... Each school district is "encouraged" to establish bullying prevention programs. N.J.S.A. 18A:37-17. The Commissioner of Education is granted authority to implement these ... intimidation and harassment based on sexual orientation, "as recommended by N.J.S.A. 18A:37-17." The Director ordered that this program be required for middle ... compliance with N.J.S.A. 18A:37-15 and N.J.S.A. 18A:37-17 are therefore reversed. D. Compensatory Damages The Director awarded L ...