini, 263 Cal. App.2d 784 (1968).

| At least 25 of the states and the

| District of Columbia require a medical

certification that an employee is free

from tuberculosis or other communicable

disease. £E.g., Alaska Stat. § 18.15.145;

! Cal. Educ. Code §§ 44839, 49406; Me. Rev.

| Stat. Ann. tit. 20A, § 6551; Mass. Gen.

| Laws Ann. Ch. 71, § 55A; NLM. Stat. Ann. §

: 22-10-10; Pa. Stat. Ann. tit. 24,

3 g 12-1209. See Appendix.

Another five States do not

specifically require certification that

‘ the employee is free from communicable

diseases but do make good physical health

a condition of employment. Conn. Gen.

Stat. Ann. § 10-207; Mont. Rev. Code Ann.

§20-4-106(b); Neb. Rev. Stat. §79-1247.06:

Nev. Rev. Stat. § 391.312(f); Utah Code

Ann. § 53-2-25; . Approximately 20 states

require employees to undergo examinations

subsequent to initial employment either

periodically or as ordered by the school

board. Most States that require

subsequent physical examinations do so on

an “as needed“ rather than periodic basis.

However, certain States still require

periodic check ups for their high risk

employees, e.g., Ark. Stat. Ann. §

80-1210; Me. Rev. Stat. Ann. tit. 20A, §

6551: and some require periodic exams for

all their employees. E.@-.-. GEl.e BE0C.

Code § 493406; W.Va. Code § 16-3-4a. In

addition, nine states provide tnat no

teacher can be employed while in the

contagious stage of tuberculosis.

B. Courts consider infectivity of

the disease in Section 504 cases

involving students with

communicable diseases.

Several cases address the issue of

the applicability of Section 504 to

Students with communicable diseases. New

York State Assn. for Retarded Children,

Inc. v. Carey, 466 F, Supp. 479 (E.D.N.VY.

1978), involved the question of whether

School officials violated Section 504 by

isolating from the rest of the school

community retarded children who were

carriers of the hepatitis B virus. The

court noted that the school board should

not be required to “clearly demonstrate

existence of a significant health PIGR.”

Dut in this case there was no showing that

the carriers posed a health risk to

others, because the disease 1s

“transmitted primarily by blood-to-blood

contact, Dy means of transfusion of

»*

injected blood...and may also be

transmitted through body fluids other than

blood, such as saliva or semen." Id at

page 489, n.l.

Other court decisions have upnheida

school officials' decisions refusing to

admit students with hepatitis, based on

the transmissibility of the disease in tne

particular individual. In an unreported

decision out of the U.S. District Court of

Maryland, Ely v. Howard County Board of

Education, 3 E.H.L.R. 553:288 (D. Md.

1982), the court upheld the emergency

suspension and ultimate exclusion from a

special school for the handicapped of 4a

retarded student with severe learning

disabilities who had been identified as a

carrier of the hepatitis B virus.

In that case experts testified that

the child drooled constantly and that

because saliva carries the virus, there

existed a “high risk" of infection through

contact of other students or staff with

the child's saliva. Other evidence also

Showed that a member of the school staff

nad contracted hepatitis, apparently from

this child.

The court acknowledged the right of

the child to an education “in the least

restrictive environment" and the hardship

and injury he would suffer by being

excluded from school. But it contrasted

the child's hardship with the hardship

that would be suffered by the board of

education (representing other students and

School staff) if the child were placed in

school, and concluded that the two “are of

a different degree and kind."

"The former is undoubtedly a

temporary setback to the child in his

EE ee eT

tragic circumstances," the court wrote.

"The latter could be life threatening at

the worst, and life debilitating if not

life threatening.”

The court then continued with a

discussion of the question of “risk"--4

question which always is present in these

cases.

while it may well be tha

the hygenic precautions, 1

rigorously followed, wou |

reduce the risk to a minimal

one, the defendant's expert

believed that the risk was

nevertheless significant.

After hearing the

evidence the court concludes

that the risk is significant

to the health and safety of

the staff and the other

Students and believes the

probability that [the student

will infect a staff member or

a student] is so great that

the court cannot, In good

conscience, say that the risk

to the defendants would not

Outweigh the injury to tne

Olaintiff.

It should also be emphasized that,

unlike hepatitis B, AIDS and other

diseases which have been the subject of

recent cases involving Students,

tuberculosis is highly infectious in

so-called "casual" settings such as the

classroom. The lower court in the instant

case recognized that fact.

