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Davis v. Board of Education of Aurora Public School District No. 131

Citations: 312 N.E.2d 335; 19 Ill. App. 3d 644; 1974 Ill. App. LEXIS 2685Docket: 72-312

Court: Appellate Court of Illinois; June 5, 1974; Illinois; State Appellate Court

Narrative Opinion Summary

In the case of tenured teachers versus the Board of Education of Aurora Public School District No. 131, the plaintiffs appealed a dismissal of their claim for declaratory judgment concerning salary discrepancies. The dispute arose when the Board offered a new contract with increased benefits, requiring a no-strike clause. Teachers who refused to sign this contract were given the option to return under the previous year's terms. The plaintiffs argued that they were entitled to the same salary increases as those who signed the new contract. The Illinois Appellate Court examined whether the Board's actions in establishing two salary schedules were arbitrary or unreasonable. It was held that tenured teachers are not obliged to sign new contracts, and those who choose not to sign naturally revert to the prior year's terms. The court found the Board's distinction between signed and unsigned contracts justified and not capricious, affirming that unsigned teachers are not entitled to benefits of the new contract. However, the court also determined that plaintiffs are entitled to a salary increment for their additional experience under the previous year's schedule. The case was affirmed in part, reversed in part, and remanded for further proceedings to grant the plaintiffs the appropriate salary increment.

Legal Issues Addressed

Contractual Obligations for Tenured Teachers

Application: Tenured teachers are not legally required to sign new contracts offered by the Board of Education and may continue under the previous year's terms if they choose not to sign.

Reasoning: The court recognized that Illinois law does not mandate tenured teachers to sign new contracts but allows Boards to establish new contracts.

Equitable Salary and Contractual Acceptance

Application: The Board's establishment of two salary schedules based on contract signing was found to be neither arbitrary nor unreasonable, reflecting equitable treatment of teachers who chose different contractual options.

Reasoning: The court found this distinction neither arbitrary nor unreasonable, noting it would be unjust to extend benefits to those who opted out.

Right to Salary Increment for Experience

Application: Plaintiffs who chose to return under the previous year’s contract terms are entitled to a salary increment based on additional experience accrued under that schedule.

Reasoning: It was determined that the plaintiffs, by accepting option 'B,' are entitled to a salary increment based on their additional experience under the 1970-71 schedule.