Hopp v. Oroville School District No. 410

639 P.2d 872, 31 Wash. App. 184, 1982 Wash. App. LEXIS 2450
CourtCourt of Appeals of Washington
DecidedJanuary 21, 1982
DocketNo. 4194-8-III
StatusPublished
Cited by1 cases

This text of 639 P.2d 872 (Hopp v. Oroville School District No. 410) is published on Counsel Stack Legal Research, covering Court of Appeals of Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hopp v. Oroville School District No. 410, 639 P.2d 872, 31 Wash. App. 184, 1982 Wash. App. LEXIS 2450 (Wash. Ct. App. 1982).

Opinion

McInturff, C.J.

Erik Hopp appeals the denial of his writ of certiorari to review a decision of the Oroville School District No. 410 (District). That decision precluded renewal of his contract after his initial year of teaching in the District.

Mr. Hopp was hired by the District to teach at Oroville High School during the 1979-80 school year. On November 27, 1979, within the first 90 days of the employment period, an evaluation report on Mr. Hopp was made by the principal of Oroville High School. The District's evaluation policy includes evaluation criteria required by RCW 28A.67.0651 [187]*187including instructional skill, classroom management, professional preparation and scholarship, effort toward improvement when needed, handling student discipline, interest in teaching, knowledge of subject matter and personal qualities. The evaluation noted various areas of deficiency and suggested means of improvement.* 2

On March 10, Mr. Hopp was given an annual evaluation report by Principal Motta. This report again noted deficiencies in various areas and a lack of improvement from the prior evaluation. On May 13, 1980, the superintendent of the school district advised Mr. Hopp in writing of his decision not to renew the teaching contract for the 1980-81 school year, listing reasons for the determination and advising him of procedures for requesting reconsideration of the decision. On May 16, 1980, Mr. Hopp's attorney advised the superintendent by letter of a request for an informal meeting to present evidence for reconsideration. The meeting was held on May 28, 1980; present were Mr. Hopp and his attorney, the District superintendent, Mr. Motta, and counsel for the District. Mr. Hopp presented letters from several fellow teachers and other supporters in addition to a memorandum of legal authority. On June 3, 1980, the superintendent recommended nonrenewal of the contract to the Oroville School Board.

On June 10, 1980, the Board of Directors convened to consider the matter. Mr. Hopp was again present and represented by two attorneys who submitted additional arguments on Mr. Hopp's behalf. At a special meeting on June 17,1980, the Board voted not to renew Mr. Hopp's teaching contract and notified him of its decision.

Mr. Hopp subsequently filed a petition for writ of certiorari asking the Okanogan Superior Court to review the [188]*188school district's proceedings. The court filed findings of fact and conclusions of law denying the petition and dismissed the action with prejudice.

On appeal, Mr. Hopp claims RCW 28A.67.072,3 the pro[189]*189visional employee statute, is violative of his due process and equal protection rights. We disagree.

Initially, we note our courts have held there is no constitutional "property" interest in public employment. Giles v. Department of Social & Health Servs., 90 Wn.2d 457, 461, 583 P.2d 1213 (1978). Property interests are defined by rules which stem from state law. Bishop v. Wood, 426 U.S. 341, 48 L. Ed. 2d 684, 96 S. Ct. 2074 (1976); State ex rel. Swartout v. Civil Serv. Comm'n, 25 Wn. App. 174, 182, 605 P.2d 796 (1980). Thus, Mr. Hopp, as a provisional teacher under RCW 28A.67.072, does not have a fundamental property right to employment which requires us to measure the questioned statute by the strict scrutiny test.* **4 Consequently, the applicable review standard is the 3-pronged rational basis test of Equitable Shipyards, Inc. v. State, 93 Wn.2d 465, 478, 611 P.2d 396 (1980):

(1) Does the classification apply alike to all members within the designated class? (2) Does some basis in reality exist for reasonably distinguishing between those within and without the designated class? (3) Does the classification have a rational relation to the purpose of the challenged statute?

First, we find RCW 28A.67.072 applies alike to all first-year teaching or noncertificated employees in the District. Second, a probationary period under this statute is a legitimate precondition to bestowing benefits of public employment. Ross v. Department of Social & Health Servs., 23 Wn. App. 265, 271, 594 P.2d 1386 (1979). Last, a [190]*190rational basis exists because of the need for a probationary period in which an employer may observe the performance of the probationary employee prior to conferral of a continuing contract under RCW 28A.67.070 with its elaborate procedural system. The rational purpose behind RCW 28A.67.072 was to afford a means of assuring effective teachers and proper education. See generally State ex rel. Swartout v. Civil Serv. Comm'n, supra at 179-80. The statute passes constitutional muster.

Next, Mr. Hopp argues the Board acted illegally by failing to apply the probationary provisions under RCW 28A.67.065.5 He maintains these probationary provisions are preconditions to nonrenewal of teaching contracts, whether the teacher is provisional or otherwise.

In interpreting a statute it is the duty of the court to ascertain and give effect to the intent and purpose of the legislature. In re Lehman, 93 Wn.2d 25, 27, 604 P.2d 948 (1980). Statutes in pari materia must be construed together in ascertaining legislative intent in order to give each statute meaning and validity. Kirk v. Miller, 83 Wn.2d 777, 522 P.2d 843 (1974). Mr. Hopp correctly points out that RCW 28A.67.065 predated RCW 28A.67.072. The legislature is presumed to be-familiar with its prior enactments when creating a new statute. Baker v. Baker, 91 Wn.2d 482, 486, 588 P.2d 1164 (1979). RCW 28A.67.072 states in part:

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Bluebook (online)
639 P.2d 872, 31 Wash. App. 184, 1982 Wash. App. LEXIS 2450, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hopp-v-oroville-school-district-no-410-washctapp-1982.