Cahokia CUSD 187 — Chapter XII Compliance Flag Matrix

Captured: 2026-05-16

Framework: Illinois Public Education Accountability Project — Chapter XII Master Audit Violation Matrix

Applicable statutes cited per the framework: 105 ILCS 5/10-3, 5/10-9, 5/17-2.11, 5/10-23.8, 5 ILCS 140, 5 ILCS 120, 50 ILCS 105, 5 ILCS 430, 5 ILCS 420, 65 ILCS 5/11-74.4

District context (input parameters):

Tier 1 EBF district (lowest funded — under 73% of adequacy target)

13.3% ELA proficiency (#3 lowest in Illinois per illinoisschooldistrictaudit.com)

7-member elected Board of Education (April 2023 election)

Successor district to consolidation of CCSD 187 + CHSD 188 (July 1, 2008)

Currently constructing new Cahokia High School

Active union-allegation file (Cahokia Federation of Teachers Local 1272, Feb-Mar 2026): $1M+ supplemental payments to Asst. Supt. Arnett Harvey; Harvey is married to CFO Ciara Corley.

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TIER A — HIGH-CONFIDENCE FLAGS (probable violations on evidentiary record)

A1. Nepotism — Asst. Superintendent / CFO spousal supervisory relationship

Statute: 105 ILCS 5/10-23.8 (Nepotism Prohibition); Cahokia 187 Policy 5:120 (Employee Ethics)

Evidence on record (sourced):

Cahokia 187 administration page lists Mr. Arnett Harvey — Assistant Superintendent and Ciara Corley — CFO.

Multiple news outlets (FOX 2 St. Louis, STLPR/NPR, First Alert 4, Labor Tribune) report Harvey's wife is Ciara Corley.

Why this is a flag: The CFO controls payroll, supplemental pay authorization, expense reimbursement, and audit-preparation workflow. A direct spousal relationship between CFO and an Assistant Superintendent receiving alleged supplemental pay >$1M creates an inherent conflict of interest. Absent strict segregation of duties (verified by board minutes recusal and independent supervisor sign-off), this is a per-se 10-23.8 violation.

Legal consequence (per Chapter XII): Removal; vote voidable; potential Class 4 Felony for any board member voting on related-party employment without disclosure.

Required verification:

FOIA: payroll records 2019-present for Harvey

FOIA: every board action item, agenda + minutes, where Harvey's contract, pay, or supplemental compensation was approved — identify recusals

FOIA: written conflict-of-interest disclosure required under Policy 2:100 / 5:120

Cross-flag: If board approved Harvey's pay packages without documented Corley-absent finance approval chain, the audit also implicates 5 ILCS 430 (Ethics Act) and 5 ILCS 120/2(c) (improper executive session).

A2. Sister/Spouse on Board — surname clusters

Statute: 105 ILCS 5/10-23.8; 50 ILCS 105/3; 5 ILCS 420/4A-101 (SEI)

Evidence:

Duncan cluster: Richard Duncan Sr. (Vice President) and Debra Duncan (Secretary) — same surname, concurrent 4-year terms.

Jackson cluster: Marius "Mark" Jackson (Board President) + Faith Jackson (Director of Student Activities) + Drake Jackson (Director of Family Support Services).

Why this is a flag: The IL School Code permits related persons to serve concurrently on the board, BUT 10-23.8 forbids voting on hiring/contracts of relatives. If President Jackson voted on the appointment/retention of Faith or Drake Jackson, that vote is voidable.

Required verification:

FOIA: every personnel action (hire, promotion, contract renewal, dismissal, layoff, transfer, supplemental pay) for Faith Jackson and Drake Jackson since 2019 — match board vote records.

FOIA: Statement of Economic Interests filings (5 ILCS 420/4A-101) at St. Clair County Clerk — verify all 7 board members + cabinet have filed annually.

A3. Statement of Economic Interests filings

Statute: 5 ILCS 420/4A-101 (annual SEI by May 1 to St. Clair County Clerk)

Required of: All 7 board members; superintendent; all administrators with discretionary authority over contracts or hiring.

