ADVERSE EMPLOYMENT ACTIONS AND PUBLIC SCHOOL ...

In 1955, LaBelle was hired as an elementary teacher. In 1966, she was promoted to the
position of assistant principal. Eight year later, she was elevated to the position of principal. In
1978, she was notified of her non-renewal as principal and reassignment as an elementary
teacher. Upon request for a hearing and statement of reasons for demotion, she was informed by
letter that financial contractions made it necessary to lessen administrative positions. There was
no mention of a hearing as that is not a mandate in California public school law.
Issues: (1) Was city charter 5.101 wrongly overruled by § 44850.1 of the Education
Code? (2) Did the trial court err in not allowing LaBelle to submit evidence that she had a
legitimate expectation of continued employment as principal based on her satisfactory
performance?
Holding: The court held that Labelle’s claims were either trumped by state statutes or by
misinterpretations of her current contract and found for the defendants.
Reasoning: Under § 5.101 of the Charter of the City and County of San Francisco,
administrators and supervisors were granted 4-year renewable contracts so long as their
performance was satisfactory. This was very near to tenure. Nonetheless, this charter did not
apply to LaBelle because she was certified as a teacher and had been granted tenure as a teacher
under §§ 44894 and 44895 of the educational code.
LaBelle’s continued argument for submission of evidence was incorrect. LaBelle
contended that because her job performance was satisfactory she was entitled to certain measures
of due process. This was ill-founded in so much that LaBelle’s assertions were still based on §
5.101 of the city charter, which held no bearing on her reassignment.
Disposition: The judgment was affirmed in full.
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