Hayes v. Ridley Township School District

20 Pa. D. & C. 48, 1933 Pa. Dist. & Cnty. Dec. LEXIS 117
CourtPennsylvania Court of Common Pleas, Delaware County
DecidedJuly 12, 1933
DocketNo. 743
StatusPublished

This text of 20 Pa. D. & C. 48 (Hayes v. Ridley Township School District) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Delaware County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hayes v. Ridley Township School District, 20 Pa. D. & C. 48, 1933 Pa. Dist. & Cnty. Dec. LEXIS 117 (Pa. Super. Ct. 1933).

Opinion

MacDade, J.,

This matter comes before us for consideration in the form of a case stated. . . .

We are called upon to decide whether teachers of public schools who concededly taught and efficiently discharged their full duties as such beyond the usual school term for the years 1932-1933, on account of the closing of the schools in Ridley Township last September by the local boards of health, because of the infantile paralysis epidemic, are entitled to extra compensation. This teacher, for herself and others in a similar class of persons in Ridley Township School District, has raised the issue that she and the others should be paid for teaching services for a period of 18 days after the expiration of the date or term mentioned in the written contract which she entered into with the said school district under the terms of the School Code. There is not claimed to be any irregularity or illégality in this respect.

It would appear that the said written contract entered into by the said school district with this plaintiff as a teacher called for the teaching term to commence on September 6th last for the school term of 1932-1933. This teacher and all the other teachers of the said district and the eligible pupils of the same reported at the various schools therein on this date.

The following morning, September 7th, the public schools were closed by order of the township board of health. Instead of finishing the school term on May 29, 1933, the scheduled time, school sessions in the respective schools were continued under instructions from the Department of Education at Harrisburg (which has statutory authority) until June 23, 1933, even though the graduating class had its commencement on the evening of June 1st.

It would appear also that this plaintiff and the other efficient teachers have been paid for the 180 days called for in said written contract or contracts, but nevertheless they have not been paid for the extra 18 days required because the State Department of Public Instruction had insisted, against the protest of the said school district, that the school should be kept open until June 23, 1933, claiming that was the only date to be regarded as completing the full term of 180 school days. The plaintiff is simply asking for compensation upon the same basis of pay as the written contract has provided. She and the others claim that the full teaching (school) term expired May 29th last, for she and the others were notified by the school board of the said district to report every day for duty notwithstanding the action of the said board of health in ordering the schools closed, and they did, notwithstanding the pupils were not permitted to attend but the buildings remained open, constantly attend and perform such duties as teachers under the written contracts as required by the school district.

[49]*49It would appear that a somewhat similar situation arose in Westmoreland County, where Judge Copeland made a ruling in Stump v. School District of Hempfield Township, 46 Pa. C. C. 621, wherein he said that the school board has no authority to pay for the teaching outside of the written contract.

However, while this ruling may be correct under the facts of that case, yet the decision was rendered before the amendment to the School Code on May 23, 1919, P. L. 260.

The latter act was undoubtedly intended to remedy the unfortunate situation in the case of Stump v. Hempfield Township School District, supra (and school teachers are usually poorly paid for the substantial educational and patriotic work they perform), and perhaps, in Holter v. School District of Patton, which was decided in the Court of Common Pleas of Cambria County as of March Term, 1918, and Gumaer v. Dalton School District, 21 Lack. Jur. 85. It will be seen from these decisions that there was really a necessity for this amendment. In the Holter case, an appeal was taken to the Superior Court and an opinion filed by Judge Porter on October 13,1919, which will be found in 73 Pa. Superior Ct. 14. The Superior Court reversed the decision of the court below, holding, where the epidemic occurred within the school term, that the teacher was entitled to be paid for the full term, and this is what the amendment provides.

It is admitted that the plaintiff and the other teachers have been paid for the full term of their written contracts with the school district but the latter now wants them to forfeit compensation for the extra 18 days the said school district required them to serve by notice in the form of a letter on May 27, 1933, directed to plaintiff extending the term and the said written contract and directing her and the others to teach under the terms of the written contract for an additional 18 days, the period arbitrarily ordered and directed by the Department of Public Instruction for the schools to remain open.

The School Code of Pennsylvania, as amended, provides for just such a condition and expressly states that the teacher is to be paid for the extra time which she teaches. Categorically, the provision in the School Code with reference to this (sec. 1206, P. L. 309) is as follows:

“Section 1206. When a board of school directors is compelled to close any school or schools on account of contagious disease, the destruction or damage of the school building by fire, or other causes, unless otherwise provided in their contracts of employment, the school district shall be liable for the salaries of the teachers of said school or schools for the terms for which they were engaged.”

The case of Holter v. School District of Patton, 73 Pa. Superior Ct. 14, construed this section and held that the liability of the school district is established for the full term of the employment contract, whether the school is closed by reason of an epidemic or other cause mentioned in the act over which the teacher had no control.

The School Code of 1911, so far as section 1206 is concerned, was amended by the Act of May 23,1919, P. L. 260. The amendment reads as follows:

“Section 1206. When a board of school directors is compelled to close any school or schools on account of contagious disease, the destruction or damage of the school building by fire or other causes, the school district shall be liable for the salaries of the teachers of said school or schools for the terms for which they were engaged. Whenever a teacher is prevented from following his or her occupation as a teacher, during any period of the school term, for any of the reasons in this section specified, the school district shall be liable for the salary of such teacher for such period, at the rate of compensation stipulated in the [50]*50contract between the district and the teacher, in addition to the time actually occupied in teaching by such teacher.”

Section 1206, as amended by the Act of 1919, was reenacted in the amendment of section 1206 by the Act of May 20, 1921, P. L. 1012. The amendment of this section by the Act of 1921 is immaterial in this proceeding, as the amendment as therein contained has reference to sickness, etc., upon the part of the teacher.

Attention is particularly called to the amendment of 1919, which states that if the teacher is prevented from teaching during any period of the school term, she shall be entitled to the rates stipulated in the contract “in addition to the time actually occupied in teaching by such teacher.”

The amendment of 1919, as carried into the amendment of 1921, was passed for a very obvious reason, and that reason meets the facts in the instant case.

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Related

Hepburn v. City of Philadelphia
24 A. 279 (Supreme Court of Pennsylvania, 1892)
McManus v. Philadelphia
51 A. 320 (Supreme Court of Pennsylvania, 1902)
Ayers v. City of New Castle
10 Pa. Super. 559 (Superior Court of Pennsylvania, 1899)
Holter v. School Dist.
73 Pa. Super. 14 (Superior Court of Pennsylvania, 1919)

Cite This Page — Counsel Stack

Bluebook (online)
20 Pa. D. & C. 48, 1933 Pa. Dist. & Cnty. Dec. LEXIS 117, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hayes-v-ridley-township-school-district-pactcompldelawa-1933.