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Rauhaus v. Buckeye Local School District Board of Education

Citations: 6 Ohio St. 3d 320; 453 N.E.2d 624; 6 Ohio B. 379; 1983 Ohio LEXIS 830Docket: No. 82-1392

Court: Ohio Supreme Court; August 31, 1983; Ohio; State Supreme Court

Narrative Opinion Summary

This case involves a dispute regarding the application of Ohio's statutory minimum salary requirements for teachers, specifically under R.C. 3317.13 and R.C. 3317.14. The appellant, a school board, was challenged by the appellee, a teacher, for not providing a salary that reflected her five years of teaching experience according to the local salary schedule, despite meeting the statutory minimum. The appellee argued that her experience should be credited fully, supported by the precedent set in Bernardini v. Bd. of Edn., which mandates credit for military service on salary schedules. The appellant contended that Bernardini pertained only to military service and not to teaching experience. The court, however, found that the principles in Bernardini were applicable, requiring the appellant to credit both teaching and military experience up to five years fully. Thus, the court of appeals' judgment was affirmed, ensuring that the appellee's salary was adjusted to reflect her qualifications and experience per the local salary schedule, beyond merely meeting the statutory minimum.

Legal Issues Addressed

Local Salary Schedule Compliance under R.C. 3317.14

Application: The court determined that school boards must adhere to their local salary schedules, ensuring full credit is given for teaching and military experience up to five years.

Reasoning: R.C. 3317.14 mandates that school boards adopt a salary schedule with increments for training and experience, ensuring no teacher earns less than the minimum outlined in R.C. 3317.13.

Minimum Salary Requirement under R.C. 3317.13

Application: The court affirmed that teachers must be paid no less than the minimum salary set forth by the statutory schedule, which considers years of service and training.

Reasoning: R.C. 3317.13 mandates that no teacher receive less than the minimum salary set in its schedule, which accounts for years of service, including a maximum of ten years for new teachers to the district.

Precedential Effect of Bernardini v. Bd. of Edn.

Application: The court applied Bernardini to clarify that military and teaching experience must be credited on the salary schedule, irrespective of whether the schedule exceeds the statutory minimums.

Reasoning: In Bernardini, it was determined that military service credit is entitled regardless of the salary schedule exceeding minimums.