EXECUTIVE SUMMARY
Priority Findings
- SECONDARY EMPLOYMENT: None documented
- TRANSPORTATION VENDOR: Unknown | Bypass miles: Unknown
SECTION 1: DISTRICT PROFILE AND FINANCIAL SNAPSHOT
| Field | Value |
|---|---|
| District Name | Athens CUSD 213 |
| Superintendent | Scott Laird |
| Phone | 217-636-8761 |
| Type | Unit District |
| County | Menard |
| City/Region | Athens |
| Enrollment | 947 |
| ISBE Entity ID | N/A |
| IL Senate District | IL-54 |
| IL House District | IL-108 |
| Title I Status | None |
| EBF Tier | 1 |
| EBF Adequacy % | 74.2% |
| Per-Pupil Expenditure | $5062.76 |
| ISBE Summative Rating | Not rated |
SECTION 3: BOARD COMPOSITION AND GOVERNANCE
3.0 — Current Board Members
| # | Name | Role | Source |
|---|---|---|---|
| 1 | Eric Gordon | President | verified |
| 2 | Kim Westervelt | Vice President | verified |
| 3 | Mark Shiffer | Secretary | verified |
| 4 | Shauna Ingram | Member | verified |
| 5 | Bryan Purchis | Member | verified |
| 6 | Wade Meteer | Member | verified |
| 7 | Valerie Woodrum | Member | verified |
3.1 — The Law
105 ILCS 5/10-10.5 prohibits more than 3 of 7 board members from the same PLSS township (6x6 mile cell). Violation = illegal board. 105 ILCS 5/10-11 makes those seats automatically vacant.
| Field | Value |
|---|---|
| Ultra Vires Votes | Not documented |
| Board Status (Forensic) | Not documented |
| Board Member of Note | Eric Gordon (President) |
| Secondary Employment | None documented |
3.2 — How to Verify Board Residency (Self-Help)
- Obtain board member residential addresses from Menard County Clerk voter registration records (public record)
- Map each address to PLSS Township/Range at geocommunicator.gov
- More than 3 of 7 board members in same 6x6 mile township = illegal board
- File Quo Warranto petition at Menard County Circuit Court: 735 ILCS 5/18-101
- All board actions during illegal period are voidable
SECTION 4: LEGAL COUNSEL — UNKNOWN
| Field | Value |
|---|---|
| Counsel of Record | Unknown |
| Address | Address not on file — search ARDC attorney directory at iardc.org |
| Fee Agreement Status | Not in governance audit |
| Hourly Billing Rate | $Unknown/hr |
| Annual Legal Spend | Unknown |
Documented Violations — Unknown
- Fee agreement status: Not in governance audit
- Annual legal spend: Unknown at $Unknown/hr
- 105 ILCS 5/10-22.21a — Competitive selection documentation not verified
How Taxpayers Can Act
- ARDC Complaint (attorney misconduct): iardc.org — File online, cite Rule 1.5, 1.7, 1.8 as applicable
- FOIA Request: Demand all executed fee agreements with Unknown for past 10 years
- Board Meeting Comment: Demand board produce signed contracts at next public meeting
- IL AG Complaint: If district refuses FOIA — illinoisattorneygeneral.gov/government/foi
- SEC Complaint (if bond counsel involved): sec.gov/tcr — cite Rule 15c2-12
SECTION 5: FOIA NON-COMPLIANCE AND TRANSPARENCY
No specific FOIA violation records on file for this district. Risk level: Unknown. This district should be served with FOIA requests per the template below.
FOIA Request Template for This District
Health/Life Safety Bond FOIA Request
FOIA Enforcement Chain
- Step 1: Submit written FOIA to district FOIA officer
- Step 2: If denied/delayed past 5 days — Appeal to Public Access Counselor: (217) 558-0486
- Step 3: If PAC ignored — File suit in Menard County Circuit Court (5 ILCS 140/11)
- Step 4: Court may award attorney fees if district willfully violated FOIA
SECTION 6: FINANCIAL FORENSICS
Transportation Analysis
| Item | Value | Flag |
|---|---|---|
| Transportation Vendor | Unknown | Unverified |
| Bypass Mileage Total | Unknown | Verify via PTCRS |
| Transport Irregularity | None documented | Not documented |
| Bid Law Status | Not documented | Verify |
| Section 29-5 Claim | N/A | Review ISBE PTCRS |
1. Look up PTCRS filings at apps.isbe.net/ptcrsinquiry
2. Compare cost-per-mile to Illinois average ($2.50/mile)
3. Check for year-over-year rate increases exceeding CPI (~3%/year)
4. FOIA: Request all transportation vendor contracts and invoices for 10 years
5. If cost-per-mile exceeds $5.00, file complaint with ISBE Finance Division
SECTION 7: DEMOGRAPHICS (ISBE 2025)
| Demographic | Percentage |
|---|---|
| White | 90.3% |
| Hispanic / Latino | 2.5% |
| Black / African American | * |
| Asian | * |
| MENA | * |
| Indicator | Percentage |
|---|---|
| Low Income | 34.1% |
| IEP (Special Education) | 16.4% |
| English Learner (EL) | * |
| Chronic Absenteeism | 16.7% |
| Student Attendance Rate | 93.8% |
SECTION 9: PROFICIENCY, POVERTY & CURRICULUM ACCESS ANALYSIS (2021–2025)
IAR scores (grades 3–8). 2021 = first post-COVID year (2020 cancelled). Poverty data from ISBE 2025 Report Card. CTE and services data from ISBE 2025.
