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Evans v. Board of Education of Murphysboro Community Unit School District

Citations: 85 Ill. App. 3d 436; 406 N.E.2d 855; 40 Ill. Dec. 652; 1980 Ill. App. LEXIS 3078Docket: No. 79-320

Court: Appellate Court of Illinois; June 6, 1980; Illinois; State Appellate Court

Narrative Opinion Summary

In this case, the petitioner, a school psychologist, sought reinstatement and damages following his dismissal by a local high school district. He filed a petition for a writ of mandamus and a complaint for declaratory judgment against the local Board of Education and the executive board of a special education district. The trial court ruled in favor of the respondents, finding the petitioner was not employed by the special education district. On appeal, the petitioner challenged this finding, asserting that he was employed by the district, which controlled his hiring, work methods, and salary. The appellate court determined that the trial court's decision was against the manifest weight of the evidence, as the petitioner's employment was integral to the special education district's operations and funding. The court emphasized that the authority to terminate employees in a special education district lies with the district's executive board, not the operating district. Consequently, the appellate court reversed the lower court's judgment, ordering the petitioner's reinstatement and remanding the case to calculate damages for the improper termination.

Legal Issues Addressed

Authority to Dismiss Employees in Special Education Districts

Application: The court concluded that District 165 lacked authority to dismiss the petitioner, as such power lies with the special education district’s executive board.

Reasoning: The court concluded that petitioner was indeed an employee of the Tri-County Special Education District, and the trial court's contrary finding was against the manifest weight of the evidence.

Employment Status Determination under Federal Employers’ Liability Act

Application: The court applied the F.E.L.A. criteria to determine the petitioner's employment status, focusing on the control exerted over work methods and payment by the Tri-County Special Education District's executive board.

Reasoning: The court analyzed whether a party qualifies as an employee under the Federal Employers’ Liability Act (F.E.L.A.), emphasizing that the terms 'employee' and 'employed' reflect the traditional employer-employee relationship without a special definition.

Manifest Weight of the Evidence in Employment Disputes

Application: The appellate court found that the trial court's judgment was against the manifest weight of the evidence, as the petitioner's employment was beneficial to the special education district and controlled by its executive board.

Reasoning: The court concluded that petitioner was indeed an employee of the Tri-County Special Education District, and the trial court's contrary finding was against the manifest weight of the evidence.

Reinstatement through Writ of Mandamus

Application: The court ordered a writ of mandamus to reinstate the petitioner as a school psychologist, reversing the lower court's decision.

Reasoning: Based on these conclusions, the court reversed the Circuit Court of Jackson County’s judgment, ordered a writ of mandamus to reinstate petitioner as school psychologist, and remanded the case to determine damages from the improper discharge.