ADVERSE EMPLOYMENT ACTIONS AND PUBLIC SCHOOL ...

Finally, McCormack accused M-RHSD with intentionally inflicting emotional distress on
her. The court was not persuaded. Because summary judgment was properly awarded to the
defendant, the intentional infliction of emotional distress was not a sustainable argument.
Disposition: The Missouri Court of Appeals affirmed the circuit court’s ruling for
summary judgment in favor of the defendants.
Citation: Brown v. Board of Education, 928 P.2D 57, (1996 Kan.).
Key Facts: Brown had served as a principal for 3 years in Unified School District No.
333. She was notified of her non-nonrenewal in March of the 1994-1995 school year. Reasons
for non-renewal were cited as a failure to develop staff trust and support due to poor
organizational and leadership measures. Brown was provided the opportunity to meet in
executive session with the board. She was provided with reasons for non-renewal and a chance to
respond to the board’s reasoning. Following the meeting, the board held firm in its decision to
non-renew Brown.
Brown brought suit against the school district based on claims that she was not afforded
proper protection under the Kansas Administrator’s Act (Kan. Stat. Ann. § 72-5451). Moreover,
she argued that her non-renewal was made under “quasi-judicial” circumstances, which meant
that evidence had to be heard and presented at the meeting. Brown contended that these failures
invalidated her non-renewal. The district court found in favor of Brown. The defendants
promptly appealed claiming the court’s review was invalid because the meeting was not
“judicial” or quasi-judicial,” which meant that official review was not allowable.
Issues: (1) Does the Kansas Administrator’s Act require boards to show “good cause”
when choosing to non-renew an administrator? (2) Were Brown’s due process rights violated
through the board’s non-renewal procedures thereby denying her a legitimate property interest in
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