ADVERSE EMPLOYMENT ACTIONS AND PUBLIC SCHOOL ...

way evidentially rebutted the assertion by the district, Ritter, and Cozette that she was removed
from Lee for her ineffective leadership and caustic relationships.
Howard claimed that the district, Ritter, and Cozette violated her liberty interest by
stigmatizing her through speech and official letters presented to the public. The court disagreed.
One example presented by Howard was a letter to the board--not publically disclosed prior to the
trial--that cited her poor leadership. Moreover, the only publically released letter that reflected
Howard’s change in position was a submission to the local paper that announced Howard’s new
position and praised her grant-writing abilities.
Howard also claimed a violation of her property interest in continued employment as
principal. This argument was ill-founded. Mo. Ann. Stat. § 168.101(6) outlines procedural rights
of principals and enumerates that principals may not gain tenure but may gain further procedural
safeguards after having been reemployed for 5 years by a district. These safeguards did not
protect Howard as she had only been employed for 3 years. Moreover, she was notified of her
non-renewal in timely fashion.
Howard also argued that her right to equal protection was violated by the district, Ritter,
and Cozette because other struggling principals were provided more support and treated more
favorably than she. Once again, the court found this assertion to be without merit, for Howard
provided no evidence to refute the district, Ritter, and Cozette’s explanation. Howard’s state law
claims, likewise, were found to be without merit and dismissed.
Va.).
Disposition: The district court judgment was affirmed.
Citation: Tazewell County School Board v. Brown, 267 Va. 150; 591 S.E.2d 671 (2004
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