Verification: FOIA to St. Clair County Clerk for all SEI filings by name for years 2019-2025. Missing filing = fine + potential removal from office.

A4. Limitation of Administrative Costs / Pay (105 ILCS 5/17-1.5)

Statute: Admin cost capped at 5% of operating cost; exceedance requires ISBE waiver.

Evidence: Cahokia 187 publishes a "Limitation of Administrative Costs Worksheet" (2018; 2024 current).

Audit step: Compute (admin cost ÷ operating cost) for FY17-FY25 from AFRs. If any year >5% without ISBE waiver = violation. Especially scrutinize years coinciding with Harvey's alleged supplemental pay.

A5. OMA — board recordkeeping & retention

Statute: 5 ILCS 120/2.06 (verbatim records of executive session — 18 month retention minimum); 5 ILCS 120/2.02 (agenda posting 48 hr; minutes within 7 days after approval)

Audit step: FOIA all agendas, open + executive minutes, and exec-session verbatim recordings for 2017-2026. Verify no votes on non-agenda items.

A6. FOIA compliance

Statute: 5 ILCS 140/3(d) (5 business day response); 140/11 (judicial review; $2,500/violation; attorney's fees)

Audit step: Submit a structured set of FOIA requests; track 5-day response window; document any failures for PAC complaint.

A7. Open-bid / contract conflicts

Statute: 105 ILCS 5/10-20.21 (competitive bid for purchases/contracts ≥$25,000)

Audit step: Pull "Vendors over $25,000" file (Annual Statement of Affairs 105 ILCS 5/10-17). Cross-reference vendor list against:

All 7 board member surnames

All cabinet/admin surnames

Stephen Brown's outside employers (City of Cahokia Heights / CHPD)

Any LLC where a board member or administrator is a member

Per Chapter XII consequence: Contract void; Class 4 Felony; removal from office.

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TIER B — STRUCTURAL / STATUTORY EXPOSURE (verification needed)

B1. New Cahokia HS construction — bond compliance

Statutes: 105 ILCS 5/17-2 (referendum), 5/17-2.11 (Life Safety, no referendum); 5/17-9; SEC Rule 15c2-12; 15 USC 78j

Action needed: Pull MSRB EMMA Official Statement for the bond(s) financing the new HS. Identify whether GO (referendum) or Life Safety (ISBE survey approval required).

If Life Safety: verify ISBE-approved Life Safety Survey on file in ISBE's records; verify FPS Fund (105 ILCS 5/17-2.11(e)) used only for approved items.

If GO: verify referendum on file with St. Clair County Clerk (date, ballot language, vote totals).

B2. ISBE Financial Profile / Financial Watch

Statute: 105 ILCS 5/1A-8; 105 ILCS 5/1B (Financial Oversight Panel) — invoked if district falls onto Financial Watch.

Action needed: Pull Cahokia 187's annual Financial Profile score and designation for FY15-FY24 from ISBE. Determine if district has ever been on Financial Watch or had FOP recommended.

B3. TIF revenue diversion (if applicable in Cahokia Heights)

Statute: 65 ILCS 5/11-74.4-5(d) — school board entitled to seat on Joint Review Board for any TIF affecting district revenue

Action needed: Identify any TIF districts overlapping Cahokia 187 territory in former Cahokia / Centreville / Alorton areas; pull Joint Review Board records; verify district was not silent on revenue diversion.

B4. Mandated reporter training compliance

Statute: 325 ILCS 5; 105 ILCS 5/24-5

Action needed: FOIA mandated-reporter training certifications for every district employee for last 5 years.

B5. PERA / Teacher Evaluation Plan

Statute: 105 ILCS 5/24A (PERA); ISBE rules at 23 IAC 50

Action needed: Pull current Teacher Evaluation Plan; verify joint committee composition; verify use of student-growth data per 24A-2.5.

