Hattie M. Blunt v. Marion County School Board

515 F.2d 951, 10 Empl. Prac. Dec. (CCH) 10,344, 1975 U.S. App. LEXIS 13708
CourtCourt of Appeals for the Fifth Circuit
DecidedJuly 14, 1975
Docket74-1279
StatusPublished
Cited by30 cases

This text of 515 F.2d 951 (Hattie M. Blunt v. Marion County School Board) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fifth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hattie M. Blunt v. Marion County School Board, 515 F.2d 951, 10 Empl. Prac. Dec. (CCH) 10,344, 1975 U.S. App. LEXIS 13708 (5th Cir. 1975).

Opinion

COLEMAN, Circuit Judge:

In May, 1969, on grounds of incompetency the school board of Marion County, Florida, terminated the employment contract of Mrs. Hattie M. Blunt, a black school teacher of some twenty-five years experience. Unsuccessful in an administrative appeal from the school board decision, 1 Mrs. Blunt initiated this civil rights suit, 2 challenging the constitution *953 ality of her dismissal. She alleged that in the course of proceedings before the Marion County School Board and the Florida State Board of Education certain of her constitutional rights had been violated. Specifically, her claims ran as follows:

(1) The evidence before the Marion County School Board was, in a constitutional sense, insufficient to support a finding of ineompetency. Thus, says Mrs. Blunt, she was dismissed on arbitrary and capricious grounds in violation of substantive due process;
(2) The dismissal was the result of an effort on the part of the Marion County School Board to voluntarily desegregate its faculties. Under these circumstances, the school board was under an obligation to prove that Mrs. Blunt was incompetent as compared to all other teachers in the system — a burden which the school board had failed to carry; and
(3) She was denied procedural due process in the course of the administrative proceedings before the Florida State Board of Education.

The relief sought was reinstatement of Mrs. Blunt’s teaching contract, along with back pay and accrued retirement benefits.

After a bench trial before the District Court for the Middle District of Florida, judgment was entered in favor of the Marion County School Board and the State Board of Education on the basis of failure of proof, Blunt v. Marion County School Board (M.D.Fla., 1973), 366 F.Supp. 727.

We affirm the judgment of the District Court in all respects.

The Substantive Due Process Claim

The essence of Mrs. Blunt’s substantive due process claim is that the evidence presented to the Marion County School Board was insufficient to support a finding of incompetency. A review of the transcript of the testimony presented at her dismissal hearing in May, 1969 supplies the following facts:

Prior to her dismissal at the close of the 1968-69 school year, Mrs. Blunt had taught elementary education in the Marion County school system for twenty-five years. During the 1968-69 term she was employed as a second grade teacher at Fessenden School under a “continuing contract”. Under this contractual agreement, Mrs. Blunt could not be dismissed except for “good and sufficient reasons”. 3 Further, if a dismissal recom *954 mendation was made, she was entitled to notice and a hearing before contract termination could become effective.

Throughout the 1968-69 school year Mrs. Blunt’s teaching performance was observed by three supervisors: Mr. Eugene Broxton, the principal at Fessenden School; Mrs. Margaret Cody, the assistant principal in charge of elementary education at Fessenden; and Mrs. Marie Keeney, early childhood coordinator for the Marion County school system. As early as October, 1968, Mr. Broxton, Mrs. Cody, and Mrs. Keeney agreed that Mrs. Blunt’s performance was not sufficient to meet the educational needs of her children. On November 7, Mrs. Keeney submitted a written evaluation of Mrs. ■Blunt’s work, which was reviewed with Mrs. Blunt by Mr. Broxton and Mrs. Cody. Mrs. Blunt was hostile to the criticisms set forth in the evaluation, and she displayed an unreceptive attitude to the assistance offered by her supervisors. On November 12, 1968, Mr. Broxton sent Mrs. Blunt a letter detailing the deficiencies noted in Mrs. Keeney’s evaluation and offering assistance for the improvement of her teaching techniques.

