Whether a school district's deliberate manipulation of federal Title I enrollment counts to maximize funding allocations while systematically diverting funds from disadvantaged students violates Title I's mandatory allocation requirements

1. Whether a school dist rict’s deliberate manipu lation of federal Title I enrollment counts to maximize funding allocations—while systematically diverting those funds from the disadvantaged students who generated them—violates Title I’s mandatory allocation requirements under 34 C.F.R. §§ 200.78(a)(1) and 200.78(b)(1), regardless of wh ether a regulation specific ally prohibits the district’s precise manipulation scheme. 2. Whether the California Court of Appeal’s requirement that Ti tle I violations can only occur when regulations specifically prohibit an employer’s exact manipulation scheme conflicts with this Court’s prece dent in Bennett v. Kentucky Department of Education , 470 U.S. 656 (1985), which held Title I violations require repayment regardless of whether specific regulations prohibit the precise conduct. 3. Whether federal courts may effectively immu nize systematic subversion of Title I’s fundamental regulatory framework—including the rank -order allocation requirement of 34 C.F.R. § 200.78(a)(1) and the per -pupil minimum of 34 C.F.R. § 200.78(b)(1)— by requiring identification of regulations that anticipate each specific method of manipulation, thereby creating a dangerous safe harbor for creative violations of Title I’s comprehensive regulatory scheme. ii LIST OF PROCEEDINGS California Supreme Court No. S290506 Jason Camp , Plaintiff and Appellant v. Los Angeles Unified School District, Defendant and Appellant Petition for Review Denial : July 16, 2025 _ California Court of Appeal, Second Appellate District, Division Five No. B318925, B321227 (consolidated) Jason Camp , Plaintiff and Appellant v. Los Angeles Unified School District, Defendant and Appellant Opinion : March 25, 2025 Petition for Rehearing Denial : April 11, 2025 _ Los Angeles County Superior Court No. BC673403 Jason Camp, Plaintiff v. Los Angeles Unified School District, et al., Defendants Judgment November 3, 2021