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 the Inland Personnel Council 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. The Inland Personnel Council 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 the Inland Personnel Council’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 Inland Personnel Council 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, the Inland Personnel Council 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 the Inland Personnel Council is a separate entity when it is claimed 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, the Inland Personnel Council 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 the Inland Personnel Council 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 the Inland Personnel Council. 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?
THE REDLANDS CONNECTION: A CASE STUDY IN IPC’S REACH
If there is a single case that illuminates the potential consequences of the Inland Personnel Council’s expanded investigative authority, it is the saga of Redlands Unified School District, a cautionary tale that ended with California’s Attorney General imposing court supervision on a district that had failed, over many years, to protect its students from sexual harassment, assault, and abuse.
In June 2024, Attorney General Rob Bonta filed suit against Redlands Unified School District and obtained a stipulated judgment requiring the district to submit to at least five years of oversight by the Office of the Attorney General. The court order, signed by Superior Court Judge Colin Leis on June 7, 2024, permanently enjoined the district from violating a sweeping array of state and federal civil rights and child protection laws, including California Education Code sections 200 et seq. (antidiscrimination), California Penal Code section 11164 et seq. (Child Abuse and Neglect Reporting Act CANRA), California Government Code section 12950.1 (sexual harassment prevention training), Title IX of the Education Amendments of 1972, and Title 5 of the California Code of Regulations section 4600 et seq.
The judgment was not merely a consent decree. It imposed affirmative obligations requiring Redlands to create an entirely new compliance infrastructure: hiring an Assistant Superintendent of Compliance, establishing a centralized tracking system for sexual misconduct complaints, revising multiple board policies, conducting mandatory staff and student trainings, administering anonymous climate surveys, and providing compensatory mental health and academic services to identified student victims.
The attorney of record for Redlands Unified in the Attorney General’s proceeding was Mark W. Thompson of AALRR, the same law firm that runs the Inland Personnel Council. The same Mark Thompson signed the county-level IPC agreements in both 2020 and 2023 on behalf of AALRR, formalizing the expansion of IPC’s investigative authority over the very districts AALRR represents.
Thompson is also listed as a “featured speaker” for the Inland Personnel Council on his AALRR bio and on the IPC calendar of presentations.
Thompson’s firm also serves as legal counsel for Etiwanda School District, where board agendas from April 2021 show IPC listed as a single line item in a consent calendar — identified as Attorney Services with members of the firm Atkinson, Andelson, Loya, Ruud & Romo for the term 2020-2023 approved without separate discussion, public disclosure of the Inland Personnel Council agreement, or explanation of its implications.
The law firm that negotiated Redlands’ expanded oversight agreement with the Attorney General is the same firm that simultaneously expanded IPC’s control over investigations across 64 districts while representing many of those districts in sensitive personnel matters.
The Redlands judgment is a public record of systemic failure: years of mishandled complaints, inadequate investigations, failures to report child abuse as required by state law, and a culture in which student safety was subordinated to institutional reputation.
Several advocates have noted a troubling structural question: if the Inland Personnel Council was directing legal services, including personnel investigations at Redlands during the period that predated the Attorney General’s intervention, what role did that direction play in the failures documented in the Attorney General’s complaint? One advocate noted that if IPC/AALRR was training districts on issues such as Title IX, why did Redlands administrators ignore the law and have inadequate policies that they were trained on?
The answer is not yet known. the Inland Personnel Council agreement grants the county superintendents authority to direct services, including investigations. But the transparency mechanisms that would allow the public to trace IPC’s involvement, agendas, minutes, and documented decisions do not exist in any accessible form. That opacity may be, by itself, part of the problem.
BROWN ACT VIOLATIONS: PUBLIC MEETINGS WITHOUT THE PUBLIC
California’s Ralph M. Brown Act is among the most important transparency laws in the state. It requires that local government bodies conduct their business in public, with advance notice, accessible agendas, and the right of the public to attend and comment. Its protections are not discretionary; they are foundational to democratic governance.
the Inland Personnel Council appears to violate the Brown Act in multiple respects. There are no agendas, no minutes, and no public comment.
Despite operating as a body that exercises governmental authority through pooled public resources, and despite the California Attorney General’s 2022 opinion in Opinion No. 22-402, which held that the SANDABS consortium (a strikingly similar structure) constituted a legislative body subject to the Brown Act, IPC has never posted publicly accessible agendas for its Advisory Committee meetings, has never made meeting minutes available to the public, and has never provided a public forum for attendance or comment. A slight difference between SANDABS and IPC is that SANDABS posted meetings and agendas; they just didn’t allow public comment. IPC doesn’t even show when/where meetings are held.
IPC’s Advisory Committee is composed of representatives of the county superintendents and district administrators, public employees exercising government authority over sensitive personnel matters affecting tens of thousands of workers and students. Under the Attorney General’s SANDABS analysis, this committee should be subject to the Brown Act. It is not.
