EXECUTIVE SUMMARY
This is a public record forensic audit of Valmeyer CUSD 3. Data sourced from ISBE 2025 Report Card, Illinois Statewide Education Governance and Financial Audit 2026, MSRB EMMA bond registry, and ISBE Annual Financial Report. All findings based on public records. Zero FOIA requests to this district required to compile this report.
Estimated Taxpayer Waste
$0
Board Status
NO
Counsel Contract
VERIFIED
Annual Legal Spend
$0.4M
EBF Funding Tier
Tier 4 (115.4%)
ISBE Summative Rating
Not rated
Priority Findings
- SECONDARY EMPLOYMENT: None documented
- TRANSPORTATION VENDOR: Unknown | Bypass miles: Unknown
SECTION 1: DISTRICT PROFILE AND FINANCIAL SNAPSHOT
| Field | Value |
|---|---|
| District Name | Valmeyer CUSD 3 |
| Superintendent | Mr. Eric Frankford |
| Phone | 618-935-2100 |
| Type | Unit District |
| County | Monroe |
| City/Region | Valmeyer |
| Enrollment | 327 |
| ISBE Entity ID | ENT-0421 |
| IL Senate District | IL-58 |
| IL House District | IL-115 |
| Title I Status | None |
| EBF Tier | 4 |
| EBF Adequacy % | 115.4% |
| Per-Pupil Expenditure | $7060.78 |
| ISBE Summative Rating | Not rated |
EBF Adequacy
115.4%
Adequately funded
EBF Tier 4: This district is receiving full funding.
SECTION 3: BOARD COMPOSITION AND GOVERNANCE
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 | NO |
| Board Status (Forensic) | NO |
| Board Member of Note | Member_PN |
| Secondary Employment | None documented |
No ultra vires votes confirmed from available governance data. Board composition should still be independently verified using county clerk voter registration records vs. PLSS township coordinates.
3.2 — How to Verify Board Residency (Self-Help)
- Obtain board member residential addresses from Monroe 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 Monroe County Circuit Court: 735 ILCS 5/18-101
- All board actions during illegal period are voidable
SECTION 4: LEGAL COUNSEL — HODGES LOIZZI
| Field | Value |
|---|---|
| Counsel of Record | Hodges Loizzi |
| Address | Address not on file — search ARDC attorney directory at iardc.org |
| Fee Agreement Status | VERIFIED |
| Hourly Billing Rate | $350/hr |
| Annual Legal Spend | $0.4M |
Fee agreement status: VERIFIED. Verify by requesting copy of executed engagement letter via FOIA (5 ILCS 140).
Documented Violations — Hodges Loizzi
- Fee agreement status: VERIFIED
- Annual legal spend: $0.4M at $350/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 Hodges Loizzi 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
To: FOIA Officer, Valmeyer CUSD 3
Request 1 — LEGAL FEES:
All executed fee agreements with Hodges Loizzi or any law firm, FY2015-present.
All legal invoices paid to Hodges Loizzi, FY2015-present, including hourly rate and matter description.
Request 2 — TRANSPORTATION:
All transportation service contracts, FY2010-present, with vendor names and rates.
All ISBE PTCRS submissions, FY2010-present.
Request 3 — BOARD GOVERNANCE:
All board member residential addresses.
All Statement of Economic Interest filings by board members, FY2020-present.
All board meeting minutes where attorney was in attendance, FY2020-present.
Request 4 — BONDS AND FINANCE:
All bond resolutions, official statements, and continuing disclosure filings, FY2010-present.
All construction contracts over $25,000, FY2015-present.
Request 5 — CTE AND CURRICULUM:
All articulation agreements with community colleges for dual credit.
All curriculum adoption minutes and voting records, FY2015-present.
Statutory basis: 5 ILCS 140/3. Response required within 5 business days.
Non-compliance: File complaint at illinoisattorneygeneral.gov/government/foi
Health/Life Safety Bond FOIA Request
Health/Life Safety (SFPS) Bond Records Request — 5 ILCS 140/3:
1. All HLS 10-year facility survey reports (FY2010-present) — include engineer/architect name and firm.
2. All SFPS bond authorizations and board resolutions (FY2010-present).
3. All construction contracts for HLS/SFPS projects — include contractor, amount, and bid process.
4. All called-inspection records and certificates of occupancy for HLS projects (FY2010-present).
5. All financial advisor and bond counsel invoices for SFPS bond issuances (FY2010-present).
NOTE: SFPS bonds do not require voter approval and are exempt from PTELL tax caps.
Verify that all bond proceeds were spent on certified HLS violations — not cosmetic renovation.
