Barton v. Independent School District No. I-99 of Custer County, Oklahoma

914 P.2d 1041 (1996)

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Barton v. Independent School District No. I-99 of Custer County, Oklahoma

Oklahoma Supreme Court
914 P.2d 1041 (1996)

  • Written by Alexander Hager-DeMyer, JD

Facts

Jim Barton (plaintiff) was a teacher in Oklahoma and certified to teach general industrial arts, wood and metal technology, zoology, biology, and driver/safety education in public schools. The Independent School District No. I-99 of Custer County (school district) (defendant) hired Barton to teach driver’s education in the school district. After 19 years of teaching, Barton was notified that the school district was eliminating the driver’s-education program and not renewing his contract due to a reduction-in-force (RIF) plan to improve the district budget. However, through renewals and hiring, the school district employed eight more certified teachers than in the year prior to Barton’s layoff. The school district’s RIF policy was created through collective bargaining. The policy provided that if a RIF plan was implemented and teaching positions needed to be eliminated, the positions would be the determining factor rather than the tenure status of teachers in those positions. If a position was eliminated, career teachers employed for three or more years with the school district would be the last to be released. Barton filed suit in an Oklahoma trial court, claiming that the school district violated his employment contract when it failed to renew his contract. The trial court granted summary judgment to the school district, and the Oklahoma Court of Appeals affirmed on appeal. Barton appealed to the Oklahoma Supreme Court.

Rule of Law

Issue

Holding and Reasoning (Per curiam)

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