How A Secretive Two-County Legal Consortium Seized Control of Personnel Decisions Affecting 64 School Districts Without Public Knowledge or Board Approval
By Carlos Avalos
For more than a decade, school districts across San Bernardino and Riverside counties have been unknowingly funneling their most sensitive personnel decisions, employee misconduct investigations, labor negotiations, discipline proceedings, and legal settlements through a secretive consortium controlled not by their elected boards, but by two county superintendents and a private law firm.
The organization is called the Inland Personnel Council, or IPC. On paper, it is described as a resource-sharing cooperative for local educational agencies. In practice, documents obtained by the Sentinel and the public reveal it has evolved into something far more powerful: a shadow governance structure that has quietly absorbed authority that California law reserves for independently elected school boards, operating entirely outside the transparency requirements of the state’s open meetings laws.
Now, a cascade of legal challenges, public records disclosures, and a landmark court settlement involving one of IPC’s most prominent member districts, Redlands Unified School District, is bringing this hidden architecture into the open. And the picture that emerges raises serious questions about violations of California and federal law at every level of government.
WHAT IS IPC AND WHY DOES IT MATTER?
The Inland Personnel Council was established decades ago as a cooperative framework allowing school districts to share legal expertise and resources related to employer-employee relations. On its face, this is not unusual. Joint powers agreements are a routine tool in California government, used by cities, counties, and school districts to pool resources and achieve economies of scale.
But IPC is not a typical joint powers agreement. According to documents obtained through the California Public Records Act, IPC operates through a web of interlocking agreements that obscures its true governance structure from both the public and, in many cases, the school board members who approved it. According to its own website and agreement language, IPC serves approximately 64 school districts, community colleges, and county offices of education across San Bernardino and Riverside counties.
For reference, a Joint Powers Agreement (which is just a contract sharing services) vs. a Joint Powers Authority, which is a new public entity. IPC is listed on the website as a “Joint Powers Agreement”, but it has the hallmarks of a Joint Powers Authority, with bylaws, a governing board, and says it “employs” the IPC Director. The bylaws are referenced in the contracts and are critical in defining IPC and how it is governed, but school districts deny having them, and so they have not been obtained via public records requests.
Legal services are delivered through the private law firm Atkinson, Andelson, Loya, Ruud & Romo, universally known by its abbreviation, AALRR. Heading the consortium as its Executive Officers are San Bernardino County Superintendent of Schools Ted Alejandre and Riverside County Superintendent of Schools Edwin Gomez. Together, they control a structure that influences personnel decisions for hundreds of thousands of students, thousands of employees, and billions of dollars in public school spending, with almost no public accountability.
THE 2020 PIVOT: FROM ADVICE TO CONTROL
The most important development in IPC’s history may also be its least publicized. In 2020, the consortium’s governing agreement underwent a transformation that legal and governance experts say fundamentally altered the relationship between IPC, the county superintendents, and individual school districts.
A side-by-side review of the 2017-2020 IPC county-level agreement and its 2020-2023 successor reveals changes that go far beyond administrative updates. The agreement doubled in length from approximately 4 pages to 9 pages and introduced sweeping new language that redefined the scope and authority of the consortium.
In the 2017-2020 agreement, the county superintendents’ authority was explicitly limited to directing ‘advice.’ Services were framed as expert legal consultation, the model of a professional advisory body. In the 2020 revision, the word “advice” was replaced with services.
This single-word change has enormous legal implications. Under the new language, the county superintendents are authorized to direct services as broadly defined by the agreement. a definition that was simultaneously expanded to expressly include employee investigations, post-investigation services, arbitration, and operational legal functions.
In 2017-2020, County Officers provided advice. In 2020-2023, they may direct services, including investigations, that can result in employee discipline, termination, and multi-million-dollar settlements. In plain terms, before 2020, IPC told districts what the law was. After 2020, IPC controlled by the county superintendents could direct what districts actually did about it. “IPC” trains district employees on the law via conferences and presentations that are billed as “Presented by IPC in partnership with AALRR”. This is another example of how it looks like IPC is a separate entity when they claim it is not.
New Services Added in 2020: The 2020 agreement also formally incorporated several service categories that had not previously appeared in the IPC framework, such as employee investigations and post-investigation services, binding arbitration provisions between districts and AALRR, a detailed client/attorney engagement framework mirroring a full law firm retainer agreement, a shift in financial structure from consortium membership dues to direct vendor billing by AALRR using the firm’s own tax identification number
This last point deserves particular attention. Under the earlier model, IPC functioned as a cooperative with pooled membership funds administered by the county superintendents. After 2020, AALRR began billing districts directly under IPC-branded invoices using the law firm’s own EIN. The consortium was no longer simply pooling public resources; it was channeling public funds directly to a private law firm, with the county superintendents directing the flow.
There is no publicly available evidence that the 64-member districts were clearly informed of these changes, or that their governing boards formally reauthorized their participation in IPC after the 2020 expansion.
Each district’s contract to join the IPC Joint Powers Agreement has an auto-renewal clause, and withdrawal requires a board-approved written withdrawal letter to the Executive Officers. But since it auto-renews, it appears that some current district boards may not even be aware that the agreement was signed by a previous board a decade ago or even longer ago. In addition to that, the county-level services agreement signed by DeNava and Gomez requires a majority of the 64 agencies, at least 33, to completely dismantle IPC. This is impossible because there is no mechanism for these independent agencies across two counties to even take a vote.
The governance question is stark: Can a school district’s governing board delegate investigative authority over its own employees to an outside county official through an agreement that auto-renews and is never re-approved without violating California law?