Martinek v. Belmond-Klemme Community School District

772 N.W.2d 758 (2009)

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Martinek v. Belmond-Klemme Community School District

Iowa Supreme Court
772 N.W.2d 758 (2009)

EL

Facts

A school district (defendant) terminated the employment of Cynthia Martinek (plaintiff), its elementary school principal, citing declining enrollment, budgetary restrictions, and a reduction in force. District enrollment had been declining for over a decade, resulting in a loss of over 25 percent of students. The district lost over $5,000 in state funding per student, equating to a loss of approximately $1 million in yearly income. The district had also reduced its teaching staff from 70 to 55 teachers. The district determined that the best way for it to reduce administrative staff was to eliminate Martinek’s job and to divide her role between two part-time administrators who were already on staff. After the district terminated Martinek, it hired an additional administrator to serve as the high school principal at a salary higher than Martinek’s. The school district hired the new principal as part of its longer-term plan to gradually reduce administrators, including the planned retirement of one administrator at the end of the school year. Martinek requested an administrative hearing to contest her termination. At the hearing, an administrative-law judge found the district had shown by a preponderance of the evidence that it had just cause to terminate Martinek. Martinek appealed the decision to the school district’s board of directors, which affirmed. Martinek then appealed the termination decision in state court. The lower state court affirmed. Martinek appealed to the state supreme court.

Rule of Law

Issue

Holding and Reasoning (Baker, J.)

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