Deborah Jane Clapp v. Rochelle Cox, in her official capacity as Interim Superintendent of Minneapolis ...

CourtCourt of Appeals of Minnesota
DecidedDecember 4, 2023
Docketa230360
StatusUnpublished

This text of Deborah Jane Clapp v. Rochelle Cox, in her official capacity as Interim Superintendent of Minneapolis ... (Deborah Jane Clapp v. Rochelle Cox, in her official capacity as Interim Superintendent of Minneapolis ...) is published on Counsel Stack Legal Research, covering Court of Appeals of Minnesota primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Deborah Jane Clapp v. Rochelle Cox, in her official capacity as Interim Superintendent of Minneapolis ..., (Mich. Ct. App. 2023).

Opinion

This opinion is nonprecedential except as provided by Minn. R. Civ. App. P. 136.01, subd. 1(c).

STATE OF MINNESOTA IN COURT OF APPEALS A23-0360

Deborah Jane Clapp, Appellant,

vs.

Rochelle Cox, in her official capacity as Interim Superintendent of Minneapolis Public Schools, et al., Respondents.

Filed December 4, 2023 Reversed Gaïtas, Judge

Hennepin County District Court File No. 27-CV-22-12454

Daniel N. Rosen, Rosen LLC, Minneapolis, Minnesota; and

Michael Bekesha (pro hac vice), Judicial Watch, Inc., Washington, District of Columbia (for appellant)

Margaret A. Skelton, Timothy A. Sullivan, Ratwik, Roszak & Maloney, P.A., St. Paul, Minnesota (for respondents)

Considered and decided by Gaïtas, Presiding Judge; Slieter, Judge; and Frisch,

Judge.

NONPRECEDENTIAL OPINION GAÏTAS, Judge

Appellant Deborah Jane Clapp, a homeowner and taxpayer in Minneapolis, appeals

the dismissal of her declaratory-judgment action, which challenged the constitutionality of

a collective-bargaining agreement between Minneapolis Public Schools and its teachers’ union. The district court concluded that Clapp’s complaint failed to establish her standing

to sue as a taxpayer and that the claims were not ripe. Because Clapp’s complaint pleaded

an adequate basis for taxpayer standing, and the claims are ripe, we reverse the district

court’s dismissal of the action.

FACTS 1

Clapp is a Minneapolis homeowner who pays annual property taxes on her

residence. Those property taxes contribute to the funding of Minneapolis Public Schools.

Respondents are Minneapolis Public Schools, Special School District No. 1 (the

school district), the Minneapolis Board of Education, and Rochelle Cox, who is the Interim

Superintendent of Minneapolis Public Schools. We refer to respondents collectively as

MPS.

In August 2022, Clapp filed a complaint against MPS seeking declaratory and

injunctive relief. Clapp’s complaint sought to enjoin MPS from spending money to

implement and enforce a March 2022 collective-bargaining agreement that MPS and the

teachers’ union entered into following a three-week teachers’ strike. According to Clapp’s

complaint, one provision of that agreement—Article 15, which addresses the transfer,

1 In this appeal from the district court’s order dismissing Clapp’s complaint under Minnesota Rule of Civil Procedure 12.02, our review is limited to the facts alleged in Clapp’s complaint, and we must accept those facts as true. See Hansen v. U. S. Bank Nat’l Ass’n, 934 N.W.2d 319, 325 (Minn. 2019) (noting that, in reviewing a district court’s ruling on a motion to dismiss under rule 12.02, the appellate court “look[s] only to the facts alleged in the complaint, accepting those facts as true”). Correspondingly, our discussion of the facts underlying the appeal is limited to the allegations in Clapp’s complaint.

2 reassignment, and recall of teachers—violates the Minnesota Constitution’s equal-

protection guarantee.

Clapp’s complaint states that, before the adoption of Article 15, “teachers were laid

off or reassigned in order of seniority . . . , without regard to race or ethnicity.” Teachers

were also “reinstated in order of seniority, with the more senior teachers reinstated first,

without regard to race or ethnicity.” But the complaint alleges that Article 15 of the March

2022 agreement altered this practice, such that “teachers of color are exempt from [the]

seniority-based layoffs and reassignments, which means, when layoffs or reassignments

occur, the next senior teacher who is not ‘of color’ would be laid off or reassigned.” Article

15 states: 2

Starting with the Spring 2023 Budget Tie-Out Cycle, if excessing[ 3] a teacher who is a member of a population underrepresented among licensed teachers in the site, the [school district] shall excess the next least senior teacher, who

2 Typically, if “matters outside the pleading are presented to and not excluded by the court, the motion [to dismiss] shall be treated as one for summary judgment and disposed of as provided in Rule 56.” Minn. R. Civ. P. 12.02. Clapp did not attach the March 2022 agreement to her complaint. However, MPS submitted the agreement, including Article 15, to the district court with its motion to dismiss. And if a complaint contains a contract- based claim, “the court may consider the entire written contract when the complaint refers to the contract and the contract is central to the claims alleged.” Baker v. Best Buy Stores, LP, 812 N.W.2d 177, 180 (Minn. App. 2012) (quotation omitted), rev. denied (Minn. Apr. 25, 2012); see also Hous. & Redev. Auth. of Chisholm v. Norman, 696 N.W.2d 329, 337 (Minn. 2005) (noting that appellate courts interpret and enforce a collective-bargaining agreement under contract principles). Because the March 2022 agreement is central to Clapp’s claims, we may review it without converting the motion to dismiss into a summary- judgment motion. 3 As defined by Article 15, “[e]xcessed status exists when there is a reduction in staffing at a school or site.” The “process of excessing is a separate process from layoff.”

3 is not a member of an underrepresented population, for the reasons provided in Article 15.1.2.i.

....

Reinstatement must be in the inverse order of placement on lay off. The [school district] shall prioritize the recall of a teacher who is a member of a population underrepresented among licensed teachers in the [school district], per the definition provided in Article 15.1.2.i. To do this, the [school district] shall deprioritize the more senior teacher, who is not a member of an underrepresented population, in order to recall a teacher who is a member of an underrepresented population among licensed teachers, for the reasons provided in Article 15.1.2.i.

Article 15.1.2.i provides that the anticipated outcome of the policy is to:

remedy the continuing effects of past discrimination by the [school district]. Past discrimination by the [school district] disproportionately impacted the hiring of underrepresented teachers in the [school district], as compared to the relevant labor market and the community, and resulted in a lack of diversity of teachers. Language which refers to this Article will no longer be in effect once the teachers in the [school district] reflect the diversity of the labor market and the community served by the [school district].

The complaint alleges that MPS will lay off or reassign approximately 220 teachers

between 2022 and 2027.

According to Clapp’s complaint, Article 15 violates equal protection under the state

constitution because it “provides preferences, protections, and privileges for MPS teachers

of certain races and ethnicities” for layoffs and recalls. The complaint further asserts that

Article 15 requires MPS to spend public money to implement this allegedly unlawful

practice.

4 Clapp’s complaint alleges that the district court has jurisdiction to consider her

challenge to Article 15 under Minnesota’s common-law taxpayer-standing doctrine. The

complaint states that approximately 31% of MPS’s costs are funded by local property taxes,

these costs include “programs, services, and other expenses, including expenses associated

with the process of laying off, reassigning, reinstating, and retaining teachers,” and MPS

will rely on public funding “to implement the contract, including laying off, reinstating,

and retaining teachers in accordance with Article 15.”

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