Hortonville Joint School District No. 1 v. Hortonville Education Association

Members of a teachers’ union in Hortonville, Wisconsin (plaintiffs) went on strike after negotiations for their collective-bargaining agreement broke down. Wisconsin state law prohibited all public employees, including public school teachers, from striking. During the strike, the district superintendent twice invited the striking teachers to return to school. A few teachers returned, but 86 remained on strike. The Hortonville School Board (board) (defendant) held formal disciplinary hearings against the striking teachers for violating Wisconsin’s antistriking law. An attorney for the teachers asserted that the board was not sufficiently impartial to adjudicate the disciplinary hearings under the Fourteenth Amendment Due Process Clause, which required an independent, unbiased decisionmaker. The teachers argued that because the board was involved in the negotiations that caused the teachers to break the antistriking law, the board could not impartially decide disciplinary actions against them. The board rejected the teachers’ arguments and voted to terminate the striking teachers’ employment. In the notice of termination, the board invited the teachers to reapply for district teaching jobs. One teacher reapplied and was rehired. The remaining teachers and their bargaining agent, the Hortonville Education Association (association) (plaintiff), filed suit against the board and Hortonville Joint School District No. 1 (defendant) in state court. The trial court ruled in favor of the board and rejected the association’s due-process claim. The association appealed to the state supreme court. The Wisconsin Supreme Court found that although the board was within its power to terminate the teachers for breaking the antistriking law, the board’s involvement in the negotiations surrounding the strike disqualified the board members from direct involvement in the disciplinary hearing under the Due Process Clause. The court thus reversed the trial court’s ruling on the due-process claim. The board appealed the decision to the United States Supreme Court.