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

CourtCourt of Appeals of Texas
DecidedOctober 17, 2019
Docket03-18-00377-CV
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 Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
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. Ct. App. 2019).

Opinion

TEXAS COURT OF APPEALS, THIRD DISTRICT, AT AUSTIN

NO. 03-18-00377-CV

Angela Davis, as President of NEA-Dallas (a Local Affiliate of Texas State Teachers Association), on behalf of All Affected Members and Named Individuals, Appellant

v.

Mike Morath, Commissioner of Education of The State of Texas, and Dallas Independent School District, A Public Body Corporate, Appellees

FROM THE 345TH DISTRICT COURT OF TRAVIS COUNTY NO. D-1-GN-17-002145, THE HONORABLE AMY CLARK MEACHUM, JUDGE PRESIDING

OPINION

This is an appeal from a judgment in a suit for judicial review of an administrative

decision by the Texas Commissioner of Education. Appellants are teachers employed with the

Dallas Independent School District (DISD) during the 2014-15 and 2015-16 school years. They

filed a collective grievance challenging their appraisals under DISD’s newly adopted teacher-

appraisal system, and the Commissioner dismissed the Teachers’ grievance for lack of

jurisdiction. Angela Davis, the President of NEA-Dallas (a local affiliate of the Texas State

Teachers Association), then filed suit for all affected members and named individuals (Teachers)

against the Texas Commissioner of Education Mike Morath (Commissioner) and DISD. The

district court affirmed the Commissioner’s dismissal, and the Teachers appealed. In three issues, the Teachers contend that the district court erred in affirming the

Commissioner’s decision because: (1) the Commissioner incorrectly determined that the

Teachers’ grievance was untimely; (2) the Commissioner incorrectly refused to consider and rule

on the Teachers’ allegations that DISD violated Texas teacher-appraisal laws when he dismissed

the Teachers’ appraisal grievance as untimely; and (3) the Commissioner incorrectly determined

that decreasing the Teachers’ salary after the start of the school year did not violate Texas law.

For the reasons that follow, we conclude that the district court’s judgment should be affirmed in

part and reversed and remanded in part.

BACKGROUND

The Texas Education Code requires all teachers to be appraised. Tex. Educ. Code

§ 21.352(c). While most Texas school districts use the teacher-appraisal process and criteria

developed by the Commissioner, school districts may develop and use their own. Id.

§ 21.352(a)(2). Any district-developed appraisal process and criteria “must be based on

observable, job-related behavior,” including two components: “(1) teachers’ implementation of

discipline management procedures; and (2) the performance of teachers’ students.” Id. § 21.351.

Here, DISD adopted its own teacher-appraisal system in 2014 called the Teacher

Excellence Initiative (TEI). On September 18, 2015, under its new TEI appraisal process, DISD

issued a “Teacher Evaluation Scorecard” to teachers. The Scorecards issued weighted points to

three evaluation components: (1) Teacher Performance; (2) Student Experience, and (3) Student

Achievement. The Student Achievement component included students’ performance on

standardized tests, such as the State of Texas Assessment of Academic Readiness (STAAR),

2 which was not available until after the 2014-15 school year ended. The record contains a sample

Scorecard:

3 After the students’ standardized test scores were disclosed in the summer, DISD

weighted the scores for each of the three teacher-evaluation components and translated those

weighted scores into a range of points within seven categories of Evaluation Ratings:

Unsatisfactory, Progressing I, Progressing II, Proficient, Proficient II, Proficient III, and

Exemplary. Using a predetermined set of percentages called a “target distribution,” DISD

defines what proportion of scores will be assigned to each category. The target distribution for

Evaluation Ratings is set to designate 3% of teachers as Unsatisfactory, 12% of teachers as

Progressing I, 25% of teachers as Progressing II, 40% of teachers as Proficient I, 12% of teachers

as Proficient II, 6% of teachers as Proficient III, and 2% of teachers as Exemplary. The sum of

points from all three evaluation components is listed on a Scorecard for the first time as a

teacher’s numerical Evaluation Score.

