Feinerman v. Board of Cooperative Educational Services

399 N.E.2d 899, 48 N.Y.2d 491, 423 N.Y.S.2d 867, 1979 N.Y. LEXIS 2422
CourtNew York Court of Appeals
DecidedNovember 27, 1979
StatusPublished
Cited by35 cases

This text of 399 N.E.2d 899 (Feinerman v. Board of Cooperative Educational Services) is published on Counsel Stack Legal Research, covering New York Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Feinerman v. Board of Cooperative Educational Services, 399 N.E.2d 899, 48 N.Y.2d 491, 423 N.Y.S.2d 867, 1979 N.Y. LEXIS 2422 (N.Y. 1979).

Opinions

OPINION OF THE COURT

Jasen, J.

The dispositive issue on this appeal is whether a prospective [494]*494teacher may waive the right to be appointed to a three-year probationary period in a tenure-bearing position.

The facts are uncomplicated and may be briefly summarized. In February of 1974, petitioner Muriel Feinerman was appointed by respondent Board of Cooperative Educational Services of Nassau County (BOCES) as a teacher of business subjects in the BOCES adult education program — a program which was, from its inception, wholly dependent upon Federal funding. The contract of employment, duly signed by petitioner, extended only until June 30, 1974, and provided for a per diem wage. It further stated that "[tjhere is no tenure with this position.”

Petitioner was reappointed to her position for the 1974-1975 school year1 and also for the 1975-1976 school term. By letter dated September 2, 1975, petitioner was again informed that her salary would be paid on a per diem basis and that no tenure would attach to her position. Petitioner signed a copy of this letter, thereby indicating her "acceptance of the terms and conditions of employment.” Further, petitioner was a member of a collective bargaining unit during her term of employment and was subject to the parties’ collective bargaining agreement. The express terms of the agreement then in effect provided that "[tjenure is not applicable in annually funded Day Time Adult Occupational Education projects.”

Prior to the commencement of the 1976-1977 school year, the superintendent of schools, by letter dated June 18, 1976, advised petitioner that her position as a teacher of business subjects in the BOCES adult education program would be terminated as of June 30, 1976, due to decreased enrollment. Thereafter, petitioner instituted this article 78 proceeding seeking a judgment directing respondent BOCES to reinstate her to the position of teacher, with full back pay and benefits. Special Term denied the requested relief and dismissed the petition, reasoning that since petitioner had consented to be appointed to a temporary, nontenure-bearing position, she should not now be heard to complain that her dismissal worked to deprive her of the statutory benefits which attach only to a tenure-bearing teaching position.

On appeal, a unanimous Appellate Division modified the judgment of Special Term by awarding petitioner 60 days’ [495]*495back pay. Although concluding that petitioner’s position was, by law, tenure-bearing, the Appellate Division nevertheless determined that reinstatement was properly denied petitioner. The Appellate Division reasoned that even if "petitioner received the probationary appointment to which she was entitled in 1974, she still would have been subject to termination upon recommendation of the superintendent and vote of the board.” (62 AD2d 1036, 1038; see Education Law, § 3031.) The order of the Appellate Division should be modified by eliminating the award of 60 days’ back pay, and, as so modified, affirmed.

On these cross appeals to this court,2 petitioner contends that her teaching position was, by law, probationary, and, thus, tenure-bearing inasmuch as there exists no authority in the Education Law which permits BOCES to appoint a teacher to a "temporary” position which is freely revocable. Proceeding on this premise, petitioner maintains that her employment was terminated wrongfully since she has accumulated greater seniority rights than two other teachers — respondents Eisner and Smith — who serve in the same tenure area as petitioner. (See Education Law, § 2510, subd 2.)3 Further, petitioner contends that the Appellate Division erred in treating her termination as one pursuant to section 3031 of the Education Law, which delineates the procedure to be followed by BOCES when discontinuing the services of a probationary teacher.

Respondent BOCES counters these contentions by arguing that petitioner was, in fact, a temporary employee who was not entitled to protection under the tenure statutes. In support of its position, respondent emphasizes that the very terms of petitioner’s employment contracts provided that she was to be employed only for a limited period of time and, further, stated, in clear and unequivocal terms, that "[t]here is no tenure with this position.”

This case presents a novel issue for our consideration, to wit: whether considerations of public policy preclude BOCES from employing a teacher for a limited term in a position [496]*496which carries with it no tenure rights. In our opinion, considerations of public policy do not prohibit such contracts.

It should be noted at the outset that petitioner is not now claiming that BOCES engaged in coercive tactics when negotiating the terms and conditions of her employment. Indeed, the record is devoid of any indication or hint of duress whatsoever. Rather, we are concerned here with a situation where a prospective teacher freely and knowingly consented to be employed for a series of one-year terms in a nontenure-bearing position.

We begin our analysis by recognizing that the Education Law provides that "teachers and all other members of the teaching and supervising staff of the board of cooperative educational services shall be appointed by a majority vote of the board of cooperative educational services upon the recommendation of the district superintendent of schools for a probationary period of not to exceed three years”. (Education Law, § 3014, subd 1.) While it has been stated that these so-called tenure statutes — promulgated by the Legislature in furtherance of the purpose to attract qualified educators and to provide teachers with job security — may not be subverted by denominating otherwise permanent teaching positions as "temporary” (see Matter of Board of Educ. v Nyquist, 45 NY2d 975, revg on dissenting opn below 59 AD2d 76; Serritella v Board of Educ., 58 AD2d 645, mot for lv to app den 43 NY2d 642; Matter of Board of Educ. v Allen, 12 NY2d 980) or by delaying the formal appointment of a teacher to a vacancy in a permanent position (Ricca v Board of Educ., 47 NY2d 385), these fact situations are not present here, for there exists an express agreement between the parties that petitioner was to be employed only for limited terms in a nontenure-bearing position. Further, even assuming that "temporary” appointments are not authorized by law (see Matter of Board of Educ. v Nyquist, 59 AD2d, at p 79, supra; Matter of Cardo, 8 Ed Dept Rep 182, 183), petitioner’s position could, at best, be viewed as an appointment to a limited probationary term which, by express agreement, did not carry with it the expectation of tenure.

Thus, the precise question which must be resolved on this appeal is whether a "probationary” teacher may waive any expectation of tenure and relinquish the right to be appointed to a three-year probationary term. We now hold such waivers [497]*497to be valid if they are knowingly and freely made, and not the product of coercive influences.

Our holding today that a teacher may consent freely to be appointed to a nontenure-bearing position was foreshadowed by this court’s decision in Matter of Baer v Nyquist (34 NY2d 291). Although we held in Baer

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Bluebook (online)
399 N.E.2d 899, 48 N.Y.2d 491, 423 N.Y.S.2d 867, 1979 N.Y. LEXIS 2422, Counsel Stack Legal Research, https://law.counselstack.com/opinion/feinerman-v-board-of-cooperative-educational-services-ny-1979.