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Head v. Caddo Hills School District
Citations: 294 Ark. 561; 745 S.W.2d 595; 1988 Ark. LEXIS 168Docket: 87-301
Court: Supreme Court of Arkansas; February 22, 1988; Arkansas; State Supreme Court
Joe Dale Head filed a lawsuit against the Caddo Hills School District, claiming his teaching contract was terminated in a manner that violated the Arkansas Teacher Fair Dismissal Act, alleging arbitrary, capricious, and discriminatory reasons. The district moved to dismiss based on res judicata, and the trial court granted the dismissal. Head appealed this decision. Head had been a probationary teacher during the 1979-80 school year and was notified in July 1980 that his contract for the following year would not be renewed. After a hearing, the school board upheld the nonrenewal. Although the circuit court affirmed this decision, it incorrectly classified the action as a nonrenewal rather than a termination. The appellate court agreed with the circuit court's conclusion but noted a critical jurisdictional issue: probationary teachers like Head do not have a right to appeal under the Teacher Fair Dismissal Act. Following the appellate court's mandate, Head initiated the current lawsuit, which was dismissed on res judicata grounds. The appellate court found this dismissal erroneous, stating that a lack of jurisdiction renders the previous decree void and thus not applicable for res judicata in subsequent actions. It emphasized that Head's claim for breach of contract due to illegal termination had never been previously asserted and could not be precluded by an unsuccessful appeal to a court lacking jurisdiction. The court reversed the dismissal and remanded the case for further proceedings.