The Scorecards, also for the first time, notified teachers of their designated

Effectiveness Level, which correlated with compensation increases under TEI’s pay-for-

performance model and determined the salary that the teacher would receive for the 2015-16

school year. Effectiveness Levels are designed to provide context for a teacher’s evaluation

scores over a two-year period, but because TEI was newly implemented in 2015, only one year

of information was to be considered for a teacher’s Effectiveness Level in the first Scorecard.

Also during the first year of implementation, certain TEI rules limited the highest Effectiveness

Level category that some teachers could attain. 1

1 For example, teachers with just one year of experience were to be classified as Progressing I, teachers with less than three years’ experience could not be classified as Proficient I, and teachers with three or more years’ experience who did not complete a Distinguished Teacher Review process could not be classified higher than Proficient I. 4 On October 2, 2015, within ten district-business days of receiving their

Scorecards, the Teachers filed a grievance with DISD alleging that “each of the Scorecards

[was]”: unwarranted and unjustified, without factual basis or merit, based upon improper criteria

including unreliable District-promulgated standardized test scores, based on other unreliable

data, violative of each teacher’s right to due process, violative of Texas school laws, detrimental

to the teachers by undermining and impairing their effectiveness, conducted in an improper and

unlawful manner, and arbitrary, capricious, demeaning, and unprofessional. Based on those

stated complaints about the Scorecards, the Teachers further alleged that “the entire TEI

instrument and process as a whole is inequitable, arbitrary, capricious, subjective, and unlawful”

and that the TEI instrument and process have a disparate negative impact on more experienced

teachers and new teachers.

The Teachers also contended specifically that

• under the TEI system, teachers are not given a final evaluation during the appraisal school year; rather, teachers receive this information only after the school year ends;

• calculation of the Student Achievement section of the Scorecard, which is based on a three-matrix formula, is not provided to teachers, thus, they were evaluated on information not provided to them in a timely manner or at all;

• calculation of the Scorecard was influenced by other unknown factors, including formulae that are arbitrary and capricious; and

• the resulting effect on each Grievant’s compensation constitutes a breach of the Grievant’s contract of employment and/or an unlawful demotion without due process of law which has caused and will continue to cause the Grievant monetary harm.

The Teachers filed an amended grievance on October 14, 2015, contending additionally that

“TEI wrongfully attempts to circumvent the teacher’s right to rebut documentation and the right

to file a grievance”; that “DISD has created a moving target, changing the metrics for bonus to

5 stay within a defined budget which wrongfully deprives qualified teachers of increases in pay”;

and that “no teachers received cost-of-living increases.”

The Teachers had two administrative grievance hearings.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Texas v. United States
523 U.S. 296 (Supreme Court, 1998)
State v. Public Utility Com'n of Texas
344 S.W.3d 349 (Texas Supreme Court, 2011)
Thota v. Young
366 S.W.3d 678 (Texas Supreme Court, 2012)
Ysleta Independent School District v. Meno
933 S.W.2d 748 (Court of Appeals of Texas, 1996)
Bowman v. Lumberton Independent School District
801 S.W.2d 883 (Texas Supreme Court, 1990)
Hamamcy v. Texas State Board of Medical Examiners
900 S.W.2d 423 (Court of Appeals of Texas, 1995)
Texas Alcoholic Beverage Commission v. Quintana
225 S.W.3d 200 (Court of Appeals of Texas, 2005)
Suburban Utility Corp. v. Public Utility Commission
652 S.W.2d 358 (Texas Supreme Court, 1983)
Weslaco Federation of Teachers v. Texas Education Agency
27 S.W.3d 258 (Court of Appeals of Texas, 2000)
Albertson's, Inc. v. Sinclair
984 S.W.2d 958 (Texas Supreme Court, 1999)
Burke v. Central Education Agency
725 S.W.2d 393 (Court of Appeals of Texas, 1987)
Morgan v. Employees' Retirement System
872 S.W.2d 819 (Court of Appeals of Texas, 1994)
Scally v. Texas State Board of Medical Examiners
351 S.W.3d 434 (Court of Appeals of Texas, 2011)
Ruben Aleman, M.D. v. Texas Medical Board
573 S.W.3d 796 (Texas Supreme Court, 2019)
Tijerina v. Alanis
80 S.W.3d 292 (Court of Appeals of Texas, 2002)

Cite This Page — Counsel Stack

Bluebook (online)
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-texapp-2019.