Daly v. Grove City Area School District

46 Pa. D. & C.3d 281, 1986 Pa. Dist. & Cnty. Dec. LEXIS 84
CourtPennsylvania Court of Common Pleas, Mercer County
DecidedFebruary 28, 1986
Docketno. 1077 C.D. 1985
StatusPublished

This text of 46 Pa. D. & C.3d 281 (Daly v. Grove City Area School District) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Mercer County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Daly v. Grove City Area School District, 46 Pa. D. & C.3d 281, 1986 Pa. Dist. & Cnty. Dec. LEXIS 84 (Pa. Super. Ct. 1986).

Opinion

FRAMPTON, J.

This case comes before the court on the petition of Jan K. Daly to reverse the decision of the Grove City Area School District furloughing her from her position as a home economics teacher in that district.

The facts in this case are not in dispute. By virtue of various stipulations, it was agreed that the Grove City Area School District has had a substantial decline in student enrollment, as the term is used in the Public School Code, sufficient to justify the furlough of a home economics teácher. Grove City Area School District had two home economics teachers, petitioner, Jan K. Daly, and Sylvia Roach. Ms. Daly was hired on July 13, 1981, as a permanent halftime home economics teacher. Prior to that time, she had been employed for one semester as a long-term substitute, filling the leave of another home economics teacher. From the date of her permanent hiring to her date of furlough, Ms. Daly continued to teach as a half-time home economics teacher. In the school year 1984-85 another home economics teacher went on sabbatical and Ms. Daly was hired by the board as a half-time, long-term substitute to [283]*283fill the position made vacant by the regular teacher’s sabbatical leave. Therefore, for the 1984-85 school year Ms. Daly was employed both as a permanent half-time teacher and as a half-time, long-term substitute teacher.

Sylvia Roach was hired by the board on August 9, 1982, as a permanent full-time home economics teacher and has continued to work for the Grove City Area School District in that capacity to the present time. .Prior to being hired as a permanent full-time employe, Ms. Roach had been employed in the 1981-82 school year as a long-term substitute for one-half year.

The parties stipulated to the employment histories of Ms. Daly and Ms. Roach as follows:

JAN K. DALY
SUBSTITUTE PERMANENT
YEAR TIME TIME TOTAL
1980-81 682.5 hours
1981-82 1,092.5 hours
1982-83 907.5 hours
1983-84 907.5 hours
1984-85 682.5 hours 682.5 hours
1,365. 4,955 hours 0 hours + 3,590.0 hours
SYLVIA ROACH
SUBSTITUTE PERMANENT
YEAR TIME TIME TOTAL
1981-82 682.5 hours
1982-83 1.365.0 hours
1983-84 1.365.0 hours
1984-85 1.365.0 hours
682.5 hours + 4,095.0 hours = 4,777.5 hours

The issue in this case is whether, for the purpose of furlough, seniority should be calculated solely on [284]*284the basis of permanent teaching time, or whether the seniority calculation should also include substitute teaching time.

DISCUSSION

Section 1125.1 of the School Code, 24 Pa.C.S. 11-1125.1 provides:

.“(a) Professional employes shall be suspended under section 1124 (relating to causes for suspension) in inverse order of seniority within the school entity of current employment. Approved leaves of absence shall not constitute a break in service for purposes of computing seniority for suspension purposes. Seniority shall continue to accrue during suspension and all approved leaves of absence.
(b) Where there is or has been a consolidation of schools, departments or programs, all professional employes shall retain the seniority rights they had prior to the reorganization or consolidation.
(c) A school entity shall realign its professional staff so as to insure that more senior employes are provided with the opportunity to fill positions for which they are certificated and which are being filled by less senior employes.”

Section 1101 of the School Code, 24 Pa.C.S. §11-1101 provides several definitions that are important to the discussion.of this case as follows:

“(1) The term “professional employe” shall include those who are certificated as teachers, supervisors, supervising principals, principals, assistant principals, vice-principals, directors of vocational education, dental hygienists, visiting teachers, home and school visitors, school counselors, child nutrition program specialists, school librarians, school secretaries the selection of whom is on the basis of merit as determined by eligibility lists and school nurses.
[285]*285“(2) The term ‘substitute’ shall mean any individual who has been employed to perform the duties of a regular professional employe during such period of time as the regular professional employe is absent on sabbatical leave or for other legal cause authorized and approved by the board of school directors or to perform the duties of a temporary professional employe who is absent.
“(3) The term ‘temporary professional employe’ shall mean any individual who has been employed to perform for a limited time, the duties of a newly created position or of a regular professional employe whose services have been terminated by death, resignation, suspension or removal.”

The decision in this case comes down to the treatment of the hours Ms. Daly spent as a substitute teacher for the Grove City Area School District. Of particular interest is Ms. Daly’s position during the 1984-85 school year when she served as both a permanent half-time teacher and a half-time, long-term substitute teacher. The half-time, long-term substitute position was to fill the sabbatical leave of another home economics teacher.

The Public School Code does not define “seniority” nor is there a suggested method for calculating seniority. There is, however, some case law that examines the position of a “substitute” and how that position relates to the question of “seniority.”

In Marnell v. Mount Carmel Joint School System, 380 Pa. 83, 110 A.2d 357 (1955), the Supreme' Court dealt with the dismissal’of one of two school nurses after the consolidation of two school districts. One of the nurses, Miss Ambrose, was hired May 3, 1943, as a substitute for the regular school nurse who was absent on military leave. On September 7, 1943, the regular school nurse resigned and Miss Ambrose’s status changed to that of a [286]*286“temporary professional employe.” Another nurse, Miss Marnell, was hired as a “temporary professional employe” on September 1, 1943. When the two school districts for which the two nurses were employed became consolidated there was only need for one nurse. The school cbdé provided for retention of the more senior employe.

In its opinion, the court reviewed the difference between a “substitute” and a “temporary professional employe” and indicated that because a teacher who is on leave can elect to return to work and thereby cause the dismissal of the individual temporarily filling that position, the latter person could only be categorized as a substitute and not as a temporary professional employe.

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Related

Love v. Bedstone Township School District
100 A.2d 55 (Supreme Court of Pennsylvania, 1953)
Marnell v. Mount Carmel Joint School System & Joint School Committee
110 A.2d 357 (Supreme Court of Pennsylvania, 1955)
Marco v. Montgomery County Intermediate Unit No. 23
387 A.2d 164 (Commonwealth Court of Pennsylvania, 1978)
Bitler v. Warrior Run School District
437 A.2d 481 (Commonwealth Court of Pennsylvania, 1981)

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Bluebook (online)
46 Pa. D. & C.3d 281, 1986 Pa. Dist. & Cnty. Dec. LEXIS 84, Counsel Stack Legal Research, https://law.counselstack.com/opinion/daly-v-grove-city-area-school-district-pactcomplmercer-1986.