Schreffler v. Board of Ed. of Delmar Sch. Dist.

• Decision Date: 30 January 1981
• Docket Number: Civ. A. No. 79-217.
• Citation: 506 F. Supp. 1300
• Parties: Daniel K. SCHREFFLER, Plaintiff, v. BOARD OF EDUCATION OF DELMAR SCHOOL DISTRICT et al., Defendants.
• Court: U.S. District Court — District of Delaware

506 F. Supp. 1300

Daniel K. SCHREFFLER, Plaintiff, v. BOARD OF EDUCATION OF DELMAR SCHOOL DISTRICT et al., Defendants.

Civ. A. No. 79-217.

United States District Court, D. Delaware.

January 30, 1981.

COPYRIGHT MATERIAL OMITTED

Sheldon N. Sandler of Bader, Dorsey & Kreshtool, Wilmington, Del., for plaintiff.

Nicholas H. Rodriguez of Schmittinger & Rodriguez, P. A., Dover, Del., for defendants.

OPINION

LATCHUM, Chief Judge.

Plaintiff, Daniel K. Schreffler, brought this action against defendants, the Board of Education of the Delmar School District, the individual members of the Board, and the Superintendent of the school district,¹ seeking compensatory and punitive damages, and reinstatement for defendants' wrongful conduct in failing to renew plaintiff's contract as principal of Delmar High School. The jury awarded the plaintiff $113,000 as compensatory damages and $77,500 as punitive damages and assessed the punitive damages in varying amounts against each of the defendants individually. Presently before the Court are: plaintiff's motion for reinstatement as principal of Delmar High School and for expungement of all references to the plaintiff's wrongful non-renewal in records maintained by the Delmar School District (Docket Item "D.I." 46); and defendants' motion for judgment notwithstanding the verdict, for alteration or amendment of the judgment, or for a new trial.² (D.I. 49.) Pursuant to Local Rule 3.1C(3), the parties advised the Court of their belief that no briefing on these post-trial motions was necessary. This opinion represents the Court's disposition of these motions.

I. Background

The salient facts of this case may be briefly stated as follows: Daniel Schreffler was hired as Principal of Delmar High School by the Delmar Board of Education on June 30, 1977. (Trial Transcript "Tr." at A-52.)³ In an interview one day preceding the formal offer of employment, which was conducted by the Board of Education, as then constituted,⁴ and Mr. Bastian, Superintendent of the school district, Mr. Schreffler was advised that if he were selected as principal he would be given an initial two year contract and if his performance during the two year period was "satisfactory," his contract would be renewed for an additional three years. (Tr. at A-55.) One month later, the Board also hired a new Assistant Principal, Carol Cordrey, who similarly was granted a two year contract and was informed of the same conditions for renewal of her contract. (Tr. at C-74.)

Despite some difficulties encountered during his first year, Schreffler received an overall satisfactory performance rating in a first year evaluation prepared by Superintendent Bastian on September 15, 1978. (DX. 2.) Plaintiff received a negative rating, however, in certain "personal profile" categories, including "emotional stability" and "sensitivity to the feelings of others" and also scored unsatisfactory marks in his relationships with "faculty, students, parents, and community" and with the "board and other administrators." (Id.) The evaluation further stated that the composite satisfactory performance rating had been prompted in part by several unique considerations, i. e., that many policy changes had been implemented in the school year, that both Schreffler and Cordrey were new to the school district and to their respective positions, and that Schreffler was appointed principal late in the summer of 1977. (Id. at 2.) Finally, the evaluation made several recommendations and concluded that "improvement will be necessary in those areas listed under the recommendations in order to retain a satisfactory performance rating. ..." (Id.)

Schreffler responded to this evaluation on September 20, 1978 by requesting in writing more specific information concerning his alleged shortcomings as principal "so that specific behavior unacceptable to the Superintendent can be modified." (DX. 3.) Superintendent Bastian replied on October 20, 1978 by highlighting particular incidents in which Schreffler had failed to use good judgment and by explaining in greater detail areas in need of improvement. (DX. 4.) The response noted, however, that progress had been made in certain respects during the present school year and that Schreffler was then complying with the responsibilities of his job description. (DX. 4 at 4.)