In each case, of course the most

difficult question will he that posed to

tne medical experts: whether the disease

In the affected individual is reasonably

Capable of being spread to others in the

context of the school environment and, if

SO, Now long the student or employee must

De kept out of the classroom. The burden

Should always be placed on the handicapped

individual to prove lack of

Iinfectiousness.

v. REASONABLE ACCOMMODATION, IF

AUTHORIZED AT ALL BY SECTION 504,

DOES NOT REQUIRE AN EMPLOYER TO PLACE

IN ANOTHER POSITION, A PERSON

UNQUALIFIED FOR HIS/HER CURRENT

POSITION,

The most disturbing part of the court

of appeals decision is its directive to

the district court to determine first, if

Ms Arline is “otherwise qualified" for her

present job and, if not, what otner joods

the school district could devise for whicn

she would be qualified. This elevates the

“reasonable accommodation” requirement

from a means of making minor adjustments

to qualify the person for the current

position, to a separate requirement that

the employer make affirmative efforts to

create a postion for the handicapped

person when he or she is not qualified for

the position for which he or she is betng

considered.

The statutory language of section 504

contains no requirement that employers

provide “reasonable accommodation" for the

handicapping condition of an employee or

applicant. However, the Department

regulation, promulgated under Section 504,

does contain such a requirement.

The Department of Health, Education

and Welfare (now the Department of

Education and Department of Health and

Human Services) took its “reasonable

accommodation” requirement from a similar

requirement in the Department of Labor

regulation under section 503 of the

Rehabilitation Act of 1973 (applies to

federal contractors). HEW noted, in

Appendix A to its regulation, that-

“Although the wording of the reasonable

accommodation provisions of the two

regulations is not identical, the

obligation that the two regulations impose

“ Berk me S

is the same, and the federal government

policy in implementing the two sections

will be uniform." 34 C.F.R. 104, Appendix

A, Subpart B, Section 16.

As this Court has noted “an agency s

interpretation of the statute under which

it operates is entitled to some deference,

[however] ‘this deference is constrained

by our obligation to honor the clear

’

meaning of a statute as revealed by its

language, purpose and history.'" (citation

omitted) Southeastern Communit College

v. Davis, 442 U.S. 403, 411. A serious

question arises as to whether Section 504

authorizes inclusion of a “eeasonable

‘t

accomodation" provision in the regulation.

Als it as this Court has noted, the

statute does not authorize any regulation

inder Section 504, except as to employees

and contractors of the federal government.

Id at page 413, n. ll. Second, even if

authorization could be implied, the

authorization would not extend to

| encompass affirmative requirements such as

tnat mandated by the lower court.

In addition to the explicit

authorization in Section 503 for a

government regulation implementing the

provisions of the law, another important

distinction between Section 503 and

section 504 lays in question the validity

of the Department of Education's

“reasonable accommodation" requirement.

Unlike Section 504, which prohibits

discrimination, Section 503 requires

government contractors to “take

affirmative action to employ and advance

in employment qualified handicapped

Individuais....", 29 U.S.C 793(a). Thus,

while a requirement relating to

ee ee

“seasonable accommodation” under Section

503, would be appropriate in order to

implement the Congressional intent

relating to “affirmative action", sucn 4a

requirement may not be appropriate under 4a

non-discrimination statute such as Section

504,

As this Court pointed out in

Southeastern Community College v. Davis,

supra at 411, “a comparison of [sections

501, governing Federal Government

employment, 503 and 504] demonstrates tnat

Congress understood accommodation of the

needs of handicapped individuals may

require affirmative action and knew how to

provide for it in those instances where it

wished to do so.”

If, indeed, the Department of Health,

Education and Welfare is held to have had

the authority to adopt a “reasonable

accommodation" requirement, that

authorization could only extend as far as

a means of meeting Section 5004's

non-discrimination requirement. There is

no authority in the law which supports a

department regulation making an

affirmative obligation to “find a job"

somewhere in the employer's organization

for a handicapped person.

Like the court of appeals below, we

Sympathize with Ms. Arline and the

Situation she finds herself in through no

fault of her own. But, Section 504 is a

non-discrimination eet . not 4 law

guaranteeing employment to handicapped

persons, No where in the Act or in the

regulation is there a requirement that the

employer either create a job for the

handicapped person, which meets the

person's qualifications, or place the

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person in a different job than that for

which they have applied or Nave held in

the past.

Section 104.12(b) of the Department

sf Education regulation provides examples

of methods of accommodation whici. the

Department believed would be ‘reasonable.

