— I dissent.
First, Education Code section 440311 applies only to materials placed in the personnel file — not to an unfiled superintendent’s report. Second, even assuming the section is applicable to the superintendent’s report, nothing in section 44031 mandates, or even suggests, the quasi-adversary *719administrative transfer procedure established by the majority.2 Section 44031 in the plainest terms deals with inspection of school employees’ personnel files and rebuttal of derogatory information therein. It does not purport to govern administrative transfer proceedings or to establish evidentiary rules for the use of file information. Third, even assuming that the section is applicable to the superintendent’s report and that the section establishes an evidentiary rule governing use of file information, applicable principles of judicial review require affirmance of the judgment denying mandate.
I
Permitting rebuttal of personnel file information, section 44031 contains no language requiring the inclusion of any information in the file. Had the Legislature intended that certain information, derogatory or laudatory, was to be included in the files, the Legislature could have easily so provided. It did not. The section should accordingly be interpreted as applying only to information placed in the file. Such interpretation is reflected by the exceptions in the section. Those exceptions do not merely authorize withholding of information but prohibit inclusion of the excepted information.
The majority’s construction of the section mandates a costly paperwork explosion, impairing the administration of our school system and education of our children. Construing the section as requiring inclusion in the file of all derogatory information “within a reasonable time of ascertaining the material” (see fn. 2), means that superintendents must prepare a written report of each meeting with an administrator and of each criticism or suggestion made so that the administrator may rebut the report before it is filed.3 Superintendents also must record their critical observations of school programs, classroom visits, and public complaints they receive, for those also may influence a later demotion decision. Because the section also applies to teachers, the superintendent and the administrators must compile similar records for each teacher. The time *720needed to satisfy this requirement represents an impossible burden for the superintendent, administrators, and teachers. Further, it becomes patently unreasonable in light of the fact that little of such material ever will be used. In these days of school district austerity, the paperwork explosion can only mean unjustified expense and impairment of administration and teaching in our schools.
In support of their statutory interpretation, the majority cite the need to prevent preservation of stale, unrebutted information in files. Yet, once filed pursuant to the majority rule, derogatory information becomes a permanent part of an administrator’s file and may not be removed until the individual’s retirement or termination. (58 Ops.Cal.Atty.Gen. 422, 424 (1975).) It thus encourages the career-long accumulation of all derogatory information written at any time about an individual. The purposelessness of this requirement is apparent, given the rarity with which such information actually will be used and the statutory restriction against using information relating to a matter more than four years old in a termination proceeding. (Ed. Code, § 44944, subd. (a).)
I would conclude that section 44031 does not require the inclusion of any material in the personnel file but provides only for rebuttal of material placed in the file.
II
The majority’s construction of section 44031 in reality tends to convert it into a rule of evidence. Section 44031 merely provides for rebuttal of information in personnel files. However, providing that a demotion is invalidated by consideration of unanswered nonfile material — such as the instant internal memoranda — establishes an evidentiary requirement.
Such requirement is at odds with the long established rule that a school board possesses absolute discretion to return administrators to teaching positions for reasons the board deems sufficient. (Board of Education v. Swan (1953) 41 Cal.2d 546, 555-556 [261 P.2d 261]; Grant v. Adams (1977) 69 Cal.App.3d 127, 132, 137-138 [137 Cal.Rptr. 834]; Anaclerio v. Skinner (1976) 64 Cal.App.3d 194, 197 [134 Cal.Rptr. 303]; Barton v. Governing Board (1976) 60 Cal.App.3d 476, 479 [131 Cal.Rptr. 455]; Hentschke v. Sink (1973) 34 Cal.App.3d 19, 22-23 [109 Cal.Rptr. 549]; Note, Due Process for Public School Administrators? (1978) 9 Pacific L.J. 921, 933, 939; Reutter & Hamilton, The Law of Public Education (2d ed. 1976) at *721p. 424; 78 C.J.S., Schools and School Districts, § 205, p. 1101; see Barthuli v. Board of Trustees (1977) 19 Cal.3d 717, 721 [139 Cal.Rptr. 627, 566 P.2d 261], cert. den., 434 U.S. 1040 [54 L.Ed.2d 790, 98 S.Ct. 21]; Thompson v. Modesto City High School Dist. (1977) 19 Cal.3d 620, 624 [139 Cal.Rptr. 603, 566 P.2d 237]; Bogacki v. Board of Supervisors (1971) 5 Cal.3d 771, 781-783 [97 Cal.Rptr. 657, 489 P.2d 537]; Holbrook v. Board of Education (1951) 37 Cal.2d 316, 334 [231 P.2d 853]; Griffin v. Los Angeles etc. Sch. Dist. (1942) 53 Cal.App.2d 350, 352 [127 P.2d 939]; Piele, The Yearbook of School Law 1978 at pp. 77-79.) Only proper notice and, if requested, a statement of reasons are required. (Ed. Code, § 44896; Barton v. Governing Board, supra, 60 Cal.App.3d at p. 479.)