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 Monroe County Circuit Court (5 ILCS 140/11)
- Step 4: Court may award attorney fees if district willfully violated FOIA
SECTION 6: FINANCIAL FORENSICS
Enrollment
3-Year Proficiency Trend (2022 → 2025): ELA: 23.9% → 43.2% ▲ +19.3% | Math: 21.0% → 27.8% ▲ +6.8%
327
Per-Pupil Expenditure
$7060.78
EBF Adequacy
115.4%
Annual Legal Spend
$0.4M
Hourly Legal Rate
$350/hr
Est. Total Waste
$0
ELA Proficiency
43.2%
Math Proficiency
27.8%
4-Year Grad Rate
90.9%
9th Grade On Track
96.8%
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 |
How to verify transportation fraud:
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
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 | 97.2% |
| Hispanic / Latino | * |
| Black / African American | * |
| Asian | * |
| MENA | * |
| Indicator | Percentage |
|---|---|
| Low Income | 22.3% |
| IEP (Special Education) | 11.6% |
| English Learner (EL) | * |
| Chronic Absenteeism | 16.1% |
| Student Attendance Rate | 93.9% |
Demographic to Curriculum Gap: A district that is 22.3% low-income and *% Hispanic with 62 CTE concentrators is providing some CTE access — see sector gaps below.
Source: ISBE 2025 Report Card — Verified Data
Illinois Religious Context (ARDA 2020): Statewide, Catholic adherents declined 28% (1990–2020); Islam tripled to 311K adherents; Evangelical Protestant grew 54%; Mainline Protestant fell 48%. Religious demographic shifts directly affect public school enrollment patterns, board composition, and curriculum policy. View 30-Year Illinois Religious Trend →
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 | 24.1% | 23.9% | 16.0% | 23.5% | 40.6% | ▲ +16.5pp |
| Math — All Students | 20.9% | 21.0% | 18.1% | 13.1% | 24.5% | → +3.6pp |
| ELA — Low Income | 13.2% | 18.2% | 11.5% | 26.5% | 31.3% | |
| Math — Low Income | 10.5% | 12.1% | 15.7% | 10.2% | 12.5% | |
| ELA — IEP | 5.6% | 0.0% | 10.3% | 5.0% | 10.5% | |
| Math — IEP | 0.0% | 4.3% | 3.4% | 5.0% | 0.0% |
+9.3pp ELA Low Income gap vs All (2025)+30.1pp ELA IEP gap vs All (2025)+12.0pp Math Low Income gap vs All (2025)+24.5pp Math IEP gap vs All (2025)
Poverty × Curriculum Access Analysis
This district is 22.3% low income. | 4.6% homeless students. 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) | 40.6% | 31.3% | — | — | +9.3pp Low Inc gap |
| Math Proficiency (2025) | 24.5% | 12.5% | — | — | +12.0pp Low Inc gap |
| 9th Grade On Track | 96.8% | — | — | — | |
| 4-Year Graduation Rate | 90.9% | — | — | — | |
| Chronic Absenteeism | 16.1% | Elevated absenteeism directly correlates with low-income housing instability, lack of transportation, and food insecurity. | Moderate | ||
| CTE Participants (Total) | 62 | 11 (17.7% 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 | 60.0% | Suspensions remove students from instruction — disproportionately affecting low-income and minority students. | ⚠ High | ||
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 | 1:327 | 1:250 (ASCA/NASN) | — | Low-income students need 2× counselor time for FAFSA, mental health, career planning |
| School Nurse | 1:327 | 1:750 (ASCA/NASN) | ✓ Adequate | Homeless/food-insecure students present at nurse 3× more frequently |
| School Psychologist | 1:818 | 1:500 (ASCA/NASN) | ⚠ Understaffed | Trauma, poverty-related stress, and IEP evaluations increase dramatically with poverty |
| School Social Worker | 1:252 | 1:250 (ASCA/NASN) | — | Social workers are the primary poverty-intervention link between school and family |
Why this matters: A district that is 22.3% low income with a 1:327 counselor ratio has a structural barrier to poverty intervention built into its staffing model. FOIA request: demand the district's staffing plan and how it addresses ESSA Section 1114 schoolwide program requirements.
💰 FY2024 Finance (ISBE):
Per-Pupil Expenditure: $14,946 |
EBF Adequacy: 101.0% (Tier 4)
EBF = Evidence-Based Funding adequacy vs IL formula. 100% = fully funded. Districts below 60% cannot adequately staff poverty interventions, counselors, or CTE programs.
EBF = Evidence-Based Funding adequacy vs IL formula. 100% = fully funded. Districts below 60% cannot adequately staff poverty interventions, counselors, or CTE programs.
📍 Monroe County Economic Context (ACS 2024):
County Poverty Rate: 5.0% | Median Household Income: $102,880 | Bachelor's Degree+: 38.7% | County Population: 35,036
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.
County Poverty Rate: 5.0% | Median Household Income: $102,880 | Bachelor's Degree+: 38.7% | County Population: 35,036
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): 62
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 | 32 |
| Arts & AV Technology | NONE |
| Finance | NONE |
No specific access gap documented. Review CTE concentrator data by race/income for equity gaps.