Ail of the examples refer to restructuring

the qualification requirements of the job

for which the handicapped employee is

being considered, providing equipment to

assist the employee in qualifying for the

job or making the employer's facilities

accessible to the job applicant. No where

1s there any indication that the

Department intended to require the

employer to consider the person for a

different job, in the event accommodation

cannot be made in the first job.

"“(b) Reasonable

accommodation

may include: (1)

making

facilities used by employees

readily accessible to and

usable by handicapped persons,

and (2) job restructuring,

part-time or modified work

Schedules, acquisition or

modification of equipment or

devices, the provision of

readers or interpreters, and

other similar actions."

The appendix to the regulation

Provides additional guidance as to

the

department's definition of “reeasonable

accommodation."

"Job restructuring may entail

shifting nonessential duties to

other employees. In other

cases, reasonable accommodation

may include physical

modifications or relocation of

particular offices or jobs so

that they are in facilities or

parts of facilities that are

accessible to and usable by

Nandicapped persons." 34

C.F.R. 104, App. A, Subpart B,

Section 16.

Even the Department of

Labor

regulation 41 C.F.R. 60-741. implementing

Section 503, which as we have

Said

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requires “affirmative action, does not

carry the definition of “reasonable

accommodation" as far as the lower court.

The regulation provides in part, as

follows:

""Qualified handicapped

individual’ means a

handicapped individual as

defined in section 60-741-2

who is capable of performing a

particular job with reasonable

accommodation to his or her

handicap.”

Significantly, the accommodation

requirement applies only to a “particular

job." The implementing regulations of

Section 501 of the Rehabilitation Act

includes a similar qualifier on the scope

of the “reasonable accommodation”

requirement; this restriction appears even

though section 501, like Section 503,

contains an affirmative action

requirement. Under Section 501, the

regulation regarding the definition of

“qualified handicapped person" provides as

follows:

“Qualified handicapped person

means with respect to

employment, a handicapped

person who, with or without

reasonable accommodation can

perform the essential

functions of the position in

question without endangering

the health and safety of the

Individual or others...." 29

C.F.R. section 16134,.702(f).

The key phrase to note in this definition

restricts application of the accommodation

requirement to the “position in question."

Thus, it is apparent that neither the

Department of Labor nor the Department of

Health, Education and Welfare intended by

their “reasonable accommodation”

requirements to mandate that nandicapped

employees who are not qualified for the

PpOSition be provided a different one. in

the instant case, the “particular job" is

the position which Ms. Arline held as an

elementary-schoo| teacher. Since her

jisability renders her unqualified for the

’

position of elementary-school teacher, tne

shoo district was zuthorized

eminate her employment.

ALLOWING A PERSON WITH A CONTAGIOUS

DISEASE TO REMAIN IN THE CLASSROOM

SUBJECTS A SCHOOL DISTRICT TO

POTENTIAL TORT LIABILITY

In each case where a school distric

owingly allows a student or employee

a contagious disease to remain in tne

room, there exists the potential o

in tort by another who contracts tne

defendant knew or should have known of the

danger and had a duty to warn others of

that danger. See, e@.g., Earle v. Kuklo,

98 A.2d 1097 (NH. App. Div., 1953);

Kleigel v. Aitken, 69 NW. 67 (Wisc.

1896); Gilbert v. Hoffman, 23 Nid. 632

(Iowa 1885).

Employers have even been held to be

negligent for failure to take prophylactic

measures to clean up the premises after

removing an infected person from the

premises. For example, a case in

Minnesota involved a school teacher who

alleged that she contracted tuberculosis

because the school district had not

properly cleaned and disinfected the

classroom after the teacher's predecessor

left her job due to tuberculosis.

Although dismissing the action because of

the school district's immunity, the court

held that the school district nad been

negligent. Bang v. Independent Schoo

District No. 27, 225 N.W. 499 (1929

CONCLUSION

’

Amicus submits that Ms

"handicapped" under Section 504 of the

Rehabilitation Act of 1973. The schoo!

district, as an important part of its duty

to protect the students within its cnarge

requires that teachers must De pnysicaily

capable of joing the job. The

uncontroverted nedical| testimony here

indicated that Ms. Arline was capable of

transmitting her tuberculosis infection to

the students mn tne context Tf tne

>|assroom. Since she cannot meet a va

sfFiterion for her position, she 5 [h(Cnot

‘otherwise qua fied" for tne jad

The court of appeals remanded the

ase back to the district court for a

a8,

term?)

strict

. Ar]

eme

c?T

—)

(=)

ren

~ >

Cven

sa A -

. 1} UUS

nt 5 an

JUCS5S

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nn +

yme L

Sectio

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, - >

= ~

(=)

nny

1ct

= +

allowing

position

4 position

Gwendolyn

Counsel of Record

Deputy Genera!

