Gucciardo v. Springfield Local School Dist. Bd. of Edn.

2020 Ohio 5038
CourtOhio Court of Appeals
DecidedOctober 23, 2020
DocketL-19-1276
StatusPublished

This text of 2020 Ohio 5038 (Gucciardo v. Springfield Local School Dist. Bd. of Edn.) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Gucciardo v. Springfield Local School Dist. Bd. of Edn., 2020 Ohio 5038 (Ohio Ct. App. 2020).

Opinion

[Cite as Gucciardo v. Springfield Local School Dist. Bd. of Edn., 2020-Ohio-5038.]

IN THE COURT OF APPEALS OF OHIO SIXTH APPELLATE DISTRICT LUCAS COUNTY

Patrick Gucciardo Court of Appeals No. L-19-1276

Appellant Trial Court No. CI0201902581

v.

Springfield Local School District Board DECISION AND JUDGMENT of Education

Appellee Decided: October 23, 2020

*****

Edward J. Stechschulte, for appellant.

Lisa E. Pizza and David M. Smigelski, for appellee.

MAYLE, J.

{¶ 1} Appellant, Patrick Gucciardo, appeals the November 5, 2019 judgment of

the Lucas County Court of Common Pleas, affirming the decision of appellee, Springfield

Local School District Board of Education, not to renew his teaching contract. For the

following reasons, we affirm the trial court judgment. I. Background

{¶ 2} Patrick Gucciardo was employed as a teacher by the Springfield Local

School District Board of Education (“the Board”). For school years 2012-2013, 2013-

2014, and 2014-2015, he was employed under successive one-year limited contracts. He

was issued a three-year limited contract beginning August 18, 2015, and ending June 30,

2018.

{¶ 3} The Board sought to non-renew Gucciardo’s contract when his three-year

limited contract expired, but it failed to conduct three formal observations as is required

under R.C. 3319.111 when a board seeks to non-renew a teacher’s contract. Gucciardo

was, therefore, reemployed under an extended limited contract for a term of one year

under R.C. 3319.11(B). He did not grieve or otherwise challenge the issuance of this

one-year extended limited contract; he accepted the contract and signed it.

{¶ 4} During the 2018-2019 school year, the Board conducted formal observations

of Gucciardo on December 13, 2018, February 6, 2019, and March 13, 2019. On March

27, 2019, superintendent Matt Geha recommended to the Board that it take action to non-

renew Gucciardo’s teaching contract. The Board passed a resolution of its intent not to

reemploy Gucciardo, and notice of its intent not to re-employ was provided to Gucciardo

on April 3, 2019. On April 9, 2019, Gucciardo requested a written statement of the

reasons for the non-renewal recommendation, which was provided to him on April 12,

2019. On April 15, 2019, he requested a hearing to challenge the non-renewal

2. recommendation. The hearing was scheduled for April 30, 2019, at the Board’s next

meeting.

{¶ 5} The hearing took place during executive session at the Board meeting. The

parties were represented, witnesses provided sworn testimony, exhibits were offered, and

a court reporter recorded the hearing. When the Board resumed its public session, it

voted 3-2 to uphold the non-renewal decision.

{¶ 6} On May 28, 2019, Gucciardo appealed the Board’s April 30, 2019 decision

to the Lucas County Court of Common Pleas under “[R.C.] 3319.11(G)(7) (and, as

applicable, [R.C.] 2505.01, et seq. and/or [R.C.] 2506.01, et seq.).” Gucciardo argued

that the non-renewal of his contract was procedurally defective because (1) the parties’

collective bargaining agreement (“CBA”) required the Board to issue a three-year limited

contract—not a one-year extended limited contract—when it failed to follow the

evaluations procedure in 2018; (2) the Board’s second evaluation of him did not assign an

overall performance rating incorporated into his Final Summative Rating of Teacher

Effectiveness (“final summative rating”), in violation of R.C. 3319.112(A)(4); and (3) the

Board failed to provide Gucciardo assistance to improve his performance, as required

under the CBA.

{¶ 7} The common-pleas court affirmed the Board’s decision not to reemploy

Gucciardo in a judgment journalized on November 5, 2019. It concluded that (1)

Gucciardo accepted the one-year extended limited contract when he signed it and failed

to grieve it; (2) Gucciardo received three formal observations, he cited nothing requiring

3. that each observation culminate in a single rating, the formal observation performance

rubric identified the defects in Gucciardo’s performance, and an overall rating in the

February 2019 rubric would not have changed the outcome of his final summative rating;

and (3) the incidents leading to the Board’s decision to non-renew Gucciardo’s contract

identified specific rules violations that required no further explanation or assistance, and

the CBA does not specify the nature of assistance that should be given as part of the

evaluation process.

{¶ 8} Gucciardo appealed the trial court judgment and assigns a single error for

our review:

The trial court erred when it found that the Springfield Local School

District Board of Education’s non-renewal of Appellant Patrick Gucciardo

was procedurally compliant with the evaluation procedures of R.C.

3319.11, R.C. 3319.111, and the collective bargaining Agreement.

II. Law and Analysis

{¶ 9} Gucciardo challenges the trial court’s conclusion that the Board complied

with the procedural requirements of R.C. 3319.11, 3319.111, and the CBA in non-

renewing his teaching contract. He maintains that the non-renewal was procedurally

defective in two regards: (1) the Board failed to comply with R.C. 3319.111 and the

CBA because its second of three written evaluations omitted a rating for

“professionalism” and an “overall rating” and his final summative rating was based on

4. only two formal observations instead of three; and (2) the Board failed to provide him

assistance to improve his performance in accordance with the CBA.

{¶ 10} Under R.C. 3319.11(G)(7), “[a] teacher may appeal an order affirming the

intention of the board not to reemploy the teacher to the court of common pleas * * * on

the grounds that the board has not complied with this section or section 3319.111 of the

Revised Code.” But the common pleas court “is limited to the determination of

procedural errors and to ordering the correction of procedural errors.” Id. It has “no

jurisdiction to order a board to reemploy a teacher, except that the court may order a

board to reemploy a teacher * * * when the court determines that evaluation procedures

have not been complied with pursuant to section 3319.111 of the Revised Code * * *.”

Id. “Otherwise, the determination whether to reemploy or not reemploy a teacher is

solely a board’s determination and not a proper subject of judicial review and * * * no

decision of a board whether to reemploy or not reemploy a teacher shall be invalidated by

the court on any basis, including that the decision was not warranted by the results of any

evaluation or was not warranted by any statement given pursuant to division (G)(2) of

this section.” Id.

{¶ 11} In an appeal from the common pleas court’s decision, we do not review the

Board’s action directly; rather, we review the trial court’s factual findings under an

abuse-of-discretion standard and its legal conclusions de novo. Sturdivant v. Toledo Bd.

of Edn., 157 Ohio App.3d 401, 2004-Ohio-2878, 811 N.E.2d 581, ¶ 27 (6th Dist.). We

5. then determine “whether, as a matter of law, the decision of the common pleas court has

correctly applied the law to the facts * * *.” Id.

A. Three Formal Observations

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Bluebook (online)
2020 Ohio 5038, Counsel Stack Legal Research, https://law.counselstack.com/opinion/gucciardo-v-springfield-local-school-dist-bd-of-edn-ohioctapp-2020.