Harrah Indep. Sch. Dist. v. Martin - 440 U.S. 194 (1979)
U.S. Supreme Court
Harrah Indep. Sch. Dist. v. Martin, 440 U.S. 194 (1979)
Harrah Independent School District v. Martin
Decided February 26, 1979
440 U.S. 194
Respondent, a tenured teacher, was denied salary increases during the 1972-1974 school years because of her refusal to comply with the School Board's continuing education requirement, which was incorporated by reference into her employment contract. After the Oklahoma Legislature enacted a law mandating certain salary raises for teachers regardless of their compliance with the continuing education policy, the School Board notified respondent that her contract would not be renewed for the 1974-1975 school year unless she enrolled in the required continuing education courses. When respondent refused to comply, the School Board found that her persistent noncompliance with the continuing education requirement constituted "willful neglect of duty" under an Oklahoma statute and refused to renew her contract for the following school year. The District Court dismissed respondent's complaint, which claimed that the School Board's action denied respondent her liberty and property without due process of law and equal protection of the laws, as guaranteed by the Fourteenth Amendment. The Court of Appeals reversed.
1. The School Board's actions did not violate respondent's due process rights. Respondent has no colorable claim of a denial of procedural due process: she was advised of the School Board's decision not to renew her contract and of her right to a hearing before the Board, and, at her request, a hearing was held at which both she and her attorney appeared and unsuccessfully contested the Board's determination that her refusal to enroll in continuing education courses constituted "willful neglect of duty." Nor did the School Board's action deny respondent substantive due process. After the state legislature, by making pay raises mandatory, deprived the Board of the sanction that it had earlier used to enforce its teachers' contractual obligation to earn continuing education credits, the Board turned to contract nonrenewal, but applied this sanction purely prospectively, so that those who might have relied on its past practice would nonetheless have an opportunity to bring themselves into compliance with the terms of their contracts. Such a course of conduct on the part of a school board responsible for the public
education of students within its jurisdiction, and employing teachers to perform the principal portion of that task, can scarcely be described as arbitrary
2. Respondent was not deprived of equal protection of the laws. The School Board's concern with the educational qualifications of its teachers cannot, under any reasoned analysis, be described as impermissible, and it is not contended that the Board's continuing education requirement bears no rational relationship to that legitimate governmental concern. The sanction of contract nonrenewal, imposed uniformly on the "class" of teachers who refuse to comply with the continuing education requirement, is quite rationally related to the Board's objective of enforcing the continuing education obligation of its teachers. That the Board was forced by the state legislature to penalize noncompliance differently than it had in the past in no way alters the equal protection analysis of respondent's claim.
Certiorari granted; 579 F.2d 1192, reversed.