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Unified School District No. 446, Independence, Kansas v. Sandoval

Kansas Supreme Court
295 Kan. 278 (2012)


Deborah Sandoval (defendant) was a teacher at Unified School District No. 446 (the district) (plaintiff). The principal of the district informed Sandoval that her contract would not be renewed. During a school-board meeting, Sandoval’s union representative verbally negotiated a settlement agreement with the school board. Sandoval told the representative to accept the deal. District policy stated that the board could consider the resignation of an employee that was submitted to the board in writing. The minutes from the school-board meeting did not mention Sandoval’s resignation. After the meeting, the school superintendent emailed the union representative a draft of the settlement agreement. The two exchanged emails regarding modifications to the agreement. Sandoval then informed the union that she had changed her mind and wanted to proceed with a due-process hearing. Sandoval’s union representative informed the superintendent that Sandoval was no longer willing to accept the terms proposed by the school board. The superintendent then sent Sandoval a letter stating that because Sandoval changed her mind about the agreement, the board would proceed with a resolution to non-renew Sandoval’s contract. The board then adopted a resolution of non-renewal of Sandoval’s contract, including a clause reserving the right to enforce the oral agreement arrived at during the school-board meeting. The district filed a petition seeking a declaratory judgment that Sandoval had entered into an oral contract governing the terms of her separation from the district. Sandoval argued that all of the communications about the terms of her resignation were merely preliminary negotiations. The trial court agreed with the district, holding that Sandoval had entered into a binding oral contract and thus had waived her statutory due process hearing. The appeals court affirmed the decision. Sandoval then appealed to the state supreme court.

Rule of Law


Holding and Reasoning (Rosen, J.)

Concurrence (Luckert, J.)

Dissent (Nuss, C.J.)

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