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Burden v. Hayden
Citations: 275 Ark. 93; 627 S.W.2d 555; 1982 Ark. LEXIS 1248Docket: 81-171
Court: Supreme Court of Arkansas; February 8, 1982; Arkansas; State Supreme Court
George Rose Smith, Justice, addressed the case involving an appellant, a school teacher, whose contract with the Lavaca School District was not renewed after the 1977-1978 school year. Following a public hearing requested by Mrs. Burden, the school board upheld its decision not to renew her contract. At that time, the relevant statutes did not allow for an appeal to the circuit court. Consequently, Mrs. Burden filed a lawsuit in December 1978 against the school district and its officials, seeking a declaratory judgment to deem the non-renewal unlawful, along with reinstatement, back pay, and damages. The court's jurisdiction stemmed from Rule 29 (1.c). The court clarified that this case was not governed by previous cases such as Fullerton v. Southside Sch. Dist. and Maxwell v. Southside Sch. Dist., as the statutes and policies allowing for a statement of reasons and a hearing for nonprobationary teachers were not in effect when Mrs. Burden's contract expired. The case faced significant delays, attributed to the circuit judge taking 21 months to issue a ruling after the last brief was submitted. Although Mrs. Burden claimed the district failed to comply with its policies regarding non-renewal, the details of her complaint contradicted this assertion. The superintendent notified her of the non-renewal on April 11, allowing her five days to request a hearing, which she did not do until the sixth day, after the board's decision was made. She received five reasons for non-renewal but was not provided with witness names. The hearing later scheduled was explained by the superintendent as an opportunity for her to present her case for renewal rather than a trial. Ultimately, after the public hearing, the board unanimously upheld its non-renewal decision. The court found that there was substantial compliance with the applicable requirements despite a minor failure to provide three conferences for Mrs. Burden to discuss her performance prior to the non-renewal decision. The hearing was deemed sufficient to allow her to present her case before the decision was finalized. The complaint filed by Mrs. Burden does not adequately highlight the omission of significant facts. It claims a violation of her rights under the due process clause via 42 U.S.C. § 1983. However, case law indicates that a teacher with a one-year contract lacking tenure or a right to renewal typically cannot claim a deprivation of liberty or property if their contract is not renewed. Relevant precedents include Board of Regents of State Colleges v. Roth and Perry v. Sindermann. Although Roth acknowledged that a failure to rehire might harm a teacher's community standing or create a stigma affecting future employment, this does not apply in Mrs. Burden's case, as the reasons for her non-renewal were not publicly disclosed. Furthermore, while the board offered her a private hearing, her insistence on a public hearing potentially exposed any deficiencies, negating claims of a liberty deprivation. The court affirmed the decision.