In order to “teach or to administer, direct, or supervise, the teaching, instruction or educational guidance of pupils in public schools” a professional staff member must hold a certificate issued by the Board of Examiners. N.J.A.C. § 6A:9-4.2 (a). The Board of Examiners issues certificates in three different categories: Instructional, Educational Services, and Administrative. N.J.A.C. § 6A:9-5.2. An individual may hold more than one certificate. Nelson v. Bd. of Educ., 148 N.J. 358 (1997). In addition to the foregoing, the Board of Examiners issues six types of certificates: a Standard Certificate, a Provisional Certificate, an Emergency Certificate, a Certificate of Eligibility, a County Substitute Credential, and a Limited Certificate for Foreign Teachers. According to N.J.A.C. § 6A:9-6.4(b), “A certificate of eligibility with advanced standing (CEAS) is a certificate with lifetime validity that the Board of Examiners may issue to candidates who meet degree, academic and test requirements and complete a State-approved college professional education preparation program.” Id. In addition, N.J.A.C. § 6A:9-6.4(c) provides, “The . . . CEAS authorizes the holder to seek employment. A holder of a CE or CEAS shall not assume responsibility for a job assignment until the holder has been issued a provisional certificate.” Id. To be eligible for tenure, one must hold either a standard, provisional or emergency certificate. N.J.SA. § 18A:1-1, See N.J.SA. § 18A:28-5; William Davis v. Board of Education of the City of Englewood, OAL Dkt. No.: 442-06, adopted by Commissioner, December 8, 2006. According to Pamela Miller v. Board of Education of the Township of West Amwell, Hunterdon County, OAL Dkt. No. Edu. 4523-05S, 2006 N.J. AGEN Lexis 749, 14-15 (2006):
It is virtually axiomatic that the period of time a teacher serves in a position without benefit of a valid and appropriate teaching certificate . . . required by the position cannot be counted toward the accrual of tenure or seniority.
[Id. (citing Bjerre v. Hampton Bd. of Educ., 92 N.J.A.R.2d (EDU) 884 (certified elementary school library skills teacher’s contract held void because she did not hold media specialist endorsement required by State Board); Passaic Bd. of Educ. v. Gonzales, 97 N.J.A.R.2d (EDU) 488 (bilingual teacher who failed to maintain bilingual emergency certification properly terminated notwithstanding her elementary school and Spanish teacher endorsements); Cooker v. Brigantine Bd. of Educ., 91 S.L.D. 1202, aff’d. 91 S.L.D. 1224 (teacher lacking valid and appropriate certificate denied tenure rights after ten years in position).]
Similarly, N.J.S.A. § 18A:28-4 provides, “[n]o teaching staff member shall acquire tenure in any position in the public school . . . who is not the holder of an appropriate certificate for such position, issued by the State Board of Examiners, in full force and effect.”