Cook v. Bennett

The state legislature in Florida enacted performance-evaluation requirements for public-school teachers in a statute called the Student Success Act. The act mandated that Florida’s commissioner of education approve a formula using the annual Florida Comprehensive Assessment Test (FCAT) to measure individual student-learning growth. The commissioner created the FCAT value-added model (FCAT VAM), which took variables into account to predict student-learning growth. The FCAT VAM measured the effect on students of an individual teacher and the effect on students of other factors related to the school environment in order to generate a teacher’s final evaluation score. Public schools had to adopt the FCAT VAM to evaluate teachers according to the requirements of the act. Public-school teachers in Florida (plaintiffs) filed an action in the district court against the Florida State Board of Education and three school districts (school administrators) (defendants). The teachers claimed that the act and its implementation by the school administrators violated the teachers’ due-process and equal-protection rights under the Fourteenth Amendment to the United States Constitution. The teachers argued that the act’s policies arbitrarily and illogically evaluated teachers based on irrelevant test scores and did not pass rational-basis review. The school administrators contended that the act’s policies were rationally related to a legitimate government interest in increasing student academic performance. The district court held that the act’s performance-evaluation policies did not violate the teachers’ due-process or equal-protection rights. The teachers appealed.