But the justices stressed that local officials must make a “nuanced” analysis before seeking to remove a board member on conflict grounds for special-education claims involving themselves or their own families, one that takes into account the nature of the dispute and the relief sought.

“We hold that not all controversies and disputes that occasionally may erupt between the parents of special education pupils and local school districts concerning a child’s educational program should require a sitting board of education member’s removal from office,” the Court held in Board of Education of the City of Sea Isle City v. Kennedy, A-37-07.

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