Dulany v. Board of School Commissioners

512 F. Supp. 685, 1981 U.S. Dist. LEXIS 13272
CourtDistrict Court, S.D. Alabama
DecidedMarch 26, 1981
DocketCiv. A. No. 80-0468-H
StatusPublished

This text of 512 F. Supp. 685 (Dulany v. Board of School Commissioners) is published on Counsel Stack Legal Research, covering District Court, S.D. Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Dulany v. Board of School Commissioners, 512 F. Supp. 685, 1981 U.S. Dist. LEXIS 13272 (S.D. Ala. 1981).

Opinion

FINDINGS OF FACT AND CONCLUSIONS OF LAW

HAND, District Judge.

A short, non-jury trial was held on March 17, 1981 in this case. The Court heard evidence, viewed the credibility of the witnesses, and received exhibits.

I. The Facts

The complaint was filed by Ray T. Dulany, a tenured teacher under Alabama law employed by defendant Board of School Commissioners for approximately ten (10) years. He claims that a one-month suspension violated his due process rights under the fourteenth amendment to the Constitution, his rights under the State’s Teacher Tenure Law. Ala.Code §§ 16-24-38, and his rights under Ala.Code §§ 16-8-23 and 16-9-23.

Defendant Board of School Commissioners is the general supervisory agency of the public schools of Mobile County, Alabama. It is empowered to perform executive and administrative functions, including developing and executing certain employment practices and policies, and is responsible for the hiring, retention and termination of teachers for the public schools of Mobile County. At all material times herein, the defendant Board of School Commissioners was the plaintiff’s employer.

Defendants Dan C. Alexander, Jr., R. W. Gilliard, Norman J. Berger, Hirman C. Bosarge, Norman G. Cox and Ruth F. Drago are and were at the time pertinent to this action members of the School Board and are and were responsible for developing and executing certain employment policies and practices, including the hiring, retention and termination of teachers for the public schools of Mobile County.

Defendant Abe L. Hammons was at all times pertinent to this action Superintendent for the Board of School Commissioners of Mobile County, Alabama. In that position he participated in the development and execution of certain employment policies and practices including the hiring, retention, and termination of teachers for the public schools of Mobile County.

[687]*687By letter dated November 7, 1979, Dulany was advised by the defendant Hammons that the plaintiff was suspended without pay from his duties at Alba High School for thirty (30) days effective November 1, 1979 through November 30, 1979. Further, the letter also informed the plaintiff that he would be placed on probation for the remainder of the 1979-80 school year.

Pursuant to the action taken by the defendant Hammons, the plaintiff was not paid a monthly installment of $1,308.43 as provided for in his teaching contract for the 1979-80 school year.

The principal of Alba High School, Mr. Frank Wood, gave written and verbal notification to Dulany of the complaint which was filed against him by the parents of a student at Alba High School. Further the principal officially reprimanded the plaintiff for hitting this student with a paddle and using improper language in violation of Board policy.

In accordance with Board policy the principal gave written notification to the Acting Assistant Superintendent of Personnel describing the incident at Alba High School. On October 23, 1979 Mr. Owen of the Division of Personnel met with Dulany and discussed the incident at Alba High School. At this meeting Dulany was informed of the principal’s recommendation and the principal’s referral of the matter to the office of personnel. Mr. Owen later forwarded a written memorandum to the Deputy Superintendent regarding the incident which was acknowledged by the Deputy Superintendent with a recommendation that the plaintiff appear before a Central Appeals Committee for a hearing regarding his employment status.

The Division of Personnel notified Dulany about the proposed hearing before the Central Appeals Committee. The Central Appeals Committee met, considered all allegations brought against the plaintiff in an evidentiary hearing, and listened to the plaintiff’s side of the story. The hearing was conducted according to Board policy.

In accordance with the Board policy the Central Appeals Committee on November 1, 1979 recommended in writing to the Superintendent of the Board of School Commissioners of Mobile County, Alabama that the plaintiff be suspended without pay for thirty (30) days and that he be placed on probation for the remainder of the school term.

