Angela Davis, as President of Nea-Dallas (A Local Affiliate of Texas State Teachers Association), on Behalf of All Affected Members and Named Individuals v. Mike Morath, Commissioner of Education of the State of Texas, and Dallas Independent School District, a Public Body Corporate

CourtTexas Supreme Court
DecidedMay 28, 2021
Docket19-1035
StatusPublished

This text of Angela Davis, as President of Nea-Dallas (A Local Affiliate of Texas State Teachers Association), on Behalf of All Affected Members and Named Individuals v. Mike Morath, Commissioner of Education of the State of Texas, and Dallas Independent School District, a Public Body Corporate (Angela Davis, as President of Nea-Dallas (A Local Affiliate of Texas State Teachers Association), on Behalf of All Affected Members and Named Individuals v. Mike Morath, Commissioner of Education of the State of Texas, and Dallas Independent School District, a Public Body Corporate) is published on Counsel Stack Legal Research, covering Texas Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Angela Davis, as President of Nea-Dallas (A Local Affiliate of Texas State Teachers Association), on Behalf of All Affected Members and Named Individuals v. Mike Morath, Commissioner of Education of the State of Texas, and Dallas Independent School District, a Public Body Corporate, (Tex. 2021).

Opinion

IN THE SUPREME COURT OF TEXAS ══════════ No. 19-1035 ══════════

ANGELA DAVIS, AS PRESIDENT OF NEA-DALLAS (A LOCAL AFFILIATE OF TEXAS STATE TEACHERS ASSOCIATION), ON BEHALF OF ALL AFFECTED MEMBERS AND NAMED INDIVIDUALS, PETITIONERS, v.

MIKE MORATH, COMMISSIONER OF EDUCATION OF THE STATE OF TEXAS, AND DALLAS INDEPENDENT SCHOOL DISTRICT, A PUBLIC BODY CORPORATE, RESPONDENTS ══════════════════════════════════════════ ON PETITION FOR REVIEW FROM THE COURT OF APPEALS FOR THE THIRD DISTRICT OF TEXAS ══════════════════════════════════════════

Argued March 23, 2021

JUSTICE BLACKLOCK delivered the opinion of the Court.

A group of teachers (Teachers) at Dallas Independent School District objected to DISD’s

method of evaluating teacher performance. Pursuing a procedural pathway provided by the

Education Code, the Teachers brought their grievances first to the school board, then to the

Commissioner of Education, and finally to the courts. DISD denied the grievances as untimely.

The Commissioner dismissed the grievances, concluding that their untimely presentation to the

local school board deprived him of jurisdiction. The Teachers appealed to district court, which

affirmed the Commissioner’s decision. The court of appeals held that the Commissioner had

jurisdiction over the grievances. It further held that some of the grievances were untimely and must be dismissed but that others were timely and could proceed. The Teachers, the school district,

and the Commissioner all filed petitions for review.

We agree with the court of appeals that the Commissioner had jurisdiction to hear the

Teachers’ appeal. We further hold that the grievances were timely filed with the school district.

We do not resolve the parties’ disputes about the legality of DISD’s teacher evaluation system.

We also affirm the court of appeals’ disposition of the Teachers’ contractual complaints regarding

their compensation. The decision of the court of appeals is affirmed in part and reversed in part,

and the matter is remanded to the Commissioner.

I. Background

A. Factual Background

State law requires school districts to evaluate teachers using a procedure adopted by the

Commissioner of Education or one developed by the district. TEX. EDUC. CODE § 21.352.

Beginning in 2011, Dallas Independent School District developed its own evaluation procedure,

called the “Teacher Excellence Initiative” (TEI). The District’s briefing makes clear that it

considers TEI a great success. The Teachers disagree. Our decision today is purely procedural

and takes no position on that question.

On May 22, 2014, the District’s Board of Trustees voted to adopt TEI beginning with the

2014–15 school year. The District asserts that all teachers were informed about the new system.

For example, the District published a “Guidebook” in May 2014, which it updated in March 2015.

