Elias v. The Board of Education of the City of Chicago

2020 IL App (1st) 190066-U
CourtAppellate Court of Illinois
DecidedSeptember 4, 2020
Docket1-19-0066
StatusUnpublished

This text of 2020 IL App (1st) 190066-U (Elias v. The Board of Education of the City of Chicago) is published on Counsel Stack Legal Research, covering Appellate Court of Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Elias v. The Board of Education of the City of Chicago, 2020 IL App (1st) 190066-U (Ill. Ct. App. 2020).

Opinion

2020 IL App (1st) 190066

FIFTH DIVISION September 4, 2020

No. 1-19-0066

NOTICE: This order was filed under Supreme Court Rule 23 and may not be cited as precedent by any party except in the limited circumstances allowed under Rule 23(e)(1).

IN THE APPELLATE COURT OF ILLINOIS FIRST JUDICIAL DISTRICT

MOSES ELIAS, ) On Petition for Administrative ) Review from the Board of Petitioner, ) Education of the City of Chicago ) v. ) ) THE BOARD OF EDUCATION OF THE CITY OF ) CHICAGO and JANICE JACKSON, Chief Executive ) Officer, ) ) Respondents. ) No. 18-1205-RS4

PRESIDING JUSTICE DELORT delivered the judgment of the court Justices Hoffman and Rochford concurred in the judgment.

ORDER

¶1 Held: The Board of Education’s order to terminate a teacher complied with the applicable law and was not contrary to the manifest weight of the evidence.

¶2 BACKGROUND

¶3 After a hearing, the respondent, the Board of Education of the City of Chicago (Board)

dismissed the petitioner, Moses Elias, from his position as a teacher at Lane Technical High

School. The Board determined that Elias received an unsatisfactory rating following his

remediation period and thus failed to satisfactorily complete his remediation. Elias seeks 1-19-0066

administrative review of that decision, arguing that the Board wrongfully terminated him. We

affirm the Board’s order.

¶4 FACTS

¶5 On August 12, 2015, the Board’s chief executive officer approved a charge against Elias,

alleging that his teaching performance was unsatisfactory. The Board issued ten specifications

relating to its charge: (1) Elias’s 2013-2014 summative rating from his evaluator was

unsatisfactory; (2) the following school year, he attended or was invited to an orientation session

focused, in part, on the teacher evaluation plan; (3) his evaluator selected a qualified consulting

teacher to assist him in improving his performance; (4) the evaluator developed a 90-school-day

remediation plan after giving Elias and the consulting teacher a chance to provide input into the

plan; (5) the evaluator, consulting teacher, and Elias signed the 90-school-day remediation plan;

(6) the evaluator conducted a formal mid-point evaluation of Elias’s performance using the CPS

Framework for Teaching; (7) at or around the mid-point evaluation, Elias met with the evaluator

and consulting teacher to discuss his progress; (8) at or around the conclusion of the remediation

period, the evaluator conducted a final evaluation of Elias’s performance using the CPS

Framework for Teaching; (9) based on the evaluator’s personal observations and other evidence,

the evaluator determined that Elias failed to attain “proficient” or better level of teaching

practice; and (10) no further remediation was necessary, rendering Elias subject to dismissal

under Section 24A of the Code, 105 ILCS 5/24A1-1 et seq. (West 2014) (Code). The charges

concluded that Elias was “subject to dismissal due to [his] unsatisfactory teaching performance”

and that dismissal “may result in [his] permanent ineligibility for future employment with the

Board.”

2 1-19-0066

¶6 Elias’s union requested a hearing on the charge before a mutually selected hearing officer

pursuant to section 34-85 of the Code (105 ILCS 5/34-85 (West 2014)). The parties selected

Brian Clauss as the hearing officer. Elias filed an answer to the charge denying the Board’s

allegations and all the underlying specifications. His answer included six affirmative defenses,

stating essentially that the Board would be unable to prove the allegations and conclusorily

stating, with no factual explanation, that Elias was denied his due process rights.

¶7 At the beginning of the hearing, the hearing officer summarized an off-the-record

discussion he had with the parties. He identified an “exhibit binder” containing the Board’s 22

exhibits. He recited that Elias’s counsel had time to review it, had no objection to the foundation

of any of the exhibits contained therein, “and that will be the stipulation that he’ll enter into.” He

continued: “of course that does not affect anybody’s ability to argue weight, inferences and

conclusions that should be drawn from these exhibits, but we won’t have to belabor the

procedural aspect of the hearing by asking a bunch of foundational questions. So you’ll stipulate

to the foundation, correct?” Elias’s counsel responded, “yes.”

¶8 The hearing officer then noted that there was a stipulation that there were no procedural

defects (in the underlying proceedings) and that the remediation case was procedurally sound.

Both attorneys so stipulated. As the hearing officer eventually issued an exceptionally detailed

written summary of the testimony and evidence he heard, we summarize only the testimony and

evidence most relevant to the issues which Elias raises on administrative review.

¶9 Amanda Smith testified that she is a project manager for performance improvement for

the Board. At the beginning of her testimony, she was asked to identify Exhibit 5 from the

exhibit binder, which was a “framework for teaching with critical attributes” used to evaluate

3 1-19-0066

teachers under the REACH 1 program. Referring to this exhibit, she explained that employees

who evaluate teachers must be state-certified. Teachers are evaluated using a rubric with four

“domains”: (1) planning and preparation; (2) classroom environment; (3) instruction; and (4)

professional responsibility. At the conclusion of her explanation of this exhibit, the Board’s

attorney asked to admit Exhibit 5 into evidence. The hearing officer declined to do so, stating,

“We do that all at the end”.

¶ 10 Smith testified that Elias did not file a grievance regarding his employee reviews. She

identified Elias’s signature on a sign-in sheet for a REACH training session he attended. She

explained that, based on her review of various exhibits, Elias was observed in the classroom

during the 2013-2014 school year and attended a pre-observation conference on October 4, 2013.

Following that school year’s evaluations, he received a score of 196.8, which was in the

“unsatisfactory” range on a scale where 210 was “developing” and 285 was “proficient”. She

identified a letter notifying Elias that he was being placed in a remediation status based on his

unsatisfactory rating.

¶ 11 During remediation, she explained, teachers must receive coaching from a consulting

educator who develops a 90-school-day remediation plan with the teacher. Elias’s consultant was

Thomas Scanlan 2, a certified middle- and high-school mathematics teacher. Following the

remediation period, Elias received a score of 186, again in the unsatisfactory range.

¶ 12 Christine Gonzales testified that she worked for the Board from 2007-2016 in

successively more responsible capacities, the last of which was assistant principal at Lane. She is

a mathematics specialist with two master’s degrees. She was the head of the mathematics

department at Lane during Elias’s tenure there. Although she had done REACH evaluations, she

1 The term stands for “Recognizing Educators Advancing Chicago’s Students”. 2 Scanlan’s name is spelled “Scanlon” in certain places in the record, but we use the spelling set forth on his Illinois State Board of Education certificate of credentials, which was an exhibit below.

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2020 IL App (1st) 190066-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/elias-v-the-board-of-education-of-the-city-of-chicago-illappct-2020.