5-Year Proficiency Trend (All Students)
| Metric | 2021 Post-COVID | 2022 | 2023 | 2024 | 2025 | 4-Yr Trend |
|---|---|---|---|---|---|---|
| ELA — All Students | 42.3% | 37.8% | 42.9% | 53.1% | 66.8% | ▲ +24.5pp |
| Math — All Students | 29.4% | 30.8% | 31.1% | 30.6% | 49.0% | ▲ +19.6pp |
| ELA — Low Income | 25.0% | 23.0% | 23.0% | 38.1% | 53.8% | |
| Math — Low Income | 16.2% | 18.2% | 16.3% | 15.8% | 30.3% | |
| ELA — IEP | 12.0% | 15.4% | — | — | 25.0% | |
| Math — IEP | 8.6% | 7.7% | — | — | 12.5% |
Poverty × Curriculum Access Analysis
This district is 34.1% low income. Research shows low-income students receive 40–50% fewer advanced course offerings and face 3× higher chronic absenteeism rates than peers.
| Indicator | All Students | Low Income | Black | Hispanic | Gap Analysis |
|---|---|---|---|---|---|
| ELA Proficiency (2025) | 66.8% | 53.8% | — | 50.0% | +13.0pp Low Inc gap |
| Math Proficiency (2025) | 49.0% | 30.3% | — | 33.3% | +18.7pp Low Inc gap |
| 9th Grade On Track | 83.1% | 60.0% | — | — | +23.1pp Low Inc gap |
| 4-Year Graduation Rate | 89.0% | 73.3% | — | — | +15.7pp Low Inc gap |
| Chronic Absenteeism | 16.7% | Elevated absenteeism directly correlates with low-income housing instability, lack of transportation, and food insecurity. | Moderate | ||
| CTE Participants (Total) | 235 | 77 (32.8% of CTE) | If low-income % of CTE < district low-income enrollment %, students are underrepresented in career pathways. | ✓ Access OK | |
| CTE Postsecondary Placement (Low Inc) | — | Perkins Act target: 60%+ | |||
| Out-of-School Suspensions | 2.3% | Suspensions remove students from instruction — disproportionately affecting low-income and minority students. | Moderate | ||
School Support Services vs. Poverty Need
High-poverty districts require MORE support staff, yet IL data consistently shows they have FEWER. National standards shown for comparison.
| Service | This District | National Standard | Status | Poverty Impact |
|---|---|---|---|---|
| School Counselor | 1:493 | 1:250 (ASCA/NASN) | ⚠ Understaffed | Low-income students need 2× counselor time for FAFSA, mental health, career planning |
| School Nurse | — | 1:750 (ASCA/NASN) | — | Homeless/food-insecure students present at nurse 3× more frequently |
| School Psychologist | — | 1:500 (ASCA/NASN) | — | Trauma, poverty-related stress, and IEP evaluations increase dramatically with poverty |
| School Social Worker | 1:1578 | 1:250 (ASCA/NASN) | ⚠ Understaffed | Social workers are the primary poverty-intervention link between school and family |
EBF = Evidence-Based Funding adequacy vs IL formula. 100% = fully funded. Districts below 60% cannot adequately staff poverty interventions, counselors, or CTE programs.
County Poverty Rate: 10.1% | Median Household Income: $82,176 | Bachelor's Degree+: 28.3% | County Population: 12,095
County poverty and education attainment are the strongest predictors of school district chronic absenteeism, CTE access gaps, and IAR proficiency. Districts in high-poverty counties require proportionally greater state EBF investment.
