ADVERSE EMPLOYMENT ACTIONS AND PUBLIC SCHOOL ...

carried out in reaction to the declining enrollment and tax revenue and done so pursuant to G. L.
c. 59 § 20A. Moreover, the plan was approved by the board in majority. Thus, the reorganization
was legal and not arbitrarily or capriciously carried out. Because the court found that the
reorganization was valid, Breslin et al. had no grounds to appeal on because their “demotion”--
more aptly termed reassignment--was a valid systemic reorganization whereby demotion
hearings were not mandatory.
Disposition: The judgment was affirmed.
Citation: Rabon v. Bryan County Board of Education, 173 Ga. App. 507; 326 S.E.2d 577,
(1985 Ga. App.).
Key Facts: Lee Rabon was principal of Bryan County High School. Rabon offended a
number of different teachers by making inappropriate and unprofessional remarks about students
and discussing matters of sex with teachers.
The Bryan County Board of Education referred the situation to the Professional Practices
Commission (PPC). Following the PPC’s investigation, it recommended a suspension without
pay for 60 days. The board, however, chose to terminate Rabon based on the facts found in the
PPC’s investigation. The board agreed that Rabon had irreparably injured his own ability to
communicate effectively and instill confidence as the leader of the school. Thus, Rabon was
terminated on the grounds of “incompetency” and “good and sufficient cause.” Rabon brought
suit in the Bryan County Superior Court. The court affirmed the board’s decision. Rabon
appealed.
Issues: Was the board bound to accept the disciplinary measures prescribed by the PPC?
Holding: The court held that the board acted completely within its authority pursuant to
O.C.G.A. § 20-2-1160 (c).
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