State of California, Department of Education v. William J. Bennett, Secretary, U.S. Department of Education

The State of California Department of Education (“California”) petitions for review of a final decision of the United States Secretary of Education (“Secretary”). The Secretary directed California to refund $699,450 to the United States Department of Education (“Department”). The Secretary concluded that these funds were not spent in accordance with the applicable grant requirements of Title I of the Elementary and Secondary Education Act of 1965, Pub.L. No. 89-10, 79 Stat. 27 (1965) (as amended) (“Title I”). We have jurisdiction under 20 U.S.C. §§ 1234d(b), 2851(a). We affirm in part, reverse in part and remand in part.

I

FACTS AND PROCEEDINGS

Title I served as a vehicle for distributing large educational grants from the federal government to local educational agencies. It was in effect from 1965 until 1981, when it was succeeded by Chapter 1 of the Education Consolidation and Improvement Act of 1981. Pub.L. No. 97-35, 95 Stat. 464 (1981); see Bennett v. New Jersey, 470 U.S. 632 , 634 n. 1, 105 S.Ct. 1555, n. 1 , 84 L.Ed.2d 572 (1985). The present petition concerns expenditures made by the Los Angeles Unified School District (“District”) during fiscal years 1981 and 1982,…