The Illinois Appellate Court (Fourth District) recently held that school districts have the discretion to mandate completion of community service requirements as a prerequisite to graduation. 

In Earl v. Decatur Public Schools Board of Education, a parent sought to stop the Decatur Public Schools Board of Education from enforcing its policy requiring her student to complete six hours of community service for each year of high school attendance as a prerequisite to graduation. 

She asserted that Section 27-22 of the School Code set forth the minimum and maximum graduation requirements for Illinois schools and that community service is not one of the requirements.  She also argued that the legislature provided a volunteer service credit program allowing districts to offer course credit for community service work, thereby indicating that school districts are prohibited from making community service mandatory. 

The trial court found in favor of the school district, determining that districts can implement graduation requirements beyond those required by the School Code and pointing to Section 27-22e of the School Code, which provides that “[a]s a prerequisite to receiving a high school diploma, each pupil entering the 9th grade in the 2008-2009 school year or a subsequent school year must, in addition to other course requirements, successfully complete all of the following courses.” 

The court also noted that the ISBE regulations provide that school boards may adopt additional requirements for graduation.   

The parent subsequently appealed the trial court’s ruling, adding an argument that the mandatory service requirement constitutes a form of involuntary servitude.  The Appellate Court affirmed the trial court’s ruling, reiterating that the School Code provides school districts the discretion to add graduation requirements, such as service learning. 

The Court rejected the parent’s argument that the voluntary service credit program precludes mandatory service learning hours. The Court also found that the mandatory service requirement did not constitute a form of involuntary servitude because the requirement of six hours of service for each school year was “not unreasonable, onerous, or unduly burdensome making it akin to involuntary servitude.” 

This decision affirms the authority of school districts to add graduation requirements to those listed in the School Code, including mandatory service learning hours.