Harrah Independent School District v. Martin

440 U.S. 194, 99 S. Ct. 1062, 59 L.Ed.2d 248 (1979)

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Harrah Independent School District v. Martin

United States Supreme Court
440 U.S. 194, 99 S. Ct. 1062, 59 L.Ed.2d 248 (1979)

EL

Facts

Mary Jane Martin (plaintiff), a tenured teacher, refused to comply with the continuing-education requirements of her school district (defendant). For the first five years of Martin’s career, the district only penalized a teacher’s failure to comply with continuing-education requirements by eliminating yearly pay raises. After Martin had taught for five years, however, the Oklahoma legislature enacted mandatory pay raises for teachers, eliminating the district’s former penalty for teachers who refused to take continuing-education classes. The district pivoted and started a new policy of refusing to renew the teaching contracts of teachers who did not take continuing-education classes. Following its new policy, the district terminated Martin. Martin sued her school district in federal district court, claiming the district’s new policy violated the Fourteenth Amendment’s Equal Protection Clause because instead of treating teachers equally, it classified noncomplying teachers as members of a different class from teachers who complied with continuing-education requirements. The school district argued that the continuing-education requirements reflected a legitimate government concern of ensuring the educational qualifications of its teachers. The federal district court found in favor of the district and dismissed the case. Martin appealed to the United States Court of Appeals for the Tenth Circuit, which reversed the district court’s decision and ruled in favor of Martin. The school district petitioned the United States Supreme Court for a writ of certiorari to review the case.

Rule of Law

Issue

Holding and Reasoning (Per curiam)

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