SECTION 8: CTE AND DUAL CREDIT ANALYSIS
Total CTE Concentrators (ISBE 2025): 235
CTE Concentrators by Sector
| Sector | Concentrators |
|---|---|
| Information Technology | NONE |
| Health Sciences | NONE |
| Health Occupations | NONE |
| Business Management | NONE |
| Law & Public Safety | NONE |
| Construction & Architecture | NONE |
| Transportation | NONE |
| Agriculture & Natural Resources | 56 |
| Arts & AV Technology | NONE |
| Finance | NONE |
Healthcare / CNA / Nursing | IT and Cybersecurity | Agriculture Technology | Manufacturing and Trades | Business Management
Local regional community college — check ICCB district map at iccb.org
How to Force Dual Credit Expansion
- Perkins V (20 USC 2301): File complaint with ISBE CTE division if district receives Perkins funds but restricts access by race/income
- FOIA: Request all articulation agreements with community colleges for dual credit
- Attend board meeting, demand agenda item on dual credit expansion plan
- Contact nearest community college Office of Dual Credit
- File OCR complaint at ed.gov/about/offices/list/ocr if access gap correlates with race (Title VI)
SECTION 10: BOND ISSUANCE AND DEBT — MSRB EMMA VERIFIED
| Bond Series | Issue Date | Total Par | First Maturity | Last Maturity | Maturities |
|---|---|---|---|---|---|
| GENERAL OBLIGATION LIMITED SCHOOL BONDS, SERIES 2013 | 06/14/2013 | $1,500,000 | 02/01/2029 | 02/01/2029 | 4 |
| GENERAL OBLIGATION SCHOOL BONDS, SERIES 2018A | 06/12/2018 | $30,585,000 | 12/01/2026 | 12/01/2034 | 30 |
File SEC complaint at: sec.gov/tcr
STUDENT GROWTH ANALYSIS — ISBE 2024 COHORT vs BASELINE
Student Growth Percentile (SGP) measures how much students grew relative to their academic peers. The 2024 cohort vs baseline shows Athens CUSD 213's growth gap — a negative gap means 2024 students are performing below their baseline peers.
| Subject | 2024 Cohort SGP | 2024 Baseline SGP | Gap | Status |
|---|---|---|---|---|
| ELA / Reading | 46.3% | 59.0% | -12.7 pts vs baseline | Declining |
| Mathematics | 40.9% | 45.4% | -4.4 pts vs baseline | On Track |
SECTION 12: STATUTORY COMPLIANCE SCORECARD
| Compliance Item | Status | Statute | |
|---|---|---|---|
| 🟢 | Written fee agreement with counsel | PASS | ARDC Rule 1.5 |
| 🟢 | Board composition — no ultra vires votes | PASS | 105 ILCS 5/10-10.5 / 10-11 |
| 🟢 | Legal spend documented in governance audit | PASS | 105 ILCS 5/10-22.21a |
| 🟢 | Transportation vendor — competitive bid on file | PASS | 105 ILCS 5/29-3 |
| 🟢 | Transportation mileage accuracy | PASS | ISBE PTCRS reporting |
| 🟢 | Bid law compliance on construction | PASS | 30 ILCS 500 / 105 ILCS 5/10-20.21 |
| 🟢 | FOIA compliance — timely/complete responses | PASS | 5 ILCS 140 |
| 🟢 | CTE program availability for students | PASS | 20 USC 2301 (Perkins V) |
| 🔴 | Title I equitable services compliance | FAIL | 20 USC 6321 |
| 🟢 | Equity: CTE access for low-income students | PASS | Title VI / Perkins V |
| 🟢 | Board member secondary employment disclosure | PASS | 5 ILCS 420 |
| 🟢 | SEC Rule 15c2-12 bond disclosure review | PASS | SEC Rule 15c2-12 / MSRB Rule G-17 |
FAIL = non-compliance documented or strongly indicated | PASS = compliant or uncontradicted | Based on available public records only.
SECTION 12B: DATA-DRIVEN STATUTORY COMPLIANCE FLAGS
Generated from ISBE 2025 Report Card data cross-referenced against federal and Illinois statutes. 3 VIOLATION(S) | 5 WARNING(S) detected from public data. Not all violations are detectable from public data alone — FOIA requests required to confirm.
