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Sharpton v. Winston County Board of Education
Citations: 450 So. 2d 124; 17 Educ. L. Rep. 1013; 1984 Ala. Civ. App. LEXIS 1240Docket: Civ. 3977
Court: Court of Civil Appeals of Alabama; February 14, 1984; Alabama; State Appellate Court
Dalton Sharpton served over thirty-two years in the Winston County educational system as a tenured teacher, principal, and guidance counselor, holding additional duties as a professional development coordinator. This coordinator position, created by the Winston County Board of Education on Superintendent Lott's recommendation, was not tenured. In June 1981, Lott recommended Sharpton's reemployment for the upcoming year. However, on July 29, 1981, new Superintendent Letha Weaver informed Sharpton that his salary was reduced to $17,090.53, and his employment period was cut from twelve months to ten months, effectively eliminating his role as professional development coordinator. Sharpton retired at the end of the 1981-82 school year and sought to recover lost pay, asserting that the pay reduction violated the Tenure Act and his due process rights under the Fourteenth Amendment. Although the trial court found that Sharpton's coordinator role was not tenured and thus not protected under the Teacher Tenure Act, it acknowledged that his due process rights were infringed upon. Sharpton claimed lack of a written contract for the 1981-82 school year but argued he was reemployed as a professional assistant based on the prior year's arrangements. Sharpton was reemployed for the 1981-82 school year at his current salary, but the new superintendent, Mrs. Weaver, recommended the elimination of his position as professional development coordinator. The board of education followed this recommendation and terminated Sharpton's position without notice or a hearing. Sharpton contended that he was entitled to due process because he had been hired for a twelve-month term starting in June 1981. The court agreed, stating that Sharpton should have received notice and a hearing before his termination, as he had been effectively reemployed for the new school year. The board argued that his appointment expired with the previous superintendent's term, citing a 1934 Alabama Supreme Court case, Roberts v. State, which dealt with clerical positions. However, the court distinguished this case, referencing a later decision in Roth that recognized public employees' due process rights when they have protected interests in continued employment. Sharpton demonstrated that he had such interests, and the failure to provide him with due process violated his constitutional rights. Consequently, the trial court's judgment was reversed, and the case was remanded with directions for the board to conduct a hearing before taking any further action regarding Sharpton’s employment. The court emphasized that it was not ruling on the merits of Sharpton's termination, only that he was entitled to a hearing.