The Board acted in accordance with Board policy when the Superintendent reviewed the Central Appeals Committee recommendation, met with the Assistant Superintendent of Personnel, received approval to suspend the plaintiff effective November 1,1979 through November 30,1979, and placed him on probation for the remainder of the 1979-80 school year. Dulany failed to exhaust available administrative remedies. An administrative appeal could have afforded Dulany relief more or less commensurate with the claim in this case.

II. Conclusions of Law

A. Jurisdiction

The Court has jurisdiction over the section 1983 claim by virtue of 28 U.S.C. § 1343(a)(3) and 28 U.S.C. § 1331. See Act of Dec. 1, 1980, Pub.L. No. 96-486 (to be codified at 28 U.S.C. § 1331) (striking out $10,000.00 amount-in-controversy). Pendent jurisdiction over the related state-law claims is appropriate. United Mine Workers v. Gibbs, 383 U.S. 715, 726, 86 S.Ct. 1130, 1139, 16 L.Ed.2d 218 (1966).

The evidence showed, that Dulany deliberately chose not to exhaust available administrative remedies. The available remedies could have afforded the plaintiff more or less all that he sought in this suit. However, the defendants never raised the issue of exhaustion of adequate state administrative remedies. Exhaustion of adequate state administrative remedies is non-jurisdictional. Thus the Court will reach the merits of the federal claim. See Patsy v. Florida International University, 634 F.2d 900 (5th Cir. 1981) (en banc).

B. 1983 Claim

Due process is required only when state action deprives a person of a property [688]*688or liberty right. Property rights are creatures of state law. In this case it is undisputed that Dulany was a tenured teacher. Thus a state-created property right existed, and the Board could not impugn that right by suspending a tenured teacher without pay unless due process was accorded. Bell v. Board of School Commissioners of Mobile County, 450 F.Supp. 162, 166 (S.D.Ala.1978); see Board of Regents v. Roth, 408 U.S. 564, 576, 92 S.Ct. 2701, 2708-09, 33 L.Ed.2d 548 (1972); cf. Bishop v. Wood, 426 U.S. 341, 344, 96 S.Ct. 2074, 2077, 48 L.Ed.2d 684 (1976) (no entitlement under state law).

Due process means different things in different contexts.

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Related

United Mine Workers of America v. Gibbs
383 U.S. 715 (Supreme Court, 1966)
Board of Regents of State Colleges v. Roth
408 U.S. 564 (Supreme Court, 1972)
Bishop v. Wood
426 U.S. 341 (Supreme Court, 1976)
William C. Ferguson v. Alvin I. Thomas
430 F.2d 852 (Fifth Circuit, 1970)
Roy N. Stapp v. Avoyelles Parish School Board
545 F.2d 527 (Fifth Circuit, 1977)
James v. Bd. of Sch. Com'rs of Mobile County, Ala.
484 F. Supp. 705 (S.D. Alabama, 1979)
Johnson v. San Jacinto Junior College
498 F. Supp. 555 (S.D. Texas, 1980)
Bell v. Board of Sch. Com'rs of Mobile Cty.
450 F. Supp. 162 (S.D. Alabama, 1978)
Vodantis v. Birmingham Bd. of Ed.
373 So. 2d 320 (Supreme Court of Alabama, 1979)
Armstrong v. BD. OF ED. OF CITY OF BIRMINGHAM, ALA.
430 F. Supp. 595 (N.D. Alabama, 1977)
Gregory v. Mitchell
634 F.2d 199 (Fifth Circuit, 1981)
Patsy v. Florida International University
634 F.2d 900 (Fifth Circuit, 1981)

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Bluebook (online)
512 F. Supp. 685, 1981 U.S. Dist. LEXIS 13272, Counsel Stack Legal Research, https://law.counselstack.com/opinion/dulany-v-board-of-school-commissioners-alsd-1981.