East Orange Board of Education v. Rotimi Owoh

CourtNew Jersey Superior Court Appellate Division
DecidedAugust 26, 2025
DocketA-3964-22
StatusUnpublished

This text of East Orange Board of Education v. Rotimi Owoh (East Orange Board of Education v. Rotimi Owoh) is published on Counsel Stack Legal Research, covering New Jersey Superior Court Appellate Division primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
East Orange Board of Education v. Rotimi Owoh, (N.J. Ct. App. 2025).

Opinion

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ." Although it is posted on the internet, this opinion is binding only on the parties in the case and its use in other cases is limited. R. 1:36-3.

SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. A-3964-22

EAST ORANGE BOARD OF EDUCATION,

Plaintiff-Respondent,

v.

ROTIMI OWOH,

Defendant-Appellant. __________________________

Submitted May 5, 2025 – Decided August 26, 2025

Before Judges Gummer and Berdote Byrne.

On appeal from the Superior Court of New Jersey, Chancery Division, Essex County, Docket No. C-000071-23.

Rotimi Owoh, appellant pro se.

Antonelli Kantor Rivera, attorneys for respondent (Ramon E. Rivera, of counsel and on the brief; Lawrence M. Teijido and Madelaine P. Hicks, on the brief).

PER CURIAM Defendant Rotimi Owoh was employed by plaintiff East Orange Board of

Education as a teacher. An arbitrator found plaintiff had substantiated certain

tenure charges against defendant that supported his dismissal. Defendant

appeals from the arbitration award, the arbitrator's denial of defendant's

reconsideration motion, and the Chancery Division's confirmation of the

arbitration award. Perceiving no legal error or abuse of discretion in the

arbitrator's or Chancery Division's decisions, we affirm.

I.

Defendant began working for plaintiff in September 2001 and

subsequently attained tenure status. Based on defendant's purported excessive

absenteeism during the 2018-19, 2019-20, and 2020-21 school years and other

alleged conduct, plaintiff certified the following tenure charges against him in

2021 pursuant to N.J.S.A. 18A:6-10: incapacity, conduct unbecoming,

insubordination, neglect of duty, and other just cause. N.J.S.A. 18A:6-10 is part

of the Tenure Employees Hearing Law (TEHL), N.J.S.A. 18A:6-10 to -18.1.

Plaintiff sought to terminate defendant's employment.

In his answer, defendant denied the charges, claimed he had a condition

that made it medically impractical for him to "keep up" with elementary-school

children and to climb the stairs at the school, asserted he had provided medical

A-3964-22 2 documentation to plaintiff, and contended the charges were pretextual and

issued in retaliation for activities he had engaged in that he claimed were

protected by various laws, including the New Jersey Law Against

Discrimination (LAD), N.J.S.A. 10:5-1 to -50, and the Conscientious Employee

Protection Act, N.J.S.A. 34:19-1 to -14. In the answer, defendant referenced a

June 18, 2021 letter he had written to plaintiff. In that letter, defendant advised

plaintiff he was practicing law but might later choose to return to teaching if he

became medically able to do so without limitation or restriction.

The case was referred to an arbitrator pursuant to N.J.S.A. 18A:6-16.1

After denying plaintiff's summary-decision motion, temporarily staying the

matter at defendant's request, and granting defendant's multiple adjournment

requests, the arbitrator scheduled the hearing on the charges to take place on

November 1 and 9, 2022. On October 31, 2022, defendant requested an

adjournment of the November 1, 2022 hearing date for health reasons. The

arbitrator granted that request but advised defendant the matter would be marked

as peremptory going forward and that no further adjournments would be granted

1 Defendant did not include in his appellate appendix copies of plaintiff's charges, his answer, related correspondence, or a transcript of the proceedings before the arbitrator. We take this information from the summary set forth by the arbitrator in his opinion. The arbitrator's summary appears to be undisputed. A-3964-22 3 absent extraordinary and compelling circumstances. On November 1, 2022,

defendant told the arbitrator he was not available for the November 9, 2022

hearing date because he had a court appearance in another matter, of which he

had had notice since September 15, 2022. The arbitrator declined to adjourn the

hearing, citing defendant's delay in raising the issue and concluding defendant

had not presented extraordinary and compelling circumstances. On November

9, 2022, defendant did not appear at the hearing, and plaintiff decided to defer

presentation of its case until December 13, 2022, which was the next hearing

date.

Defendant moved for dismissal of the tenure charges based on a default

entered against plaintiff in a LAD action defendant had filed against plaintiff in

the Superior Court. Although the arbitrator advised defendant it would address

the motion at the December 13, 2022 hearing, defendant chose not to appear.

The arbitrator later denied the motion as moot after learning the court in the

LAD matter had vacated the default.

During the December 13, 2022 hearing, Marissa McKenzie, plaintiff's

business administrator, testified plaintiff maintained an attendance policy,

which stated in relevant part:

The East Orange Board of Education recognizes that an effective educational system is one in which all

A-3964-22 4 members, whenever possible, report for duty each and every working day. Therefore, to foster and maximize staff attendance at the [ninety-five] percent level, an attendance improvement program shall be developed and implemented.

The primary purpose of the attendance program shall be to improve and maintain the quality of education. Improved attendance will increase the level of staff contact time and ensure the continuity of learning by reducing to a minimum the interruption of services provided students by full[-]time staff.

The regular and prompt attendance of teaching staff members is an essential element in the efficient operation of the school district and the effective conduct of the educational program. Staff member absenteeism disrupts the educational program [and] the Board of Education considers attendance an important component of staff member's job performance.

A teaching staff member who fails to give prompt notice of an absence, misuses sick leave, fails to verify an absence in accordance with Board policy, falsifies the reason for an absence, is absent without authorization, is repeatedly tardy, or accumulates an excessive number of absences may be subject to appropriate consequences, which may include the withholding of salary increments, dismissal and/or certification of tenure charges.

McKenzie also testified about defendant's absences from work, his

reported health issues, the leaves of absence he had taken, his communications

with the principal and others, his stated intention to return to work, and his

failure to return to work and to provide a return-to-work clearance from his

A-3964-22 5 doctor and other requested medical information to support his absences.

According to McKenzie, she sent him a letter on April 26, 2021, noting he had

been out of work since September 16, 2019, and making a "final request for

medical information to support [his] absence from December 3, 2020 to [the]

present." McKenzie testified she had advised defendant that if he did not

respond by May 14, 2021, he would be considered "absent without leave

effective December 3, 2020, and subject to discipline." McKenzie stated that

because defendant had not responded by May 14, 2021, she sent him a letter

dated May 17, 2021.

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East Orange Board of Education v. Rotimi Owoh, Counsel Stack Legal Research, https://law.counselstack.com/opinion/east-orange-board-of-education-v-rotimi-owoh-njsuperctappdiv-2025.