Further evaluations of Mrs. Blunt’s work were made on November 20 and December 5, neither of which indicated any substantial improvement in her instructional technique. These were followed by a letter from Mr. Broxton, dated December 12, in which he stated that Mrs. Blunt would have to improve in her performance or else a recommendation would be made for her dismissal. Thereafter, Mrs. Blunt continued to exhibit the same belligerent attitude toward offers of assistance from her supervisors, so, in March, 1969, Mr. Broxton recommended that she be dismissed. In a letter to the Marion County School Board dated March 25, 1969, Mr. Robert Dun-woody, superintendent of schools for Marion County, detailed the charges which prompted the recommendation for Mrs. Blunt’s dismissal:

Mrs. Blunt has exhibited inadequate knowledge of subject matter. She has not exhibited good teaching practices in the conduct of her classes. As a direct result of poor planning and poor organization, student motivation has been poor. Her management of students and class discipline has not met acceptable standards.

In due course, the school board scheduled a hearing on Mrs. Blunt’s dismissal for May 7, 1969. On May 2, Mrs. Blunt’s attorney was provided with a bill of particulars respecting the charges against Mrs. Blunt. 4

*955 At the May 7 hearing Mr. Broxton, Mrs. Cody, and Mrs. Keeney testified on the instructional deficiencies they had observed in Mrs. Blunt’s teaching performance during the 1968-69 school year. Each of these witnesses had visited Mrs. Blunt’s classroom on numerous occasions throughout the school year, 5 and all of them noted essentially the same shortcomings with respect to Mrs. Blunt’s performance. The cumulative effect of their testimony revealed the following points:

(1) Mrs. Blunt exhibited poor organizational skills with respect to her utilization of group teaching techniques. Although she attempted to divide her class into groups to teach certain subjects, she failed to use this technique in an efficient manner. While teaching one group of students, she would leave the remaining students idle without an assignment.
(2) Mrs. Blunt’s speech was at times difficult to understand. She had the habit of covering her mouth with her hand when she spoke, and, as a result, her speech was often muffled and unintelligible.
(3) Mrs. Blunt employed poor grammatical usage in her speech, and her grammatical errors were repeated by her students. Her most common grammatical mistake was the frequent use of double negatives.
(4) Mrs. Blunt misspelled words which she wrote on the blackboard, and, in turn, her students would copy these words.
(5) Mrs. Blunt exhibited poor writing techniques, which, in turn, were reflected in her students’ work. She would often use capital letters improperly, and she failed to employ proper spacing between words which she wrote on the blackboard.
(6) Mrs.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

United States v. Nicolas Alvarado Garcia
781 F.2d 422 (Fifth Circuit, 1986)
Adams v. Gaudet
515 F. Supp. 1086 (W.D. Louisiana, 1981)
Lee v. Washington County Board of Education
625 F.2d 1235 (Fifth Circuit, 1980)
Shanklin v. Dow Chemical Co.
494 F. Supp. 351 (M.D. Louisiana, 1980)
Hamm v. Yeatts
479 F. Supp. 267 (W.D. Virginia, 1979)
Lee v. Tuscaloosa County Board of Education
591 F.2d 324 (Fifth Circuit, 1979)
Gregory v. Mitchell
459 F. Supp. 1162 (M.D. Alabama, 1978)
New Jersey Education Association v. Fred G. Burke
579 F.2d 764 (Third Circuit, 1978)
New Jersey Education Ass'n v. Burke
579 F.2d 764 (Third Circuit, 1978)
Citron v. Jackson State University
456 F. Supp. 3 (S.D. Mississippi, 1977)
Ayers v. Western Line Consolidated School District
555 F.2d 1309 (Fifth Circuit, 1977)
Jon Tom Staton v. James K. Mayes
552 F.2d 908 (Tenth Circuit, 1977)

Cite This Page — Counsel Stack

Bluebook (online)
515 F.2d 951, 10 Empl. Prac. Dec. (CCH) 10,344, 1975 U.S. App. LEXIS 13708, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hattie-m-blunt-v-marion-county-school-board-ca5-1975.