Relph v. Board of Education of DePue Unit School District No. 103
Docket: No. 79-408
Court: Appellate Court of Illinois; April 29, 1980; Illinois; State Appellate Court
The defendant, DePue Unit School District No. 103, appeals a circuit court judgment mandating the payment of $41,294 to plaintiff Norma Relph and her reinstatement as a high school home economics teacher. Relph, a tenured teacher, was dismissed in 1973 for economic reasons and was not hired for two subsequent open teaching positions. She sought a writ of mandamus under section 24.12 of the School Code, which requires that recently dismissed tenured teachers be offered available positions if they are "legally qualified." The circuit court initially ruled in favor of the school board, stating Relph did not meet the qualifications outlined in Circular Series A, No. 160. Relph appealed (Relph I), and the appellate court reversed the circuit court's decision, determining that her certification for grades 6 through 12 qualified her for the positions, and the Circular Series A, No. 160 requirements were advisory. The Illinois Supreme Court denied leave to appeal on this ruling.
After the appellate court’s decision, Relph filed a motion for damages, which led to a stipulation regarding her potential salary. However, while this motion was pending, the Illinois Supreme Court issued a ruling in Lenard v. Board of Education, stating that the qualifications in Circular Series A, No. 160, must be considered in determining if a teacher is "legally qualified." Following this ruling, the school board sought reconsideration based on the Lenard decision, but the trial court denied the motion, feeling bound by the previous appellate ruling. The trial court ultimately entered judgment for Relph, granting her damages and reinstatement.
The board contends that the Illinois Supreme Court's decision in Lenard should apply to this case, necessitating a judgment in its favor. It claims the trial court was required to adhere to Lenard and rule for the board of education. Conversely, plaintiff Norma Relph maintains that the prior appellate decision is binding and should prevail, asserting that Lenard's ruling is irrelevant to her case and advocating for the maintenance of the judgment in her favor. The court agrees with Relph, referencing the doctrine of res judicata as established in Hagopian v. Board of Education, which clarifies that a final appellate mandate is conclusive and can prevent re-litigation of the same issues, even if subsequent legal interpretations differ. The court emphasizes that an error in law does not negate the application of res judicata. The analysis of Relph I reveals that the judgment directive was specific and did not allow for a general remand, thereby obligating the circuit court to comply with the appellate mandate, which required entering a judgment favoring Relph for hiring and salary parity with other district teachers. With the Illinois Supreme Court's denial of appeal following Relph I, the circuit court was bound to follow the appellate court's instructions precisely.
Incorporating terms into a mandate through reference to pleadings is a recognized practice. Upon remand, the trial court must issue a writ that aligns with these referenced terms, and it cannot make further determinations once the appellate court has reversed its judgment or remanded the case with specific directions. The trial court and the parties are bound to act only to implement the reviewing court's mandate, as established in **Hamilton v. Faulkner** and **Martin v. Prairie Rod. Gun Club**. Any action beyond issuing the writ of mandamus by the trial court is deemed improper. The finality of the writ's issuance was affirmed when the supreme court denied further review on November 23, 1977, as illustrated by **Rubin v. Kohn** and **Hagopian v. Board of Education**. The mandate from **Relph I** fulfilled the criteria for estoppel by judgment, necessitating a specific new decree, thus rendering it res judicata on the issues at hand. Norma Relph’s judgment is now considered definitive. The appellate court lacks jurisdiction to revisit this matter, and prior judgments prevent relitigation of resolved issues, leading to the dismissal of the appeal. The appellate court holds the authority to render any appropriate judgment as outlined in the Illinois Revised Statutes. When a case is barred by a prior judgment, dismissal is the appropriate remedy.