| Compliance Finding | Status | Statute / Authority | |
|---|---|---|---|
| 🟡 | Chronic absenteeism 10–20% — monitoring required 16.7% chronically absent. Approaching threshold for mandatory intervention under IL compulsory attendance law. | WARNING | ESSA §1111(g)(1)(C); 105 ILCS 5/26-2a |
| 🟡 | EBF adequacy 72.0% — underfunded District receives 72.0% of its evidence-based funding adequacy target. Underfunding directly limits counselor staffing, special education services, and CTE programs. | WARNING | 105 ILCS 5/18-8.15 |
| 🟡 | IEP students at 25.0% ELA proficiency — IDEA review warranted 25.0% IEP ELA proficiency. Review whether IEP goals are sufficiently ambitious and whether services are being delivered with fidelity. | WARNING | IDEA §612(a)(1); 23 IAC Part 226.230 |
| 🔴 | IEP/general ed ELA gap: 41.8pp — LRE and inclusion concern 41.8pp gap between IEP and all-student ELA proficiency. IDEA requires educating students with disabilities in the Least Restrictive Environment (LRE). A large gap may indicate excessive pullout/self-contained placement without adequate general ed access. | VIOLATION | IDEA §612(a)(5) / 20 USC 1412(a)(5); 23 IAC 226.310 |
| 🟡 | 2.3% OOS suspension rate — monitor for racial disparity FOIA request: demand suspension data broken down by race, grade, and disability status. Compare to enrollment demographics to identify racial disparity. | WARNING | 105 ILCS 5/10-22.6; Title VI / 42 USC 2000d |
| 🟡 | 1:493 counselor ratio — below ASCA standard 1:493 ratio exceeds 1:250 ASCA standard. In a high-poverty district, this gap directly reduces academic achievement and postsecondary access. | WARNING | ESSA §8101(52); ISBE School Counseling Guidelines |
| 🔴 | 9th grade on-track gap: 23.1pp (all 83.1% vs low-income 60.0%) A 23.1pp on-track gap between all students and low-income students at 9th grade is the single strongest predictor of dropout. Requires targeted ESSA Title I intervention documentation. | VIOLATION | ESSA §1111(b)(2) accountability; 105 ILCS 5/26-1 compulsory attendance |
| 🔴 | Low-income graduation rate: 73.3% — below 75% threshold Only 73.3% of low-income students graduate in 4 years. ESSA uses graduation rate as a primary accountability indicator. This rate may independently trigger Comprehensive Support designation. | VIOLATION | ESSA §1111(d) Comprehensive Support trigger; 105 ILCS 5/26-1 |
SECTION 14: TAXPAYER LEGAL ROADMAP — FILE IT YOURSELF
Action 1 — FOIA Request (No Attorney Needed)
- Send written FOIA to Athens CUSD 213 FOIA Officer (find on district website)
- Statutory basis: 5 ILCS 140 — District must respond within 5 business days
- If denied: Appeal to IL AG Public Access Counselor — (217) 558-0486
- Website: illinoisattorneygeneral.gov/government/foi
Action 2 — ARDC Complaint Against Attorneys (No Attorney Needed)
- File online at iardc.org/Complaints/complaint.asp
- Cite: ARDC Rule 1.5 (no written fee agreement), Rule 1.7 (conflicts), Rule 1.8
- Name the attorney(s) at Unknown responsible for this district
- Attach: FOIA response showing no signed contract; billing statements if available
Action 3 — Quo Warranto Petition (Board Illegality)
- File petition at: Menard County Circuit Court
- Statute: 735 ILCS 5/18-101 — Quo Warranto
- Prerequisite: Obtain leave of court OR get IL AG to file on your behalf
- Evidence needed: Board member addresses (county clerk voter reg) + PLSS township maps
- Cost: Circuit court filing fee (~$250-400) + service of process
- Result: Ouster of illegally seated board members; all illegal actions voidable
Action 4 — SEC Complaint (Bond Fraud)
- File at: sec.gov/tcr
- Cite: SEC Rule 15c2-12 — Material disclosure failure
- Attach: EMMA filing gaps for this district + proof of illegal board at time of issuance
- No attorney required; SEC investigates anonymously if requested
Action 5 — OCR Complaint (Civil Rights / Curriculum Access)
- File at: ed.gov/about/offices/list/ocr
- Cite: Title VI (42 U.S.C. 2000d) — Discriminatory denial of CTE/AP access by race
- Evidence: CTE concentrator data by race (ISBE Report Card) showing equity gap
- Cite: Perkins V (20 USC 2301) — CTE access requirements
Action 6 — ISBE Complaint (District Regulatory Failure)
- File with ISBE at: isbe.net
- Issues: EBF underfunding, PTCRS mileage fraud, CTE non-compliance, board governance failures
- Contact: ISBE Regional Superintendent for Menard County
Michael F. Henry | Illinois Statewide School District Compliance and Equity Audit | orlandmfh@gmail.com
All data is public record. Prepared as part of statewide accountability audit filed with ISBE, ARDC, SEC, and MSRB.