84 F.3d 1035 (8th Cir. 1996), 95-3192, Buchanan v. Little Rock School Dist. of Pulaski County, Ark.
|Citation:||84 F.3d 1035|
|Party Name:||Karen BUCHANAN, Plaintiff-Appellee, v. LITTLE ROCK SCHOOL DISTRICT OF PULASKI COUNTY, ARKANSAS; Linda Poindexter, Patricia Gee, Judy Magness, Oma Jacovelli, T. Kevin O'Malley, John E. Riggs, IV, Individually and in their official capacities as the Board of Directors for the Little Rock School District; Henry Williams, Individually and in his offici|
|Case Date:||May 28, 1996|
|Court:||United States Courts of Appeals, Court of Appeals for the Eighth Circuit|
Submitted April 12, 1996.
Rehearing and Suggestion for Rehearing En Banc Denied July 15, 1996.
Michael S. Moore, Little Rock, Arkansas, argued for appellants (Christopher J. Heller, on the brief).
Troy Anthony Price, Little Rock, Arkansas, argued for appellee.
Before BEAM and MURPHY, Circuit Judges, and NANGLE, [*] District Judge.
MURPHY, Circuit Judge.
Karen Buchanan claims her due process rights were violated because she did not receive a hearing in connection with her reassignment from principal of a junior high school to an administrative post. The district court concluded as a matter of law that she had a property interest in her position as principal, and judgment was entered in her favor after a jury trial. The Little Rock School District of Pulaski County, Arkansas (the district), the members of its school board, and its superintendent appeal from the judgment. We reverse.
The facts are essentially undisputed. Buchanan was hired by the district as a teacher in 1985, promoted to assistant principal the following year, and then to principal in 1987. She received an individual contract for each school year. She served as the principal of a number of elementary schools within the district through the 1993-94 academic year and received favorable evaluations.
In April 1994, she signed a contract indicating she would be the principal at Garland Elementary School the following year. The superintendent, Dr. Henry Williams, recommended that she instead take over as principal at Henderson Junior High School, a magnet school troubled by poor student performance and discipline problems. The school board approved the recommendation, and a letter from a district administrator confirmed the transfer early in the summer.
After Buchanan started at Henderson friction developed quickly between her and some of the teachers. At the beginning of the 1994-95 school year, Buchanan reviewed with them the policy manual she had revised over the summer. Apparently a number of teachers were upset that they would no longer be able to use their preparation periods to run errands. Several teachers were angry because they had been moved to different classrooms without being consulted. There were several other unpopular policy changes, such as requiring teachers to record their grades as percentages. The school board received a number of complaints, which in turn were reported to Buchanan by Williams. The changes instituted by Buchanan were consistent with district rules, and Williams indicated that he supported her efforts to enforce district policies.
The situation did not improve over the next month, however, and Buchanan had a difficult time with unruly students and disgruntled faculty. Following an incident in which a girl was beaten by other students on a bus, Buchanan told Williams, "Get me out of here." She later changed her mind and said she wanted to stay at Henderson, and Williams provided increased security staff. The tension between Buchanan and the faculty continued. Williams told her that they perceived her as being arbitrary, authoritarian, and insensitive to their concerns. Some teachers were discussing a walkout.
After Williams met with some of the teachers, he told Buchanan to "make peace" with the faculty. Buchanan circulated a survey to pinpoint problems with the faculty, but only six of some seventy teachers responded. She received a list of complaints from teachers on September 16. Three days later she met with the faculty and received a second list of concerns, which was similar to the first. The meeting apparently failed to reduce the tension.
Matters came to a head on September 20, when at least seven teachers apparently participated in a "sickout" and failed to come to work. Williams visited Henderson that day and asked Buchanan to meet with him that evening. Fearing she would be removed from her position, Buchanan retained counsel, who attended the meeting with her.
At their meeting Williams told Buchanan that he had decided to recommend that she be reassigned to another position within the district and explained that his decision was "political." The school board unanimously approved the recommendation at a regular board meeting on September 22. The board minutes indicate she was "temporarily reassigned." Six other principals and assistant principals were also...
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