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Ramsay v. Sierra Vista Unified School District No. 68
Citations: 144 Ariz. 260; 697 P.2d 343; 1985 Ariz. App. LEXIS 468Docket: No. 2 CA-CIV 5055
Court: Court of Appeals of Arizona; March 11, 1985; Arizona; State Appellate Court
The case pertains to the authority of a school board to employ a teacher as a "continuing teacher" after the teacher, James Ken Ramsay, failed to accept a re-employment offer within the statutory timeframe. Ramsay had been employed by the Sierra Vista Unified School District for eight years and received a continuing teacher's contract offer on May 11, 1982. He submitted the signed contract on June 14, 1982, which was four days past the 30-day acceptance period mandated by former A.R.S. 15-536(A). Following this, the assistant superintendent informed Ramsay that his failure to meet the deadline resulted in the revocation of his continuing teacher's contract. Ramsay later requested another contract, and while he was allowed to apply for a new position, the subsequent contract offered on August 20, 1982, was labeled as a probationary contract, omitting the term "continuing." Ramsay filed a complaint for a declaratory judgment, arguing he did not resign his tenure status or, alternatively, that his rehiring restored his tenure rights. The district contended that Ramsay's non-compliance with A.R.S. 15-536(A) legally terminated his right to re-employment as a continuing teacher and that the governing board lacked the authority to offer him that status. The district successfully moved for summary judgment, asserting that Ramsay was not statutorily qualified to be a continuing teacher. The central issue in this case involves the interpretation of A.R.S. 12-2101 and the implications of the 30-day notice provision in former A.R.S. 15-536(A). This provision does not strip a school district of its contractual power but merely revokes the initial offer made to a teacher. The statute does not specify the actions a district can take after revoking the offer, allowing for the application of ordinary contract law principles. According to these principles, a school district can immediately extend the same offer to a teacher it wishes to employ. The 30-day notice provision aims to provide flexibility for school districts in their hiring practices by ensuring they know who will be available for the upcoming year. Interpreting the statute as limiting the district’s options would contradict this intent. Therefore, it is determined that the former A.R.S. 15-536(A) allows the district to reoffer a contract to Ramsay. Since the district operated under an incorrect assumption regarding its authority, the court examines whether the facts support a different outcome. There is no factual dispute, as the district has consistently offered Ramsay an identical contract, which it has renewed for nine consecutive years. Ramsay is entitled to the declaratory relief sought, leading to the reversal of the trial court's judgment and a remand for a declaratory judgment affirming the continuity of Ramsay’s contract under the Arizona Teacher Tenure Act.