National

1680 Duke Street

Alexandria, VA

7903 )

August

NSBA

Genera!

‘

ner to

or, on

H. Gr

School

838-6722

ither risking the health of

Ms. Arline’s classroom by

remain in her present

tne otner nand, to create

for her elsewhere in the

ly submitted,

egory

Counsel

Boards Association

Steinhilber

Director

Thoma

NSBA

‘_|

Counsel/Associate Executive

Shannon

Director

utive

APPENDIX

FALTH

SCHOOL

EMENTS ON

REQUIR

STATUTORY

Teachers

Pupils

"WVXS

sTSomNowaaNL

WOUA AAA

aSVaSId ‘WNHO?)

WOUd AANA

NOT LVZINAWNWI

IVOISAHd

til

Pupils Teachers

State PE IM CD TB CD

H1 X X |

ID X | *3°4,5 X

IL = | mx

IN —

IA X |

KS =a | x, X

KY — ae

LA X X x |

ME x xX | X,

—

MD x, x 4 5

MA X X x Ky 5

M1 _— T

MN X TX, X

MC X | Ka 5 X

MO — _ sem

MT X 7

NE oe pee

Nv X X ) | =

Pupils Teachers

State PE IM CD | TB =36cD

NH x xx |

NJ X XK . +

NM Xx i X

NY x X x |

NC X K + Ka X

ND X Xx |

OH X X x |

OK X X x |

OR X x | Ke

PA a a ce see “eee

RT X X T

SC X X | X 4

SD —— X vr X

TN X ror

TX x X wr 7

IT X X R

iT X X _

Pupils , leachers

State PE IM CD | TB. cD

WA a aa X

WV KX xX | X,

_ 4

W1 xX | x,

WY . 7 |

Total: 29 49 35 | 21 15

> Wh

Discretionary with school district

General public health statute

Teacher certification prerequisite

Additional tests or exams required on a

periodic basis or when deemed necessary

Requires exclusion from school

TABLE OF CITATIONS

Pupils

Physical Exams

]

ct?

—

M™

WwW

—_

Ind. Code Ann. § 20-8.1-/7-3

Kansas Stat. Ann.

a’

Ky. Rev. Stat. § 1

La. Rev. Stat. § 17:156

Ma Gen. Laws Ann. ch. l

Mich. Compo. Laws Ann. § 15.

Mo. Ann. Stat. § 192.U/0

Physical

ev. Stat. § 18

duc. Law §§ 90

ent. Code § 15

ev. Code Ann,

Stat. Ann. tit

at. Ann. tit.

en. Laws § 16-

odified Laws An

Student

ic)

lmmunization

ode § 16-30-4

Stat. 14,30

Rey stat. Ann

tat. Ann. § 8-

UC « Code s 49

'@ a)

WwW

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Student

Haw

Lda

ind

Kan

a «

Me,

Md.

Mas

Mic

Man

Mic

Immunization

(

—

p=)

at.

ct?

)

Student

Code Ann.

Immunization

(J)

WwW?)

stat. & }

Code § 2

Code Ann,

cr “

tat. § 43

AAe SWS.

Laws § 16

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WO?

™

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cyl

}

—/

Student Immunization

Student Communicable Diseases

ME. Rev. Stat. Ann. tit. 20A, § 6301

Md. Educ. Code Ann. § 7-30(2)

Mass. Gen. Laws Ann. ch. 71, § 55A

Miss. Code Ann. § 37-7-301

Mo. Ann. Stat. § 167.191

cr?

- Code Ann. § 20-5-405

“J

ve)

—

Neb. Rev. Stat.

vev. Rev. Stat. § 439.510

ww?

—

rw"

Jhio Rey Code Ann. § 3313.55

Jkla. Stat. Ann. tit. 70, § 1210.194

PA stat. Ann tit 53, § 37306

- Lode Ann >» 44-29-2000

Student Communicable Diseases

Wash. Rev code Ann 5S 28A

- al + = ow ee Ww +

W.VA. Code L8h-3-1

41S. 9bat.« Ann. Wir r

7” P .

Nj o pe. ee ce

Teachers

Teachers Tuberculosis

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iISKa >~Lab e 2 i ea dda e@ 7 J

Ari? Ro rat Ann . 5 6

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Let tart Ann < 2 -

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This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.