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Dillon v. Board of Educ. of County of Mingo

Citations: 301 S.E.2d 588; 171 W. Va. 631; 1983 W. Va. LEXIS 484Docket: 15548

Court: West Virginia Supreme Court; March 25, 1983; West Virginia; State Supreme Court

Narrative Opinion Summary

The case concerns an appeal by teachers against the Board of Education regarding unpaid wages during a school closure caused by parental picketing. The Supreme Court of Appeals of West Virginia evaluated whether the Board had a duty to pay teachers under W.Va. Code, 18A-5-2, which mandates compensation during school closures due to uncontrollable 'calamitous causes.' Initially, the Circuit Court of Mingo County denied a writ of mandamus sought by the teachers, asserting no legal obligation for payment. However, the Supreme Court reversed this decision, finding that the teachers were entitled to compensation, as the picketing constituted a 'calamitous cause' warranting closure. The court emphasized the statutory and contractual obligations to pay teachers during such events, guided by analogous precedents and the state superintendent's interpretation. The ruling highlighted the board's inconsistent legal stance regarding the nature of the picketing and reinforced the procedural validity of the mandamus action. Consequently, the case was remanded for further proceedings, affirming the teachers' right to payment for the closure period, thereby supporting their economic rights under the statute.

Legal Issues Addressed

Interpretation of 'Calamitous Cause' in School Closure Statutes

Application: The court interpreted 'calamitous cause' broadly, including emergencies like picketing that threaten the welfare of the school, thereby obligating the board to compensate teachers.

Reasoning: The term 'calamitous cause' is defined as any emergency threatening the school's welfare.

Judicial Deference to State Superintendent's Interpretation

Application: The court accorded substantial weight to the state superintendent's interpretation that teachers are entitled to pay during closures unless clearly erroneous.

Reasoning: The state superintendent's interpretation, stating that teachers are entitled to pay during closures, is given significant weight unless clearly erroneous.

Mandamus as a Remedy

Application: The court found that the mandamus action was procedurally appropriate as there was a clear legal right to compensation and a corresponding duty of the board to fulfill this right.

Reasoning: The appellants' mandamus action was procedurally sound, as it demonstrated a clear legal right and a corresponding duty that the board failed to fulfill.

Preclusion of Inconsistent Legal Positions

Application: The board was precluded from denying the presence of intimidation during picketing, having previously taken an inconsistent position in related legal proceedings.

Reasoning: The board's argument regarding insufficient evidence of intimidation preventing teachers from crossing the picket line is undermined by their prior inconsistent position in a related injunction suit.

Teachers' Right to Compensation During School Closures

Application: The court held that teachers are entitled to pay during school closures caused by uncontrollable circumstances, such as picketing, which qualifies as a 'calamitous cause' under W.Va. Code, 18A-5-2.

Reasoning: The trial court erred in ruling that the school board had no obligation to pay teachers for the four days the school was closed due to intimidating picketing, which justified the closure.