The Guidebook explained TEI and informed teachers that their annual final evaluations for the

2014–15 year, called scorecards, would be sent in the fall of 2015. Teachers were given a day and

a half of training on TEI in August 2014. The parties dispute whether any of these events and

2 documents adequately informed the teachers that, under TEI, they would not receive their

scorecards until after the school year ended. Some teachers took the view that the timing of the

scorecards violated section 21.352(c) of the Education Code, which they believe required the

District to evaluate them before the school year ends.

The scorecards affected teacher pay. Each scorecard rated teachers based on three

categories: classroom performance, student achievement, and student perception.1 The student

achievement component is based in part on students’ standardized test scores, including the

statewide STAAR test. According to the Commissioner, STAAR results were not available until

after the school year ended, which meant the scorecards would not be prepared until then. The

Teachers contend that standardized test scores were not necessarily unavailable during the school

year in which they were administered. DISD asserts that some standardized test results “are

inherently unavailable when the school year ends and only arrive for District processing over the

summer.” In September 2014, the District issued a regulation providing further details about the

TEI process. The regulation again stated that the scorecards for the 2014–15 school year would

be provided to teachers in the fall of 2015. On September 18, 2015, in conformity with the

regulation and a published calendar, teachers received their scorecards for the 2014–15 school

year.

1 The parties agree that teacher compensation under TEI was based on each teacher’s “Effectiveness Level” determined by the three categories rated in the scorecards. As discussed below, the Teachers also made a separate compensation-related complaint, in which they alleged that the District impermissibly decreased their total compensation by increasing their health insurance premiums. See infra at ___.

3 B. Procedural Background

Some DISD teachers were unhappy with TEI and with their scorecards. Others were not.

Under DISD’s procedures, a grievance must be filed “no later than ten [business] days from the

date the employee first knew or, with reasonable diligence, should have known of the decision or

action giving rise to the grievance or complaint.” The scorecards were distributed on September

18, 2015, and a grievance was filed ten business days later, on October 2.

The grievance was filed by Angela Davis, president of NEA-Dallas, a local affiliate of the

Texas State Teachers Association, on behalf of all its affected members. The grievance document

itself did not allege any complaints specific to a particular teacher, although Davis later submitted

briefing alleging individualized complaints. The grievance alleged that the distribution of the

scorecards on September 18, 2015 was the event “giving rise to the grievance” for timeliness

purposes. It further complained that each scorecard violated state law by, among other things,

failing to give teachers a final evaluation during the appraisal school year as allegedly required by

section 21.352(c) of the Education Code. On October 14, 2015, Davis filed an amended grievance

on behalf of all affected members and on behalf of 92 Teachers identified by name in an exhibit.

The amended grievance added an allegation that the scorecards’ effect on teacher pay was “a

breach of each Grievant’s contract of employment and/or demotion without due process of law.”

Under District rules, the grievance was first considered by a grievance hearing officer. The

officer denied the grievance but granted the Teachers’ request that they “will not suffer any reprisal

or retaliation for filing this grievance.” The hearing officer otherwise denied the grievance as

untimely under the District’s ten-day rule. The officer’s decision reasoned that the Teachers were

aware of the TEI process from the time it was adopted in May 2014. The officer concluded that

4 because the Teachers failed to file their grievance within ten business days of the date they allege

their evaluations were due under state law, their grievance was untimely. Alternatively, the officer

concluded that the Teachers had not established that TEI violated the law. The Teachers appealed

the hearing officer’s decision to the DISD Board of Trustees.

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Angela Davis, as President of Nea-Dallas (A Local Affiliate of Texas State Teachers Association), on Behalf of All Affected Members and Named Individuals v. Mike Morath, Commissioner of Education of the State of Texas, and Dallas Independent School District, a Public Body Corporate, Counsel Stack Legal Research, https://law.counselstack.com/opinion/angela-davis-as-president-of-nea-dallas-a-local-affiliate-of-texas-state-tex-2021.