What this district should offer (based on demographics):
Healthcare / CNA / Nursing | IT and Cybersecurity | Agriculture Technology | Manufacturing and Trades | Business Management
Healthcare / CNA / Nursing | IT and Cybersecurity | Agriculture Technology | Manufacturing and Trades | Business Management
Nearest Community College Partners:
Local regional community college — check ICCB district map at iccb.org
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
⚠ MSRB EMMA DATA — 2 Bond Series: Valmeyer CUSD 3 has issued bonds across 2 series. Total par value on record: $6,750,000. SEC Rule 15c2-12 requires continuing disclosure on all active issuances.
| Bond Series | Issue Date | Total Par | First Maturity | Last Maturity | Maturities |
|---|---|---|---|---|---|
| DEBT CERTIFICATES, SERIES 2023 | 06/29/2023 | $4,020,000 | 12/01/2026 | 12/01/2031 | 24 |
| GENERAL OBLIGATION LIMITED TAX SCHOOL BONDS SERIES 2021 | 06/15/2021 | $2,730,000 | 12/01/2026 | 12/01/2038 | 8 |
SEC Rule 15c2-12: Requires continuing disclosure on MSRB EMMA. Failure to file annual reports or material event notices is a federal securities violation.
File SEC complaint at: sec.gov/tcr
File SEC complaint at: sec.gov/tcr
Bond Market Context: Illinois school district bonds are underwritten by firms including Bernardi Securities, Raymond James, Baird, and Stifel. Health/Life Safety (SFPS) bonds (105 ILCS 5/17-2.11) can be issued WITHOUT voter approval and are exempt from PTELL tax caps. New legislation effective July 2024 further expanded no-referendum bonding authority. View Illinois Bond Market & Underwriter Guide →
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 Valmeyer CUSD 3's growth gap — a negative gap means 2024 students are performing below their baseline peers.
ELA Growth vs Baseline (2024)
▼ -13.1 pts
2024 Cohort: 43.6% | Baseline: 56.7%
Math Growth vs Baseline (2024)
▼ -4.8 pts
2024 Cohort: 34.7% | Baseline: 39.5%
| Subject | 2024 Cohort SGP | 2024 Baseline SGP | Gap | Status |
|---|---|---|---|---|
| ELA / Reading | 43.6% | 56.7% | -13.1 pts vs baseline | Declining |
| Mathematics | 34.7% | 39.5% | -4.8 pts vs baseline | On Track |
Color Key: Green = growth gap > -5 pts (on track) | Yellow = -5 to -10 pts (caution) | Red = < -10 pts (declining cohort). Source: ISBE 2024 Student Growth Data — Verified.
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 | FAIL | 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 | FAIL | 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) | 2 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 16.1% chronically absent. Approaching threshold for mandatory intervention under IL compulsory attendance law. | WARNING | ESSA §1111(g)(1)(C); 105 ILCS 5/26-2a |
| 🔴 | IEP students at 10.5% ELA proficiency — FAPE question Only 10.5% of IEP students proficient in ELA. Under IDEA, districts must provide a Free Appropriate Public Education (FAPE) enabling meaningful educational progress. This rate suggests IEP goals and services may not be providing FAPE. ISBE APR Indicator 3 reporting required. | VIOLATION | IDEA §612(a)(1) / 20 USC 1412; 23 IAC Part 226 |
| 🔴 | IEP/general ed ELA gap: 30.1pp — LRE and inclusion concern 30.1pp 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 |
| 🔴 | 4.6% students homeless — McKinney-Vento liaison required 4.6% of students identified as homeless. Each district MUST have a designated homeless liaison, must immediately enroll homeless students without records, and must provide transportation to school of origin. FOIA: demand liaison designation letter and services log. | CHECK REQUIRED | McKinney-Vento Act / 42 USC 11431; ESSA Title IX Part A |
| 🔴 | 60.0% out-of-school suspension rate — disproportionality review required 60.0% OOS suspension rate. IL law limits K-3 suspensions (10-22.6b). For IEP students, suspension >10 days triggers manifestation determination (23 IAC 226.730). Racial disproportionality in discipline is a Title VI violation. | VIOLATION | 105 ILCS 5/10-22.6; IDEA 23 IAC 226.730; Title VI |
How to act on these findings: Each violation listed above has a corresponding complaint pathway.
ESSA violations → ISBE complaint or US DOE Office of Elementary & Secondary Education.
IDEA violations → IL State Complaint to ISBE Special Education Services, or Due Process Hearing.
Title VI/IX → OCR complaint at ocrcas.ed.gov (free, no attorney required).
Perkins V → IL DCEO complaint.
FOIA violations → IL Attorney General Public Access Counselor: (312) 814-5526.
SECTION 14: TAXPAYER LEGAL ROADMAP — FILE IT YOURSELF
You do not need an attorney to initiate most of these actions. This district is in Monroe County. Your filing court is the Monroe County Circuit Court.
Action 1 — FOIA Request (No Attorney Needed)
- Send written FOIA to Valmeyer CUSD 3 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 Hodges Loizzi 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: Monroe 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 Monroe County
Contact / Statewide Audit:
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.
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.