Leola School District v. McMahan

Steele Hays, Justice,

dissenting. By this opinion the court has, I believe, assumed the role of deciding whether a teacher’s contract should or should not have been renewed. However, that responsibility under the law belongs neither to this court nor to the circuit court, but to the Leola School District. Kirtly v. Dardanelle Public Schools, 288 Ark. 86, 702 S.W.2d 25 (1986).

In White v. Jenkins, 213 Ark. 119, 209 S.W.2d 457 (1948), we said:

It is well settled that courts may not intervene to control matters in the discretion of administrative bodies such as school boards, in the absence of a showing of an abuse of such discretion. Necessarily, some latitude in the exercise of this discretion must be given to these boards. They represent the people of the locality affected and naturally are closer to the problems to be solved than any court or other agency could be.

And in Safferstone v. Tucker, 235 Ark. 70, 357 S.W.2d 3 (1962):

The law involved appears to be well settled. In this State a broad discretion is vested in the board of directors of each school district in the matter of directing the operation of the schools and a chancery court has no power to interfere with such boards in the exercise of that discretion unless there is a clear abuse of it and the burden is upon those charging such an abuse to prove it by clear and convincing evidence.

The Teacher Fair Dismissal Act (Ark. Stat. Ann. § 80-1264 et seq., Repl. 1980)1 provides that a teaching contract may be nonrenewed for any reason, so long as it is not arbitrary, capricious or discriminatory. By including the word “any” the legislature emphasized its intention not to invade the “broad discretion” of school boards in deciding which teachers should be retained, except where the nonrenewal is arbitrary, capricious or discriminatory. Ark. Stat. Ann. § 80-1264.9(b) reads in part:

Any certified teacher. . . may be terminated or the board may refuse to renew the contract of such teacher for any cause which is not arbitrary, capricious, or discriminatory . . . (My italics).

We have interpreted that provision to mean the board’s action will not be reversed if “any rational basis” exists for nonrenewal, Lamar School District No. 39 v. Kindy, 278 Ark. 11, 642 S.W.2d 885 (1982), and the board’s discretion was not abused. “Since this determination not to renew the appellant’s contract was a matter within the discretion of the school board, the reviewing court could not substitute its opinion for that of the Board in the absence of an abuse of discretion by the Board.” Chapman v. Hamburg Public Schools, 274 Ark. 391, 625 S.W.2d 477 (1981).

There is substantial evidence in this record for Mrs. McMahan’s nonrenewal by the Leola School Board. Mrs. McMahan’s performance over a period of time was shown to be deficient in her relations with some parents and children. Her classes (first and second grade pupils) were divided into fast learners and slow learners, that the slow learners were ridiculed by the other students. One parent, on receiving her child’s report card, was told by Mrs. McMahan, “The next one will be worse.” There was evidence that some children were afraid of her, that she yelled at them, that she harassed and picked on some. Much of the proof centered on one pupil, Chad Williams, whose difficulties with Mrs. McMahan were the cause, at least as his parents saw it, of nervousness, bed-wetting and vomiting. On several occasions he wet his pants in the schoolroom, once after a request to go to the restroom had been refused. He was made to wipe up the floor in front of the other children. Mrs. Williams said that Mrs. McMahan’s reaction to her concerns on her son’s behalf was to refuse to speak to her when they met in public. There was other proof of a similar vein, including testimony that Mrs. McMahan questioned children indiscreetly about “problems at home.”

It must be said in fairness there was much offsetting proof, there were parents who praised Mrs. McMahan, and Mrs. McMahan offered a number of letters from devoted children. But those conflicts were for the school board to weigh and resolve. Once particularly unfavorable incident is virtually undisputed and would provide in and of itself a basis for nonrenewal. Mr. Pharr and Mrs. Williams described the event: Mrs. McMahan was unwilling to meet with Mrs. Williams without a witness present. She chose Mrs. Dennis, another teacher. When Mrs. Dennis interjected her own opinions concerning Chad, the three women consulted Mr. Pharr, the superintendent. His attempts to mediate were frustrated by what he described as insubordinate conduct by Mrs. McMahan to the extent that the meeting was disrupted. Finally, he asked Mrs. Williams and Mrs. McMahan to step outside while he spoke with Mrs. Dennis. He said after they went out Mrs. Williams came to the door and called him and Mrs. McMahan was lying on the floor outside the conference room “hollering and screaming.” He said the incident disturbed other classes.

Mrs. Williams’ description corroborated Mr. Pharr’s. She said when she and Mrs. McMahan stepped outside, Mrs. McMahan listened at the door a few minutes and then lay down on the floor and “began screaming and hollering.” Mrs. McMahan’s explanation was that she had been under stress and had fainted, though how that explains the alleged screaming, is not clear. There was some suggestion that the onset was due to muscle spasms of her back, yet there was testimony that she was back at school that afternoon. Whether this bizarre scene was explainable in terms of a physical or an emotional cause, and to what extent it reflected on Mrs. McMahan’s competence, was for the school board to decide.

The circuit judge virtually ignored the foregoing evidence, and looked instead to matters that were collateral to the issue of whether there was “any cause” to nonrenew Mrs. McMahan’s contract. The fact that Mr. Pharr may have been ambivalent is entirely beside the point, as it is the school board’s responsibility to decide on renewal. Nor is the fact that the school board would not hear Mrs. McMahan’s supporters at the May 6 meeting of any relevance. The open meeting was held on May 18 and Mrs. McMahan was permitted to offer whatever she chose at the meeting. The board was not required to hold two open meetings on the issue. Lastly, the finding that 1976 charges were the basis for the current nonrenewal was clearly erroneous. Certainly the board had the right to discuss earlier problems. Had the board relied on outdated charges alone, such a finding would be appropriate, but the fact is there was ample evidence of recent origin to sustain the board’s action.

I believe we should adhere to our many cases that say the courts will not invade the province of the school board in the exercise of its authority. Chapman v. Hamburg Public Schools, supra.

Hickman, J., joins in this dissent.

These proceedings occurred prior to the effective date of the Teacher Fair Dismissal Act of 1983.