The Brown Act requires that agenda items provide a description sufficient to inform the public of the nature of the business to be transacted. Almost all school districts also contract with AALRR directly for legal services. In those agreements, there is a statement that if the district remains “in good standing” with IPC, it will receive a discount on personnel-related legal services. However, the membership in IPC is never explained.
The agreement that Etiwanda approved was the county-level agreement. The county-level agreement was signed by Ted Alejandre in 2017, by Katie Hylton, Procurement and Warehouse Manager, in 2020, and by Richard DeNava in 2023. The Riverside County Superintendents signed all of the county-level agreements.
Formal Brown Act cure-and-correct demands have been submitted to the San Bernardino County Board of Education and to multiple districts, including Yucaipa-Calimesa Joint Unified School District, alleging that the manner of disclosure and approval denied the public its right to comment on IPC participation and the delegation of investigative authority. Neither the county board nor the districts has responded within the timeframes required by law.
A separate Brown Act violation identified by the American Civil Liberties Union of Southern California concerns the San Bernardino County Board of Education’s requirement that public commenters announce their names before speaking. The ACLU’s February 2026 demand letter, authored by attorney Jonathan Markovitz, cites the Brown Act’s explicit prohibition on requiring identification as a condition of attendance or participation in public meetings, as well as First and Fourteenth Amendment protections for anonymous political speech established by the U.S. Supreme Court in McIntyre v. Ohio Elections Commission (1995).
The ACLU notes that the League of California Cities explicitly advises that public speakers cannot be compelled to give their name or address as a condition of speaking. In the current climate, where parents, employees, and community members raising concerns about school governance can face retaliation, the identification requirement functions as a de facto silencing mechanism.
EDUCATION CODE VIOLATIONS: WHO GOVERNS YOUR SCHOOL DISTRICT?
California law is unambiguous about who governs local school districts. It is not the county superintendent. It is the locally elected governing board. The Education Code vests school district governing boards with exclusive authority over critical functions. Among the most relevant statutes: Education Code § 35160: Grants governing boards authority to act in any manner not inconsistent with law, Education Code § 35161: Vests boards with authority to employ and fix compensation of district personnel, Education Code § 44932 et seq.: Assigns governing boards sole responsibility for discipline and dismissal of certificated employees, and Education Code § 45113: Authorizes governing boards to adopt rules governing discipline of classified employees.
The Inland Personnel Council’s 2020 agreement, by granting county superintendents the authority to direct investigative and operational legal services, creates a structural arrangement in which county officials who lead separate governmental entities can direct investigations that may lead to the discipline or termination of employees at independent school districts.
County superintendents have specific and limited statutory roles, primarily fiscal oversight under Education Code § 42127 et seq. and certain intervention powers in cases of declared financial emergency. The Education Code does not grant county superintendents general authority over the personnel investigations of independently governed districts.
A school district’s governing board cannot contract away its statutory obligation to independently govern its own employees, even with good intentions, and even through the mechanism of an auto-renewing agreement that the board never explicitly reapproved.
Several education law experts reviewing the IPC structure have raised a further concern: the cross-county dimension. The Inland Personnel Council agreement authorizes Alejandre to direct services in Riverside County districts and Gomez to direct services in San Bernardino County districts. Not only do these county superintendents lack statutory authority over independent districts in their own counties, but they have no jurisdictional basis whatsoever for directing personnel services in the other county.
FINANCIAL OPACITY: WHERE IS THE MONEY?
IPC operates with public funds. Districts pay membership fees and legal service costs that flow through or because of the Inland Personnel Council framework. Yet the financial picture is almost entirely opaque.
A review of the Riverside County Office of Education’s most recent audited financial statements, more than 100 pages covering fiscal year 2024-25, shows no reference to the Inland Personnel Council by name, no disclosure of IPC as a joint powers agreement, and no line items for the Inland Personnel Council membership dues or pooled funding. Similar gaps exist in San Bernardino County audit materials. IPC appeared in the June 2025 audit for the Alta Loma school district under Joint Powers Agreements, so it is odd that it doesn’t show up in the county office of ed audits.
Notably, at the January 2026 meeting of the San Bernardino County Board of Education, board member Rita Fernandez Loof asked the auditor whether the Inland Personnel Council was addressed in the annual audit report. The auditor responded: not specifically.
In May 2025, AALRR made a $10,000 campaign contribution to Ted Alejandre, the San Bernardino County Superintendent of Schools, who, as IPC’s Executive Officer, directs the services that generate substantial revenue for AALRR. Alejandre subsequently announced in August 2025 that he was no longer running for re-election.
