Carson City School District v. Burnsen

Gunderson, J.,

dissenting:

The district court determined that the requirements of NRS 391.313 had not been met in admonitions made to Burnsen before her discharge. NRS 391.313(1) provides that when an admonition is made for a reason which may lead to dismissal, or cause the employee not to be reemployed, the matter shall be brought to the employee’s attention, in writing, and a reasonable time for improvement given. Although recommendations for improvement had been given to Burnsen, it had not been suggested to her that such admonitions could lead to non-reemployment. The letter of February 3, 1978, was the first such indication Burnsen received. On February 7, she was informed that she would not be recommended for reemployment.

We have previously held that the statutory admonitions must be “given the teacher to enable him to remedy the cause for potential dismissal.” Board of Sch. Trustees v. Rathbun, 92 Nev. 651, 652, 556 P.2d 548 (1976). It follows that the admonitions should be given in such a fashion that the teacher knows that dismissal or non-reemployment may result.

As a result of appellant’s lack of compliance with the statutory requirements, all proceedings subsequent to the invalid letter of non-reemployment were prematurely taken, see Fresno City High School Dist. v. DeCaristo, 92 P.2d 668 (Cal.App. 1939), and the statutory ten-day limitation period for requesting a hearing was never invoked, see Thayer v. Anacortes School District, 504 P.2d 1130 (Wash. 1972). Because Burn-sen’s resignation clearly resulted from the invalid letter of non-reemployment, it should not stand. Cf. Fresno City High School Dist. v. DeCaristo, supra.

The district court’s granting of the petition for a writ of mandamus should be affirmed.