ADVERSE EMPLOYMENT ACTIONS AND PUBLIC SCHOOL ...

presented. In the case of Ledew, it seemed evident to the court that a reasonable person would
construe the events preceding Ledew’s resignation as creating an atmosphere where no other
choice was available.
Because the court ruled that Ledew’s resignation was not voluntary, Ledew’s request for
reinstatement carried great weight. This court noted that the trial court erred in its presentation of
responsibilities to the jury on this item. The trial court unloaded the burden of proof on Ledew to
prove that, without his resignation, he would have been reemployed by the board. The facts
presented suggest that this would not have been the case. Therefore, because the court erred in
placing burden of proof on Ledew and not the board, Ledew was entitled to reinstatement.
Disposition: The court denied the post-trial motion of the board for judgment
notwithstanding verdict and granted reinstatement to Ledew.
Citation: Snipes v. McAndrew, 280 S.C. 320; 313 S.E.2d 294, (1984 S.C.).
Key Facts: Ralph Snipes and J. Alvin Shaw had each served 10 or more years as
principals in the Richland County School District when they were informed that they would be
reassigned. Both brought suit individually seeking to postpone the board’s action until they could
be heard and to be reinstated as principals respective of their current position. These motions
were granted and appeals followed.
Issues: (1) Were Snipes and Shaw entitled to an evidentiary hearing in accordance with
S.C. Code Ann. § 59-25-460? (2) Did the evaluative measures employed by the district mandate
a full hearing prior to dismissal? (3) Did Snipes and Shaw hold property interests in their
principal positions?
Holding: The court held that the tenure protections appealed to by Snipes and Shaw
offered protection only as teachers and not as administrators.
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