Shortly after the contribution, AALRR provided legal defense services to Alejandre personally and to Richard DeNava, the Chief Business Officer of SBCSS, who also serves as Alejandre’s campaign treasurer and signed the IPC legal services agreement on behalf of SBCSS. The legal matters involved FPPC (Fair Political Practices Commission) proceedings, personal ethics, and conflict-of-interest matters. AALRR contributed $10,000 to Alejandre’s campaign, then provided his personal legal defense in ethics proceedings, all while serving as the law firm that IPC member districts pay to handle their most sensitive personnel matters, with Alejandre directing those services.
The inclusion of personal FPPC defense within what is ostensibly a school personnel services consortium raises profound structural concerns. Elected officials are not employees. Their FPPC duties and personal liabilities are separate from district operations. There is no apparent authority for pooled school district funds to subsidize personal legal defense of county officials facing ethics proceedings, nor any evidence that the 64 member districts were informed this was happening.
The FPPC has initiated investigations into the San Bernardino County Superintendent of Schools (SBCSS) for its conflict of interest code, and Richard DeNava, for “non-filing” of Statements of Economic Interest.
Under the Inland Personnel Council’s current framework, member districts are charged $340 per hour for AALRR partners and $320 for associates on IPC-related services, rates marketed as discounted compared to AALRR’s standard non-IPC rates. However, no publicly accessible accounting exists showing: the total amount billed to member districts under the Inland Personnel Council framework annually, how pooled IPC funds, if any, are held and distributed, what portion of billings relate to investigations, litigation, training, or other services, and whether Riverside County districts are subsidizing services or legal defenses arising from San Bernardino-specific matters.
CONFIDENTIALITY AND PRIVACY
Personnel matters in public school districts are among the most sensitive records in government. California law subjects employee discipline, investigations, medical information, and attorney-client communications to strict confidentiality protections. Governing boards may discuss such matters only in closed session, with access strictly limited to the board, designated district staff, and district counsel.
IPC’s structure potentially expands this circle to an extraordinary degree, without the knowledge of affected employees, their unions, or the public. The Inland Personnel CouncilAdvisory Committee includes administrators from multiple districts. IPC’s director is not a district employee. The Inland Personnel Council’s own website materials describe a shared platform where member districts can enter and view other districts’ information for comparability purposes, including bargaining status and labor-relations activity.
According to Brown Act demand letters, publicly available agenda materials from districts approving AALRR contracts do not disclose that district labor-relations or personnel-related information may be entered into or accessed through a shared, cross-district platform available to other districts and county offices of education. There is no public record that any governing board evaluated what information may be entered, who may access it, or whether such participation is consistent with obligations to protect employee privacy, attorney-client privilege, and the integrity of closed-session deliberations.
State Law
California Government Code § 54950 et seq. (Ralph M. Brown Act): Requires public meetings, posted agendas, and public comment opportunities for all local government legislative bodies. IPC’s Advisory Committee meetings, if the Inland Personnel Council constitutes a legislative body under the SANDABS analysis, must be held publicly.
California Government Code § 6500 et seq. (Joint Exercise of Powers Act): Permits public agencies to jointly exercise common powers but does not permit agencies to abdicate core statutory responsibilities. The Act requires joint execution by participating agencies and formal governance structures, requirements the Inland Personnel Council may not satisfy.
California Government Code § 6250 et seq. (California Public Records Act): Requires public agencies to disclose public records upon request. IPC Director Jeff Malan’s January 2026 refusal to respond to a CPRA request — asserting that ‘the Inland Personnel Council is not itself a public entity’ may itself constitute a violation of the Act if the Inland Personnel Council is found to be a public entity or acts as one.
California Education Code §§ 35160, 35161, 44932, 45113: Vest sole authority over personnel decisions in locally elected governing boards. Contractual arrangements that effectively delegate this authority to county-level officials may be void as contrary to statute.
California Government Code § 1090 et seq. (Conflict of Interest): AALRR’s financial relationship with Alejandre, including a $10,000 campaign contribution, while simultaneously serving as the law firm whose services are directed by Alejandre through IPC and billed to dozens of public agencies might constitute a violation of this statute.
California Government Code § 87100 et seq. (Political Reform Act / FPPC Regulations): Governs conflicts of interest for public officials. The use of Inland Personnel Council-related public funds to defend officials in FPPC proceedings would raise significant questions under these provisions.
Federal Law
Title IX of the Education Amendments of 1972 (20 U.S.C. § 1681 et seq.): Prohibits sex discrimination in educational programs receiving federal funds. If IPC’s direction of personnel investigations contributed to inadequate responses to sexual harassment and assault, as may have occurred at Redlands, Title IX liability could extend beyond individual districts.
42 U.S.C. § 1983 (Civil Rights Act): Provides a federal cause of action for deprivation of constitutional rights under color of state law. Employees subjected to investigations directed by county officials without proper authority, or without procedural safeguards, may have civil rights claims.