In the summer of 1978, Carol Cordrey, the Assistant Principal at Delmar, separated from her husband and began to date Mr. Schreffler.⁵ (Tr. at C-66.) By September, rumors had begun to circulate in the community that Schreffler had "broken up" the Cordreys' marriage (Tr. at C-108) and some of these rumors reached Superintendent Bastian and certain members of the Board of Education. (Tr. at B-28, 63; D-192.) The rumors accelerated after September 20, 1978, when Schreffler sustained a broken arm in an altercation with Mr. Cordrey at the Cordrey residence. (Tr. at A-67.) When asked by interested persons about the cause of his injury, Schreffler refrained from disclosing the entire story in order to avoid embarrassing Mrs. Cordrey and simply replied that he had fallen in the driveway. (Tr. at A-67, 68.)

On November 6, 1978, at a routine administrators' meeting attended by Bastian, Schreffler, Cordrey and Kenneth Matthews, Administrative Assistant for the Delmar School District, Bastian questioned Schreffler and Cordrey about the rumors and was advised that they were in fact dating and would continue to do so. (Tr. at D-192.) Both Cordrey and Schreffler testified that Bastian reacted negatively to the news, stating that it was "absolutely terrible," and that Schreffler should not be dating single teachers of the Delmar High School. (Tr. at A-69, 70; C-69, 70.) In contrast, Bastian testified that he merely informed them that their social relationship was their personal business and that his only concern was that their relationship not interfere with school affairs.⁶ (Tr. at D-192.)

That same day, at a student disciplinary hearing attended by three Board members, Schreffler and Cordrey revealed to those present that they were dating and that Schreffler's broken arm occurred as a result of an encounter with Mr. Cordrey. (Tr. at A-71.) By all accounts, defendant C. Phillip Banks expressed his anger that Schreffler hadn't truthfully disclosed the origin of his injury when Banks previously asked him how the arm was broken. (Tr. at A-71, B-81.) Cordrey and Schreffler each further testified that the Board members generally were upset by the disclosure (Tr. at A-72, C-123), while the defendants denied this allegation. (Tr. at B-82, 113.)

On the morning of December 11, 1978, Bastian notified Schreffler for the first time that the renewal of his contract would be considered by the Board that afternoon. (Tr. at A-72, D-198.) At that meeting, Bastian voiced several criticisms about Schreffler's performance as principal, which, according to Schreffler, either had not heretofore been brought to his attention or were problems which were taken into account when he received his satisfactory evaluation in September. (Tr. at A-74, 90.) Subsequently, the Board unanimously voted not to renew Schreffler's contract. (Id.) Mrs. Cordrey's contract as Assistant Principal, however, was extended by the Board for a two year period. (Tr. at D-206.)

In response to a request by Schreffler, Superintendent Bastian sent him a letter dated December 19, 1978 setting forth in detail the reasons for Schreffler's non-renewal. (DX. 8.) Essentially, the letter noted in general terms that Schreffler had failed to show improvement in the areas cited as deficient in the September evaluation, and specifically criticized Schreffler's failure to arrive at work on time on several occasions during the preceding months. (DX. 8 at 2.) In particular, the letter stated that the Board was dismayed by Schreffler's apparent lack of concern about his tardiness problem at the December 11 meeting.⁷ (Id.) In addition, the letter generally described several other areas in which improvement had not been noted and cited several specific incidents which occurred in Schreffler's first year as grounds for the Board's decision. (Id.)

At Schreffler's request, another public hearing on his contract renewal was held on January 25, 1979. (DX. 9.) This meeting was attended by several parents, students and faculty members who testified in support of the renewal of Schreffler's contract. In addition, Schreffler was represented by counsel who presented evidence in his behalf and asked each member of the Board whether they could now impartially consider the evidence presented at this hearing in light of the fact that a decision had already been made in December not to renew Schreffler's contract. (Tr. at B-32, 47, 110.) Each member of the Board affirmatively responded that they could impartially reconsider their earlier decision. (Id.) Nonetheless, on February 12, 1979, the Board informed Schreffler that it had voted to reaffirm its earlier determination not to renew his contract. (Tr. at A-89.)

Schreffler filed this suit on May 8, 1979 alleging that defendants had violated his rights under the federal Constitution and Delaware law in the following respects: (1) Schreffler possessed a property interest in his employment and was deprived of that interest without due process of law; (2) defendants' decision not to renew Schreffler's contract was substantially based on Schreffler's relationship with Cordrey in violation of Schreffler's constitutional right to privacy; (3) defendants' decision not to renew Schreffler's contract was arbitrary and unreasonable and violated Schreffler's right to substantive due process; and (4) defendants' refusal to renew Schreffler's contract as principal constituted a breach of contract and a fraudulent misrepresentation in violation of Delaware law. After a six day trial, the jury found in favor of Schreffler on the right to privacy and procedural due process issues and awarded him $113,000 as...