Baxter v. Crosby

A public-school teacher, Leona Baxter (plaintiff) attained the status of a career teacher under a North Carolina statute. The school principal asked Baxter to stop striking the orthopedically handicapped children in her classroom as a form of punishment. Baxter continued to strike the students in front of witnesses. The superintendent of the Charlotte-Mecklenburg Board of Education (school board) (defendant) sent a notice to Baxter, advising her of a recommendation made to the school board to dismiss her at the close of the school year. The grounds for the superintendent’s recommendation made clear in the notice included Baxter’s inadequate performance, insubordination, neglect of duty, and failure to comply with school-board requirements. Baxter requested review of the superintendent’s recommendation by a Professional Review Committee panel, which conducted a hearing and issued a majority report recommending reinstatement with back pay as well as a minority report recommending dismissal. In spite of the panel’s majority report, the superintendent submitted a second recommendation to the school board that Baxter be dismissed. The school board’s chairperson sent Baxter notice that she was entitled to a hearing. The school board held the hearing, heard hearsay evidence to investigate the claims, and unanimously voted to terminate Baxter for the reasons stated in the original notice. Baxter filed an action in the state court to appeal the school board’s decision and alleged that the school board violated her constitutional due-process rights during its administrative proceedings. The trial court affirmed the school board’s order. Baxter appealed.