ADVERSE EMPLOYMENT ACTIONS AND PUBLIC SCHOOL ...

Key Facts: During the 1981-1982 school year, Sweeney et al. were administrators in the
Special School District No. 1. Each had been employed for at least 15 years in some capacity by
the district. Following this school year Sweeney et al. were demoted from either the principal
position to assistant principal or assistant principal to a teacher position based on a new school
district reorganizational plan.
While the board did adhere to seniority mandates in carrying out these demotions, it
failed to conduct hearings with Sweeney et al. This was a violation of their tenure rights. The
board was not arbitrarily overhauling the school system as they were empowered with the
authority to reorganize and realign, but that authority did not provide them with a pass to
circumvent tenure rights vested in Cities of the First Class Tenure Act (Minn. Stat. § 125. 17).
Sweeney et al. filed suit and the court reversed the decisions of the board. The board filed this
appeal.
Issues: (1) Were the demotions of Sweeney et al. valid and in accordance with Minn.
Stat. § 125. 17? (2) Were the due process rights of Sweeney et al. violated, and if so, were they
eligible for monetary damages?
Holding: The court held that the trial court properly ruled in reversing the orders of the
board, but needed to further clarify the attorney’s fees that it awarded to Sweeney et al. as it
noted the amount seemed exorbitant.
Reasoning: Following the Teacher Tenure Act, Sweeney et al. qualified, as principals are
listed in the act. Therefore, they are entitled to a hearing upon demotion as outlined in Minn.
Stat. § 125. 17, subd. 3. Thus, the demotions were valid based on reason but not in procedure.
To determine whether damages or attorney fees are available under 42 U.S.C. § 1988,
Sweeney et al., had to prove that they were deprived of a life, liberty, or property interest and
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