The reasons supporting this principle were stated in Hentschke v. Sink, supra, 34 Cal.App.3d 19: “[A] second or third level administrator bears to his superiors a relationship of the most intimate nature, requiring complete trust by the top administrators in the judgment and cooperative nature of the subordinate. The loss of that trust is not a matter susceptible of proof such as is involved in the cases where a classroom teacher is dismissed or demoted for objective acts of misconduct. To introduce into the administrative structure the elements of discharge for ‘cause’ and of formal hearing would be to make effective school administration impossible. The statutes do not require that.” (34 Cal.App.3d at p. 23.)
Even as established, there is a patchwork quality to the requirement of rebuttal of derogatory information about an administrator. It appears to affect demotion decisions based upon written reports to school boards, but not those based on oral recommendations or those initiated by board members themselves on the basis of their own knowledge.
Most important in this connection are the three exceptions in the statute. Section 44031 prohibits inspection or rebuttal of “ratings, reports, or records which (1) were obtained prior to the employment of the person involved, (2) were prepared by identifiable examination committee members, or (3) were obtained in connection with a promotional examination.” Those materials are obviously crucial to promotion, demotion, or other employment determinations, and it would be unreasonable to conclude that because the employee may not rebut them, the board may not consider them. These provisions show that the inspection and rebuttal right is not a limitation upon the matters available for board consideration.
*722III
Even assuming arguendo the instant school board partially based its demotion decision on procedurally deficient information, the majority’s use of a “but for” standard of review4 is unsupported. Such a standard is appropriate in only two instances — where cause must be shown to support a personnel decision, or where the decision allegedly was based on the employee’s exercise of a constitutional right. (See Bogacki v. Board of Supervisors (1971) 5 Cal.3d 771, 782-783 [97 Cal.Rptr. 657, 489 P.2d 537].) The majority opinion bears this out, relying solely upon such cases to support its “but for” standard. (Ante, p. 715, citing Bekiaris v. Board of Education (1972) 6 Cal.3d 575 [100 Cal.Rptr. 16, 493 P.2d 480] (infringement of constitutional rights alleged); Bonham v. McConnell, supra, 45 Cal.2d 304 (requirement of cause); Mt. Healthy City Board of Ed. v. Doyle, supra, 429 U.S. 274 (infringement of constitutional rights alleged); Byrd v. Savage, supra, 219 Cal.App.2d 396 (requirement of cause).)
The present case, however, involves neither a required showing of cause (see Board of Education v. Swan, supra, 41 Cal.2d 546, 555-556, and other authorities cited supra) nor any allegation the demotion was retaliation for plaintiff’s exercise of a constitutional right. Instead, the correct standard of review is that applied where an employee serves in a position at the pleasure of the employer.
The standard was stated in Bogacki v. Board of Supervisors, supra, 5 Cal.3d 771, 783: “A public employee serving at the pleasure of the appointing authority ... is by the terms of his employment subject to removal without judicially cognizable good cause. . . . ‘Considerations of comity and administrative efficiency counsel the courts to refrain from any attempt to substitute their own judgment for that of the responsible officials.’ [Citation.] Only when such a public employee can show that his employment has been unjustifiably conditioned on the waiver of his constitutional rights will the courts intervene and give relief.” (5 Cal.3d at p. 783; see Rosenfield v. Malcolm (1967) 65 Cal.2d 559, 562-563 [55 Cal.Rptr. 505, 421 P.2d 697]; Abel v. Cory (1977) 71 Cal.App.3d 589, 595 [139 Cal.Rptr. 555].)
*723Bogacki is particularly relevant. In that case, all the reasons cited by the employer for removing plaintiff were found to be erroneous. The reasons thus were disregarded by the court. We held that because plaintiff served at the pleasure of the employing authority — similar to the instant plaintiff’s administrative assignment — the fact that the resulting record failed to establish a specific cause for dismissal did not invalidate the dismissal. “This would be tantamount to saying that a public agency cannot employ persons subject to removal at its pleasure, for if judicially cognizable good cause is requisite to removal in all cases there can be no wholly subjective power of removal in the agency. [¶] Such is not the law in California, nor has it ever been.” (Bogacki v. Board of Supervisors, supra, 5 Cal.3d at pp. 782-783 (fn. omitted).)
In the present case, of course, the board of education was not required to consider or prove judicially cognizable cause to demote plaintiff. The majority nevertheless hold the matter must be remanded because the board voluntarily considered both valid causes5 and others that are procedurally deficient for lack of rebuttal opportunity. The defect in this procedure, the majority assert, is that, given the opportunity, plaintiff may be able to successfully counter the unrebutted reasons.
