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Junction City School District v. Alphin
Citations: 56 Ark. App. 61; 938 S.W.2d 239; 1997 Ark. App. LEXIS 79Docket: CA 96-288
Court: Court of Appeals of Arkansas; February 19, 1997; Arkansas; State Appellate Court
Olly Neal, Judge, affirms the Union County Circuit Court's November 28, 1995, order favoring appellee Margaret Alphin, a teacher whose salary was reduced by the Junction City School District. This reduction, enacted by the school board on April 28, 1994, constituted a breach of the Arkansas Teacher Fair Dismissal Act, leading to the court's ruling in favor of Alphin. The court awarded her back pay and reinstatement but later retracted the attorney's fee award, which was deemed an error. The Junction City School District faced a financial crisis in 1994 due to the termination of turn-back funds from Arkansas. In response, a temporary injunction was issued to delay this funding cut until the next school year. Following a hearing requested by Alphin, the board offered her a part-time position, which represented a 3/7th salary reduction, down from an initially proposed 4/7th cut. Alphin accepted under the condition of appealing the decision. The circuit court found that the school board's actions were arbitrary and capricious and did not comply with its own policies or state law. Superintendent Alvin Kelly testified that he was responsible for establishing criteria for contract reductions, solely considering teaching certification and seniority. The district's reduction in force policy was rejected by the board, which had two conflicting policies regarding personnel dismissals. The court clarified that the appropriate standard of review in such appeals is whether the circuit court's findings were clearly erroneous, rather than assessing if the board's decisions had a rational basis. The trial court determined that the board's attempt to reduce the appellee’s contract did not adhere to its own personnel policies, violating state law. The court ruled that the board's actions were arbitrary and capricious since they did not reference their policies. The Teacher Fair Dismissal Act mandates that each district maintain written personnel policies, have a committee comprising teachers and administrators, and require school board approval for policy modifications. Since 1989, strict compliance with the Act has been legally required. School policy is inherently part of teachers' contracts, and teachers expect adherence to these policies. At the time of the contract reduction, the district had a personnel policy, which allowed the board to terminate or demote personnel under specific conditions, ensuring fair treatment and maintenance of educational standards. The policy GAAB outlined criteria for dismissals and reductions, including both objective (certification, experience, etc.) and subjective criteria (performance, leadership, personality). However, the superintendent only utilized two of the thirteen criteria. The court found that the criteria from policy GAAB were necessary for compliance, and since the superintendent acted unilaterally without following the established criteria, the trial court's finding of non-compliance was upheld. Despite time constraints on the district, state law prohibits bypassing established dismissal criteria. Furthermore, actions under the Fair Dismissal Act qualify for attorney’s fees under Arkansas law. The trial court failed to decide on attorney’s fees, necessitating a reversal and remand for this issue. The appeal was affirmed in part and reversed and remanded in part.