Ciccone v. Cranston School Committee

513 A.2d 32, 34 Educ. L. Rep. 146, 1986 R.I. LEXIS 535
CourtSupreme Court of Rhode Island
DecidedAugust 1, 1986
DocketNo. 84-166-M.P.
StatusPublished
Cited by3 cases

This text of 513 A.2d 32 (Ciccone v. Cranston School Committee) is published on Counsel Stack Legal Research, covering Supreme Court of Rhode Island primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ciccone v. Cranston School Committee, 513 A.2d 32, 34 Educ. L. Rep. 146, 1986 R.I. LEXIS 535 (R.I. 1986).

Opinion

[33]*33OPINION

WEISBERGER, Justice.

This case comes before us on petition for common law writ of certiorari filed by John Ciccone (petitioner). The petitioner alleges that the State Board of Regents for Elementary and Secondary Education erred in determining that a tenured teacher suspended for cause is not entitled to receive notice of the suspension pursuant to the schedule set forth in G.L.1956 (1981 Reenactment) § 16-13-2. The facts are as follows.

The petitioner is a tenured teacher in the Cranston school department. In a letter dated February 11, 1982, the Cranston superintendent of schools (superintendent) notified petitioner that he would recommend to the school committee at its meeting on February 22,1982, that petitioner be suspended at the end of the 1981-82 school year. According to the letter, petitioner was to be suspended because “anticipated lack of adequate budgetary allocation may well make impossible the retaining of the professional staff as it existed in the past.”

The petitioner attended the February 22, 1982 meeting and was present when the school committee, acting on the superintendent’s recommendation, voted to suspend him at the end of the 1981-82 school year.

In a letter dated March 2, 1982, the superintendent informed petitioner of the action taken by the school committee at the February 22nd meeting and reiterated the reason for the suspension as the “anticipated lack of adequate budgetary allocation.”

Subsequent to the school committee’s vote, petitioner requested a hearing before the school committee regarding his suspension. The hearing was held on February 15, 1983. The petitioner was present and was represented by the executive secretary of the Rhode Island Federation of Teachers.

In a letter dated April 15,1983, the chairman of the school committee informed petitioner that the school committee had voted to sustain its February 22, 1982 decision to suspend petitioner at the end of the 1981-82 school year. The petitioner appealed the school committee’s decision to the State Commissioner of Elementary and Secondary Education (commissioner). Thereafter by decision dated September 15, 1983, the associate commissioner denied the appeal.1

The petitioner then appealed to the Board of Regents for Elementary and Secondary Education (board of regents), alleging that the school committee erred in not providing him with a written notice of the suspension as required by § 16-13-2.2 The board of regents denied petitioner’s appeal, thereby affirming the commissioner’s decision.

On March 28, 1984, petitioner filed a petition for common law writ of certiorari. This court entered an order issuing the writ on June 14, 1984.

This case presents two issues: (1) whether the provisions of § 16-13-2, relating to automatic continuation of annual teaching contracts, apply to the suspension of a ten[34]*34ured teacher and (2) whether the procedural provisions of § 16-13-4,3 relating to dismissal of a teacher, apply to the suspension or layoff of a tenured teacher. We answer both issues in the negative.

I

The petitioner argues that the purpose of § 16-13-2 is to accord any teacher, tenured or nontenured, the right to receive notice prior to March 1 of any school year in which their “services” are not going to be required and the right to a hearing, if so requested by the nonrenewed teacher. In accordance with that statute, petitioner contends that the school committee was required to give him written notice of his impending suspension on or before March 1, 1982.

The school committee determined that since petitioner was a tenured teacher, it was not required to give him the notice provided for in § 16-13-2. On appeal to the commissioner, the associate commissioner held that pursuant to § 16-13-2, a school committee is required to furnish notice in writing on or before March 1 to any regular teacher, tenured or nontenured, if that teacher’s contract is not going to be renewed for the upcoming school year. However, the associate commissioner concluded that since petitioner was present at the meeting when the school committee voted on his suspension, he was not materially prejudiced even though the school committee failed to comply with the exact terms of the statute.

Thereafter, the board of regents concluded that petitioner’s appeal should be denied but expressly rejected the application of § 16-13-2. Quoting a previous board of regents’ decision, the board of regents stated:

“We are also convinced that Section 16-13-2, which speaks in terms of ‘annual contract, except as hereinafter provided’ cannot apply to the nonrenewal of a tenured teacher’s contract for the very basic reason that Section 16-13-3 provides that tenured teachers ‘shall be considered in continuing service’ and thus not on an annual contract basis. Obviously a continuing service contract cannot be subject to nonrenewal.
******
“It seems equally clear to us that all references to teachers in section 16-13-2 relate to those teachers who are on an annual contract and thus not to tenured or ‘continuing service’ teachers.”

An examination of the provisions of § 16-13-2 reveals that the notice requirement refers expressly to the nonrenewal of teaching contracts. The contract of a tenured teacher is not subject to renewal or nonrenewal. In fact, it is that element of permanence that distinguishes a tenured teacher from a nontenured teacher.

The Legislature, in enacting § 16-13-3, specifically defined the nature of tenure as “continuing service,” and has further provided that a tenured teacher shall not be dismissed “except for good and just cause.”4 Accordingly, a teacher who has acquired tenure need not anxiously await [35]*35renewal of his teaching contract from one year to the next, whereas a nontenured teacher annually faces the prospect that his or her teaching contract will not be renewed. It is that possibility of nonrenewal that the notice provisions of § 16-13-2 were designed to address.

Additionally, § 16-13-2 states that a teacher’s service “shall be on the basis of an annual contract, except as hereinafter provided, and such contract shall be deemed to be continuous unless the governing body of the schools shall notify the teacher in writing on or before March 1 that the contract for the ensuing year will not be renewed * * The Legislature sought to create a clear distinction between annual contracts, which enjoy the safeguard of the March 1 notice deadline, and other contracts “as hereinafter provided.” An examination of the Teachers’ Tenure Act, chapter 13 of title 16, reveals that the only other teaching status provided for by statute is that of tenure.

Accordingly, we believe that the notice provisions of § 16-13-2 clearly apply only to the nonrenewal of a nontenured teacher’s annual contract. For that reason, petitioner, as a tenured teacher, was not entitled to receive notice of his impending suspension prior to March 1.

II

The petitioner next argues that not only was he entitled to receive the notice provided for in § 16-13-2 but he was further entitled to the hearing and appeal procedure set forth in § 16-13-4. According to petitioner, the procedural avenues of § 16-13-4 are dependent upon proper notice being given pursuant to § 16-13-2.

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Bluebook (online)
513 A.2d 32, 34 Educ. L. Rep. 146, 1986 R.I. LEXIS 535, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ciccone-v-cranston-school-committee-ri-1986.