However, even assuming that was done and those reasons were shown to be nonexistent and were disregarded, the additional concededly valid reasons still remain to support the school board’s decision. We must remember this is not a case of alleged retaliation for exercise of a constitutional privilege but, even under the majority rule, only one in *724which some of the board’s reasons may be invalid. To concede everything plaintiff alleges is to grant only that he could successfully counter the unrebutted reasons. Those reasons having been rebutted, however, valid cause concededly still exists in the record supporting the board, even though no cause at all need be shown. Such basis of support for the decision far exceeds that found adequate in Bogacki.6
For excellent reason, communities and their school boards are granted great discretion in selecting those who lead their schools. It is unwise to erect procedural barriers to the exercise of that discretion, particularly where, as here, an administrator has been afforded ample notice of deficiencies, counseling, and remediation. To do so, I believe, is to elevate procedure above the welfare of pupils.
I would affirm the judgment.
Section 44031 provides: “Materials in personnel files of employees which may serve as a basis for affecting the status of their employment are to be made available for the inspection of the person involved. [¶] Such material is not to include ratings, reports or records which (1) were obtained prior to the employment of the person involved, (2) were prepared by identifiable examination committee members, or (3) were obtained in connection with a promotional examination. [¶] Every employee shall have the right to inspect such materials upon request, provided that the request is made at a time when, such person is not actually required to render services to the employing district. [¶] Information of a derogatory nature, except material mentioned in the second paragraph of this section, shall not be entered or filed unless and until the employee is given notice and an opportunity to review and comment thereon. An employee shall have the right to enter, and have attached to any such derogatory statement, his own comments thereon. Such review shall take place during normal business hours, and the employee shall be released from duty for this purpose without salary reduction.”
“Unless the school district notifies the employee of such derogatory material within a reasonable time of ascertaining the material, so that the employee may gather pertinent information in his defense, the district may not fairly rely on the material in reaching any decision affecting the employee’s employment status.” (Ante, p. 713, fn. omitted.)
At the time the information must be put in the file the superintendent and the administrators do not know whether it will become relevant at some later date. Because of this and because the district board is entitled to all available information in determining whether to order- transfer, all potentially relevant information must be included in the dossier. The breadth of the paperwork explosion is apparent.
“As we have explained heretofore in other contexts, however, the correct inquiry focuses not merely on whether the school board considered the Cloud memoranda in deciding to reassign plaintiff, but on whether but for the memoranda the board would not have reassigned him. (See Bekiaris v. Board of Education (1972) 6 Cal.3d 575, 592-594 [100 Cal.Rptr. 16, 493 P.2d 480]; Bonham v. McConnell (1955) 45 Cal.2d 304 [288 P.2d 502]; see also Mt. Healthy City Board of Ed. v. Doyle (1977) 429 U.S. 274, 283-287 [50 L.Ed.2d 471, 481-484, 97 S.Ct. 568]; Byrd v. Savage (1963) 219 Cal.App.2d 396 [32 Cal.Rptr. 881].)” (Ante, p. 715.)
In notifying plaintiff of his demotion, the school board provided a list of 14 reasons and attached supporting documentation consisting of a memorandum written by Associate Superintendent Don A. Cloud. The Cloud memorandum listed 30 separate items relating to plaintiff’s performance, including reports, evaluations, and memoranda. Plaintiff contends the board erred by considering items 11 to 30 attached to the Cloud memorandum because plaintiff had not provided rebuttal to them. Items 1 to 10, however, appear to be conceded as procedurally valid, and their usé is not challenged. Those items include such causes as plaintiff’s inadequate implementation of suggestions for providing reading and math labs, using criterion-referenced tests, reducing certain pupil-teacher ratios, and delineating job responsibilities of staff members (item 1); a need for better communication with his subordinates (item 2); a need to give subordinates more time to contribute suggestions, excessive attention to minor classroom physical details rather than teaching effectiveness, a need to support staff in correcting student behavior problems, a need for greater involvement with students and student groups (item 3); a need to direct improvements in his school’s curriculum, a need to convince educators and the community of the effectiveness of his school’s student discipline, a need to be more sensitive to the needs of parents and staff, devoting too much time to conferences outside the school district, relying too much on his staff for decision making (item 5), and a lack of a well-defined school curriculum design, particularly in basic subject areas (item 7).
The “but for” test applied here would be inappropriate even in the case of an employing authority whose decisions must be supported by evidence. Where such an authority’s supporting reasons are found to be partially invalid, the proper remedy is to remand to the employing authority for reconsideration of its decision. (Shepherd v. State Personnel Board (1957) 48 Cal.2d 41, 51 [307 P.2d 4]; Bonham v. McConnell, supra, 45 Cal.2d 304, 306; Wingfield v. Fielder (1972) 29 Cal.App.3d 209, 223 [105 Cal.Rptr. 619]; Doyle v. Board of Barber Examiners (1966) 244 Cal.App.2d 521, 526 [53 Cal.Rptr. 420]; 2 Cal.Jur.3d, Administrative Law, § 301, at p. 574.)