20 U.S.C. § 1400 et seq. (Individuals with Disabilities Education Act): Governs the rights of students with disabilities. The Redlands judgment specifically addressed obligations to students with disabilities in sexual harassment proceedings, obligations that may have been compromised by IPC’s investigative framework.
Family Educational Rights and Privacy Act (FERPA), 20 U.S.C. § 1232g: Restricts disclosure of student educational records. The sharing of student-related information through IPC’s cross-district platform may implicate FERPA protections if student data is accessible to administrators from other districts.
THE SILENCE OF OFFICIALS
The Sentinel submitted public records requests to Jeff Malan, identified on the Inland Personnel Council website as the IPC Director, seeking foundational governance documents, financial records, and staffing information. In a January 26, 2026, response, Malan asserted that “the Inland Personnel Council is not itself a public entity’ and therefore a response is not required under the PRA.
When pressed by the requester, who noted that IPC’s own website describes participating members as ‘governed by a Joint Powers Agreement’ and that the Inland Personnel Council employs a part-time director paid with public funds, Malan did not respond.
The San Bernardino County Board of Education has not publicly addressed either the Brown Act demand regarding IPC or the ACLU’s anonymous speech complaint. County Counsel representatives Richard Luczak, Laura Feingold, and Scott Runyan were copied on both complaints but have issued no public statements. An item relating to the Inland Personnel Council was not placed on the board’s agenda following the January 2026 public comment period, in which multiple speakers raised concerns.
The Inland Personnel Council sits at the intersection of several unresolved legal disputes that could collectively reshape how school district legal services are structured across Southern California. The ACLU’s Brown Act demand regarding anonymous speech carries a 30-day deadline for the San Bernardino County Board of Education to respond with an unconditional commitment to cease violations or face litigation with exposure to attorney fees and court costs under Government Code § 54960.2.
The IPC-specific Brown Act demand requires the board to agendize matters relating to the Inland Personnel Council as a standalone item, publicly disclose the IPC agreement and all governance documents, and allow full public deliberation.
The Yucaipa-Calimesa Brown Act demand and similar demands filed against other districts require formal responses and corrective action. The absence of timely responses strengthens the legal record for potential litigation.
The Redlands Attorney General judgment remains in effect for a minimum of five years, with the Attorney General monitoring compliance on a monthly basis and filing annual compliance reports with the court. Any connection between the Inland Personnel Council’s governance structure and the failures documented in the Attorney General’s complaint could trigger further scrutiny.
The State Controller’s Office, which maintains the registry of Joint Powers Authorities, has received no registration from the Inland Personnel Council as a joint powers authority, raising questions about whether IPC’s operation as a de facto JPA without registration violates state reporting requirements.
What the documents assembled in this investigation reveal is not a single bad actor, but appears to be a structural failure that has been decades in the making: the gradual erosion of local school board authority through the mechanism of an advisory consortium that slowly became something far more powerful.
The 2020 expansion of the Inland Personnel Council from advice to services, from consultation to direction, from a few pages to a 17-page legal framework, was not disclosed to the public, not clearly communicated to the 64 member districts, and not reauthorized by the governing boards that bear legal and financial responsibility for the consequences of its decisions.
The Redlands judgment is the most visible evidence of what can go wrong when investigative processes are captured by structures that operate outside public accountability. But Redlands is not an outlier. It is a data point in a pattern,a pattern that IPC’s governance structure may have helped create, or at a minimum failed to prevent.
California law is clear about who governs public schools: the people, through their elected representatives on local governing boards. The Inland Personnel Council, as currently constituted, may represent the most comprehensive circumvention of that principle in the region’s educational history. The public deserves answers. And under California law, they are entitled to them.
KEY FIGURES
Ted Alejandre: San Bernardino County Superintendent of Schools; IPC executive officer; recipient of a $10,000 AALRR campaign contribution in May 2025; subject of FPPC proceedings for which AALRR provided legal defense.
Edwin Gomez: Riverside County Superintendent of Schools; IPC executive officer; co-signatory to IPC agreements granting county-level direction of investigative legal services.
Mark W. Thompson: AALRR partner; signed IPC county-level agreements in 2020 and 2023; attorney of record for Redlands Unified School District in the Attorney General’s sexual misconduct oversight proceedings.
Richard DeNava: Chief Business Officer, SBCSS; signed the 2020-2023 IPC agreement on behalf of the Inland Personnel Council; also served as Alejandre’s campaign treasurer.
Jeff Malan: IPC Director; declined to respond to Public Records Act requests, asserting IPC is ‘not a public entity.’
Rob Bonta: California Attorney General; plaintiff in the Redlands stipulated judgment imposing five-year oversight of the district; copied on multiple Brown Act demands related to IPC.