B6. ESSER III / federal grant compliance

Authority: 2 CFR Part 200 (Uniform Guidance); ARPA Section 2001

Action needed: Cross-check Cahokia 187 ESSER III expenditures against approved plan (https://docs.google.com/document/d/102_R7u6xk7r2CH3ZR663puw4SJ0K4oGFFZk1Rza44rs). Verify time-and-effort certifications for grant-funded positions including Minnie Taylor ("21st Century Grant" listing).

B7. Dual-employment / incompatible offices — Stephen Brown

Statute: 50 ILCS 105/3 (incompatible offices); 5 ILCS 430 (Ethics)

Allegation: Stephen Brown serves as full-time attendance officer for Cahokia 187 AND Chief of Police, City of Cahokia Heights.

Required verification: Pull (a) Brown's district personnel file + work hours; (b) City of Cahokia Heights police dept records; verify no overlapping work hours, no pay-while-elsewhere, no use of district resources for police duties (or vice versa).

B8. Annual Statement of Affairs (105 ILCS 5/10-17)

Statute: Each district must publish ASA annually showing all employees + salaries + vendors >$25,000.

Action needed: Captured FY25 ASA. FOIA FY17-FY24 ASAs. Verify (a) all salaries published, (b) supplemental pay to Harvey listed where applicable, (c) vendor list complete.

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TIER C — INVESTIGATIVE LEADS (require external corroboration)

C1. TRS service-credit / pension-spiking

Compare Harvey's TRS-reported salary with district payroll. Discrepancies trigger pension-spiking analysis under 105 ILCS 5/16-133.

Union has explicitly requested TRS audit (see data_reporting/data_reporting.md).

C2. Cahokia Heights municipal employment overlap

Cahokia Heights was incorporated only in 2021 (from Cahokia, Centreville, Alorton). Verify which board members or administrators hold or held municipal office in any of the predecessor municipalities or Cahokia Heights.

C3. Special education compliance

The Special Education department had 20 staff (largest department per Apptegy directory). Verify IDEA / 504 compliance, MTSS, FAPE litigation history.

C4. EBF litigation status

Cahokia 187 was lead plaintiff in Cahokia Unit School District No. 187 v. Pritzker, 2021 IL Supreme Court Docket 126212 (challenging EBF formula adequacy). Pull final order; verify district has filed any subsequent litigation.

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Recommended FOIA package (template)

Address: District Office, Cahokia Heights, IL

REQUEST (5 ILCS 140; 5-business-day response):

All board agendas, minutes, and exec-session verbatim recordings, 7/1/2017–present

All annual budgets (Form 50-36), AFRs, audits, management letters, FY17-FY25

All Annual Statements of Affairs, FY17-FY25

All Statement of Economic Interest filings for board members + senior admin, FY17-FY25

All employment contracts, salary schedules, supplemental pay agreements for: Curtis McCall Jr., Arnett Harvey, Ciara Corley, Tanya Mitchell, Stephen Brown, Leonard Manley, Minnie Taylor, Faith Jackson, Drake Jackson — FY17-present

All marriage/relationship disclosure forms filed by district employees under Policy 5:120

All written conflict-of-interest disclosures filed by board members under Policy 2:100

All Limitation of Administrative Costs Worksheets, FY17-FY25

All vendor lists (vendors >$25,000), FY17-FY25

All bond documents: official statements, ISBE Life Safety survey approvals, referendum records, EMMA filings — for any bonds outstanding or issued FY17-present

All ISBE Financial Profile scores + designations, FY17-FY25

All ESSER I/II/III plans, expenditure reports, time-and-effort certs

The District has 5 business days to respond. Failure = $2,500/violation + attorney's fees + PAC complaint.

Cahokia Community Unit School District 187 — Board of Education

Captured: 2026-05-16

Source: https://www.cusd187.org/page/school-board

Source (API): https://thrillshare-cmsv2.services.thrillshare.com/api/v4/o/16912/cms/pages/school-board

Per district hard rule: city/township ONLY. No residential addresses.

All members reside within District 187 territory (Saint Clair County, IL — Cahokia Heights area).

Positions elected April 4, 2023 (consolidated election). 7-member board per 105 ILCS 5/10-10.

Board counsel: Becker, Hoerner, Thompson, & Ysursa P.C. (Belleville, IL).

