ADVERSE EMPLOYMENT ACTIONS AND PUBLIC SCHOOL ...

ought about multiple suits, which were consolidated by the court for timeliness, and Smith’s
suit, which held distinction due to the “contract” issues that were aforementioned.
Issues: (1) Was Smith’s contract valid when measured against R.C. 3319.02? (2) Were
the due process rights of the appellants violated?
Holding: The court held that there were numerous issues in this case that presented
complexity and simplicity at the same time. Thus, their findings were mixed for the appellants
and appellees on certain grounds.
Reasoning: As to the contractual inconsistencies and Smith, the court reviewed R.C.
3319.02 and determined that Smith’s non-renewal of a non-existent position automatically made
him eligible for renewal in his true position. The court reversed the trial court on this count and
ordered Smith reinstated with back pay and legal fees.
As to the other appellants, the results were positive yet mixed. The appellants levied four
claims in their due process violations against the board: (1) timeliness of their notification of
non-renewal, (2) failure to produce written notification of the reasons for non-renewal, (3) failure
of the board to base its decision to non-renew on personnel evaluations, and (4) illegally
conducting a reduction in force.
On the grounds that the board failed to notify of non-renewal in a timely manner (March
30), the court found that the board was in violation on each count except for their notifications of
James Cauley and Hugh Durbin, which occurred before March 30. The court ordered for
reinstatement of the non-renewed principals with back pay and legal fees.
The board’s failure to provide written notification of reasons for non-renewal was a
mistake on the part of the appellants. Provisions regarding written notification of reasons for
non-renewal were limited for teachers, not administrators. Thus, the court affirmed here.
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