(dissenting).
The majority opinion correctly draws from Iowa cases the fundamental principle that school districts have only those powers that are expressly granted or necessarily implied in Iowa statutes. I dissent because I conclude the result in this case violates that fundamental principle.
The facts are not in dispute. The school district’s superintendent was charged with unprofessional conduct, and a hearing was held before the Iowa Professional Teaching Practices Commission. That commission, pursuant to Iowa Code chapter 272A, had the responsibility to investigate unprofessional practices of certificated school teachers and administrators, and it had the authority to hold a hearing and then “exonerate, warn or reprimand the member of the profession or ... recommend the holding of a certification suspension or revocation hearing by the state board of educational examiners.” Iowa Code § 272A.6 (1983). Faced with the charge of unprofessional conduct, the superintendent employed an attorney who submitted a bill of $6,374.10 for defending him before the commission. The school board was not a party to the proceeding. After the hearing the superintendent was reprimanded for unprofessional conduct. The truly remarkable fact is that the school board then voluntarily paid the superintendent’s $6,374.10 attorney fee.
Petitioners appealed that use of tax dollars by the school board to the Iowa State Board of Public Instruction (BPI). Following a hearing, BPI issued the final agency decision which the district court upheld in this judicial review proceeding. Both BPI and the district court construed Iowa Code section 279.37 (1983) to give the school board authority to pay the superintendent’s legal fees. That statute, which we have not previously construed, provides:
A school corporation may employ an attorney to represent the school corporation as necessary for the proper conduct of the legal affairs of the school corporation.
I disagree with the majority’s acceptance of that construction of this statute.
The BPI’s final agency decision emphasized the “as necessary” language in the statute, stating:
The phrase “as necessary” creates a strong inference of broad discretion on the part of local boards of directors in making decisions to “employ an attorney.”
The BPI did not explain, however, what evidence established that this school board employed this attorney and that the attorney’s services were somehow necessary for the proper conduct of this school board’s legal affairs. This record discloses no such evidence. At risk in the proceeding before *894the Professional Teaching Practices Commission was the personal professional certificate of the superintendent. That was not, in my view, a legal affair of the school corporation.
We must consider all parts of the statute together, without attributing undue importance to any single or isolated portion. Beier Glass Co. v. Brundige, 329 N.W.2d 280, 283 (Iowa 1983). The first portion of this statute, not explained by the BPI in its decision, is plainly contrary to the BPI’s construction. This school board did not employ the attorney whose fee it paid. The superintendent employed the attorney. Additionally, the attorney did not represent the school board, which was not a party in the proceeding. The attorney represented the superintendent and only the superintendent. Section 279.37 did not expressly or by necessary implication give the board the power to pay the fee bill submitted by the attorney who the superintendent employed to represent him.
I have no quarrel with the abstract rules of statutory construction set forth with supporting authorities in the majority opinion. Such rules can be useful, particularly when a statute is ambiguous, as we search for “the manifest intent of the general assembly.” Iowa Code § 4.1 (1983). But this statute is not ambiguous. We need not look to, or defer to, the interpretations of the agency or the attorney general in arriving at the intent of the legislature. The somewhat similar statute in effect pri- or to 1981, relied upon by the attorney general and the majority opinion, is of little value because it specifically referred to actions “instituted by or against any school officer” and the present statute does not. See Iowa Code § 279.37 (1979).
I find nothing reasonable and natural about the construction which the attorney general, the BPI, the district court, and the majority opinion place on this unambiguous statutory provision. Why should the taxpayers in this school district and in the State of Iowa pay attorney fees incurred solely to protect a certificated school administrator or teacher from disciplinary action based on unprofessional conduct? This case, in my view, has produced the kind of strained, impractical and absurd construction we previously have decried. Doe v. Ray, 251 N.W.2d 496, 501 (Iowa 1977).
In Andrew v. Stuart Savings Bank, 204 Iowa 570, 215 N.W. 807 (1927), we declared:
School boards have no powers except such as are conferred by legislative act, either expressly or by necessary implication, and doubtful claims of power are resolved against them.... School funds are in the nature of trust funds, and do not belong to the district or to the offices of the school district, but to the public.
Id. at 573, 215 N.W. at 808-09 (emphasis added). At best, the school board’s claim of statutory authority to pay the superintendent’s attorney is “doubtful” and to be resolved against the board. At worst, the board’s payment amounts to a breach of the public trust.
I would reverse the judicial review decision of the district court and direct the BPI to rule that the school board had no authority to pay the fee bill submitted by the superintendent’s attorney.