440 U.S. 194 (1979), 78-443, Harrah Independent School District v. Martin
|Docket Nº:||No. 78-443|
|Citation:||440 U.S. 194, 99 S.Ct. 1062, 59 L.Ed.2d 248|
|Party Name:||Harrah Independent School District v. Martin|
|Case Date:||February 26, 1979|
|Court:||United States Supreme Court|
ON PETITION FOR WRIT OF CERTIORARI TO THE UNITED STATES
COURT OF APPEALS FOR THE TENTH CIRCUIT
Respondent, a tenured teacher, was denied salary increases during the 1972-1974 school years because of her refusal to comply with the School Board's continuing education requirement, which was incorporated by reference into her employment contract. After the Oklahoma Legislature enacted a law mandating certain salary raises for teachers regardless of their compliance with the continuing education policy, the School Board notified respondent that her contract would not be renewed for the 1974-1975 school year unless she enrolled in the required continuing education courses. When respondent refused to comply, the School Board found that her persistent noncompliance with the continuing education requirement constituted "willful neglect of duty" under an Oklahoma statute and refused to renew her contract for the following school year. The District Court dismissed respondent's complaint, which claimed that the School Board's action denied respondent her liberty and property without due process of law and equal protection of the laws, as guaranteed by the Fourteenth Amendment. The Court of Appeals reversed.
1. The School Board's actions did not violate respondent's due process rights. Respondent has no colorable claim of a denial of procedural due process: she was advised of the School Board's decision not to renew her contract and of her right to a hearing before the Board, and, at her request, a hearing was held at which both she and her attorney appeared and unsuccessfully contested the Board's determination that her refusal to enroll in continuing education courses constituted "willful neglect of duty." Nor did the School Board's action deny respondent substantive due process. After the state legislature, by making pay raises mandatory, deprived the Board of the sanction that it had earlier used to enforce its teachers' contractual obligation to earn continuing education credits, the Board turned to contract nonrenewal, but applied this sanction purely prospectively, so that those who might have relied on its past practice would nonetheless have an opportunity to bring themselves into compliance with the terms of their contracts. Such a course of conduct on the part of a school board responsible for the public
education of students within its jurisdiction, and employing teachers to perform the principal portion of that task, can scarcely be described as arbitrary
2. Respondent was not deprived of equal protection of the laws. The School Board's concern with the educational qualifications of its teachers cannot, under any reasoned analysis, be described as impermissible, and it is not contended that the Board's continuing education requirement bears no rational relationship to that legitimate governmental concern. The sanction of contract nonrenewal, imposed uniformly on the "class" of teachers who refuse to comply with the continuing education requirement, is quite rationally related to the Board's objective of enforcing the continuing education obligation of its teachers. That the Board was forced by the state legislature to penalize noncompliance differently than it had in the past in no way alters the equal protection analysis of respondent's claim.
Certiorari granted; 579 F.2d 1192, reversed.
Per curiam opinion.
Respondent Martin was employed as a teacher by petitioner School District under a contract that incorporated by reference the School Board's rules and regulations. Because respondent was tenured, Oklahoma law required the School Board to renew her contract annually unless she was guilty of, among other things, "willful neglect of duty." Okla.Stat., Tit. 70, § 6-122 (Supp. 1976) (repealed 1977). The same Oklahoma statute provided for hearing and appeal procedures in the event of nonrenewal. One of the regulations incorporated into [99 S.Ct. 1063] respondent's contract required teachers holding only a bachelor's degree to earn five semester hours of college credit every three years. Under the terms of the regulation, noncompliance with the continuing education requirement was sanctioned by withholding salary increases.
Respondent, hired in 1969, persistently refused to comply with the continuing education requirement, and consequently forfeited the increases in salary to which she would have otherwise been entitled during the 1972-1974 school years. After her contract had been renewed for the 1973-1974 school term, however, the Oklahoma Legislature enacted a
law mandating certain salary raises for teachers regardless of their compliance with the continuing education policy. The School Board, thus deprived of the sanction which it had previously employed to enforce the provision, notified respondent that her contract would not be renewed for the 1974-1975 school year unless she completed five semester hours by April 10, 1974. Respondent nonetheless declined even to enroll in the necessary courses and, appearing before the Board in January, 1974, indicated that she had no intention of complying with the requirement in her contract. Finding her persistent noncompliance with the continuing education requirement "willful neglect of duty," the Board voted at its April, 1974, meeting not to renew her contract for the following school year. After unsuccessfully pursuing administrative and judicial relief in the Oklahoma state courts, respondent brought this action in the United States District Court for the Western District of Oklahoma. She claimed that the Board's action had denied her liberty and property without due process of law and equal protection of the laws,...
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