Whaley v. Anoka-Hennepin Independent School District No. 11

Gerald Whaley (plaintiff) taught and served as a principal in the Anoka-Hennepin School District (defendant) for over 19 years. Whaley spent the last three years as a reading teacher for grades four, five, and six. In May 1980, the school board sent Whaley a notice of deficiency pursuant to a Minnesota statute. The notice alleged that Whaley was deficient in several areas of teaching, including poor rapport with students, lack of student progress, and failure to follow the school board’s reading program. Whaley was advised that failure to improve on these deficiencies would result in termination. After a four-month evaluation window, Whaley was given a notice of proposed termination. Whaley requested a hearing to determine whether his termination was warranted. After considering evidence presented at the hearing, the school board terminated Whaley’s contract, concluding that he was inefficient, neglected his duties, failed to follow duties, and was unfit to perform them. The school board relied on 44 findings of fact in its decision. Among these findings were that Whaley relied excessively on worksheets and that his students progressed at a slower rate than those of his colleagues. These findings were based on reviews and interviews. Whaley filed suit, and an order of a Hennepin County district court judge set aside the school board’s termination of the contract, finding that the evidence did not rise to the necessary level to show Whaley was unfit to teach under Minnesota law. The school district appealed.