Audit / Compliance Notes (105 ILCS 5/10-9, 50 ILCS 105/3, 5 ILCS 420)

Surname Cluster — Richard Duncan Sr. (Vice President) and Debra Duncan (Secretary) share the surname "Duncan" and serve concurrently on the same 7-member board. If related, this does NOT per se violate the IL School Code, BUT triggers heightened scrutiny under:

105 ILCS 5/10-23.8 — nepotism: board must NOT vote on hiring or contracts involving relatives of either member

5 ILCS 420/4A-101 — Statement of Economic Interests required (St. Clair County Clerk)

50 ILCS 105/3 — incompatibility of offices analysis

VERIFY: cross-reference Duncan surname against employee/vendor roster; pull SEI filings.

President Marius "Mark" Jackson — surname "Jackson" also appears in district admin (Faith Jackson, Drake Jackson). If related, votes on related-party employment/contract matters trigger 105 ILCS 5/10-23.8. VERIFY relationship and disclosure in board minutes.

All 7 members — SEI filings (5 ILCS 420/4A-101) must be filed annually with St. Clair County Clerk. Failure = fine + potential removal.

OMA training — verify each member completed within 90 days of taking office (5 ILCS 120/1.05).

Pre-oath review — verify each member received conflict-of-interest disclosure materials before taking oath (105 ILCS 5/10-16.5; district policy 2:80).

District structure

Cahokia CUSD 187 formed effective July 1, 2008 from consolidation of CCSD 187 (elementary) and Cahokia HSD 188.

Term cycle: 4-year staggered terms at consolidated elections (April, odd years).

Next regular election: April 2027.

Cahokia CUSD 187 — Administration & Senior Staff

Captured: 2026-05-16

Sources:

https://www.cusd187.org/page/district-administration (API: thrillshare cms/pages/district-administration)

https://www.cusd187.org/page/school-directory (API: thrillshare cms/pages/school-directory)

https://www.cusd187.org/page/human-resources

All phone numbers are public district main-line extensions (618-332-3700 unless noted). No personal addresses.

Cabinet (District Office)

Building Leadership (per /page/school-directory)

Audit / Compliance flags from staff/admin roster

Surname overlap — Jackson: Faith Jackson (Dir. Student Activities), Drake Jackson (Dir. Family Support Services) share surname with Board President Marius "Mark" Jackson. If any are related, 105 ILCS 5/10-23.8 prohibits the board from voting on their hiring, evaluation, or continued employment without recusal and documented disclosure. VERIFY relationship and recusal record.

Surname overlap — Mitchell: Tanya Mitchell (Deputy Superintendent of Instruction) and Anson Mitchell (Head Principal, Cahokia HS) share surname. If related, supervisory chain creates an additional conflict-of-interest scrutiny under 105 ILCS 5/10-23.8 and district policy 5:10 (Equal Employment Opportunity & Minority Recruitment) / 5:20 (Workplace Harassment Prohibited).

Surname overlap — Duncan: see board_members.md.

CFO + CBO separation: Ciara Corley (CFO) and Tiffany Pearce (CBO / Recruitment) — verify duty separation under district policy 4:55 (Use of Credit & Procurement Cards) and 4:80 (Accounting & Audits), and ISBE School Business Official certification per 105 ILCS 5/10-21.4a.

Interim positions: Paul Culley (Interim Director of Maintenance) — interim status >12 months triggers questions about whether the position was properly posted under district HR procedures.

Verification needed (per Chapter XII master matrix)

ISBE Educator License System lookup for every administrator listed — verify current valid certification (Type 75 / Principal endorsement / Superintendent endorsement as applicable).

ISBE School Business Official certification for CFO (Ciara Corley) and CBO (Tiffany Pearce) per 105 ILCS 5/10-21.4a.

Pull most recent Statement of Affairs (SOA) salary disclosures (105 ILCS 5/10-17) — verify all administrators >$75k listed.

Verify all administrators completed mandatory training (mandated reporter / OMA / ethics / Title IX) — request from district HR per FOIA.