Russell v. Watson Chapel School District

313 S.W.3d 1 (2009)

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Russell v. Watson Chapel School District

Arkansas Supreme Court
313 S.W.3d 1 (2009)

EL

Facts

The Watson Chapel School District (the district) (defendant) examined potential deficiencies of teacher Bernice Russell (plaintiff) during a school-board hearing. The district elected to not renew Russell’s contract and issued a notice of nonrenewal of the contract, which contained reasons for Russell’s termination. The district provided specific reasons for the nonrenewal in numbered-paragraph form in its notice of nonrenewal of the contract. The district school board also fleshed out the reasons for dismissing Russell in the school-board hearing at which Russell’s termination was discussed. At Russell’s request for further reasons for her dismissal, the district provided those reasons to Russell. Russell sued the district in state trial court alleging that the district provided insufficient notice under the Teacher Fair Dismissal Act (TFDA) for the nonrenewal of her teaching contract. The state trial court found in favor of Russell, awarding her over $77,000 in contract damages. The district appealed to the Arkansas Supreme Court, arguing that its notice of nonrenewal substantially complied with the TFDA. The Arkansas Supreme Court reversed and remanded, ordering the trial court to examine the transcript of the school-board hearing that resulted in the teacher’s nonrenewal. On remand, the trial court examined the reasons for nonrenewal in the school-board transcript and found the transcript evidenced notice sufficient to give Russell concrete reasons for her contract nonrenewal. Russell appealed the dismissal of her claims to the Arkansas Supreme Court.

Rule of Law

Issue

Holding and Reasoning (Danielson, J.)

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