Colorado Education Association v. Colorado State Board of Education

2025 COA 56
CourtColorado Court of Appeals
DecidedJune 12, 2025
Docket24CA1085
StatusPublished
Cited by1 cases

This text of 2025 COA 56 (Colorado Education Association v. Colorado State Board of Education) is published on Counsel Stack Legal Research, covering Colorado Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Colorado Education Association v. Colorado State Board of Education, 2025 COA 56 (Colo. Ct. App. 2025).

Opinion

The summaries of the Colorado Court of Appeals published opinions constitute no part of the opinion of the division but have been prepared by the division for the convenience of the reader. The summaries may not be cited or relied upon as they are not the official language of the division. Any discrepancy between the language in the summary and in the opinion should be resolved in favor of the language in the opinion.

SUMMARY June 12, 2025

2025COA56

No. 24CA1085, Colorado Education Association v. Colorado State Board of Education — Education — Licensed Personnel Performance Evaluation Act — Performance Evaluation Ratings for Teachers — Process for Nonprobationary Teacher to Appeal Second Consecutive Performance Evaluation Rating of Ineffective or Partially Ineffective

A teachers’ association appeals the district court’s judgment

denying its petition for review of two rules governing the evaluation

of teacher performance adopted by the Colorado State Board of

Education (Board). The challenged rules (1) established a “partially

effective” performance rating, defined as one of two ratings

demonstrating ineffectiveness; and (2) established the appeal

process for teachers who receive a second consecutive performance

rating demonstrating ineffectiveness, limiting the grounds upon

which a teacher can base such an appeal. A division of the court of

appeals addresses the teachers’ association’s contention that the Board’s promulgation of the challenged rules exceeded its statutory

authority. The division concludes that the Board didn’t exceed its

authority with respect to either rule. Accordingly, the division

affirms the judgment of the district court. COLORADO COURT OF APPEALS 2025COA56

Court of Appeals No. 24CA1085 City and County of Denver District Court No. 23CV32208 Honorable David H. Goldberg, Judge

Colorado Education Association,

Plaintiff-Appellant,

v.

Colorado State Board of Education,

Defendant-Appellee.

JUDGMENT AFFIRMED

Division V Opinion by JUDGE WELLING Grove and Johnson, JJ., concur

Announced June 12, 2025

Colorado Education Association, Rory M. Herington, Ethan Ice, Denver, Colorado, for Plaintiff-Appellant

Phillip J. Weiser, Attorney General, Michelle Berge, First Assistant Attorney General, Joseph Peters, Senior Assistant Attorney General, Denver, Colorado, for Defendant-Appellee ¶1 The Colorado Education Association (CEA) appeals the district

court’s judgment denying its petition for review of two rules

governing the evaluation of teacher performance adopted by the

Colorado State Board of Education (Board). Department of

Education Rule 3.3, 1 Code Colo. Regs. 301-87 (Rule 3.3),

establishes a performance standard of “partially effective” and

defines it as one of two ratings that demonstrates ineffectiveness.

Department of Education Rule 5.4, 1 Code Colo. Regs. 301-87 (Rule

5.4), establishes the appeal process for teachers who have received

two consecutive ratings demonstrating ineffectiveness but limits the

grounds upon which a teacher can base their appeal. The CEA

argues, as it did to the district court, that the Board exceeded its

statutory authority by defining the “partially effective” performance

standard as a second rating demonstrating ineffectiveness and by

impermissibly restricting the grounds on which teachers may

appeal a second consecutive rating demonstrating ineffectiveness.

We, like the district court, disagree that the Board exceeded its

authority. We, therefore, affirm the judgment of the district court.

1 I. Background

¶2 In 2010, the General Assembly enacted Senate Bill 10-191,

which significantly changed the way teachers are evaluated under

the Licensed Personnel Performance Evaluation Act (the Act), §§ 22-

9-101 to -109, C.R.S. 2024. See Ch. 241, 2010 Colo. Sess. Laws

1053-75; see also Johnson v. Sch. Dist. No. 1, 2018 CO 17, ¶¶ 3-7

(discussing sweeping changes ushered in by Senate Bill 10-191).

As part of the Act, the General Assembly established a performance

evaluation system that would sort teacher performance into one of

two categories — demonstrating effectiveness or demonstrating

ineffectiveness. § 22-63-103(7), C.R.S. 2024. A teacher who

demonstrates effectiveness for three consecutive years achieves

nonprobationary status. Id. But if a teacher who has obtained

nonprobationary status is given a rating that demonstrates

ineffectiveness for two consecutive years, they lose their

nonprobationary status and are returned to probationary status.

Id.

¶3 This distinction between probationary and nonprobationary

status is vitally important because, while a probationary teacher’s

contract can’t be longer than one school year and can be denied

2 renewal for any reason, § 22-63-203(2)(a), (4)(a), C.R.S. 2024, a

nonprobationary teacher may only be dismissed for “just cause,”

§ 22-63-301, C.R.S. 2024. Simply put, nonprobationary teachers

have far more robust job protections than probationary teachers.

See § 22-63-202, C.R.S. 2024.

¶4 The legislative scheme adopted in 2010 expressly created two

performance standards demonstrating effectiveness — “highly

effective” and “effective” — and one performance standard

demonstrating ineffectiveness — “ineffective.” § 22-9-105.5(3)(a),

C.R.S. 2024. The statute, however, provides that the three

prescribed performance standards don’t constitute an exhaustive

list and explicitly authorizes the Board — in consultation with a

council of educators appointed by the governor — to create

additional performance standards. Id.; see also § 22-9-105.5(1)-(2)

(discussing the appointment and composition of the council of

educators).

¶5 The Act also instructed the Board to design and implement an

appeal process for nonprobationary teachers who have received two

consecutive ratings demonstrating ineffectiveness. §§ 22-9-

105.5(3)(e)(VII), -106(4.5)(b), C.R.S. 2024.

3 ¶6 The statutory scheme charged the Board with promulgating

administrative rules through rulemaking. §§ 22-9-103(2.5),

-104(2)(f), -105.5(10)(a), C.R.S. 2024. Following notice and

comment, the Board adopted a comprehensive set of rules in

February 2012. With respect to performance standards, the Board

adopted Rule 3.3, which defines the Act’s three prescribed

performance standards — “highly effective,” “effective,” and

“ineffective” — as well as a fourth performance standard: “partially

effective.” Dep’t of Educ. Rule 3.3(B), 1 Code Colo. Regs. 301-87.

Rule 3.3(B) defined “partially effective” as a second performance

rating — along with “ineffective” — demonstrating ineffectiveness.

¶7 Regarding the appeals process for nonprobationary teachers

who receive two consecutive performance ratings of “ineffective” or

“partially ineffective,” the Board adopted Rule 5.4. Dep’t of Educ.

Rule 5.4, 1 Code Colo. Regs. 301-87. In Rule 5.4, the Board limited

the grounds upon which a teacher could appeal a rating

demonstrating ineffectiveness to (1) the evaluator’s failure to follow

the proper evaluation procedures; and (2) the evaluator’s reliance

on data inaccurately attributed to the appealing teacher (“e.g., data

4 included in the evaluation was from students for whom the teacher

was not responsible”). Id. at Rule 5.4(A)(7).

¶8 Before these two rules could go into effect, they had to survive

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