Huber v. Mars Area School District

3 Pa. D. & C.3d 175, 1977 Pa. Dist. & Cnty. Dec. LEXIS 256
CourtPennsylvania Court of Common Pleas, Butler County
DecidedJuly 21, 1977
DocketMiscellaneous docket no. 76-145
StatusPublished

This text of 3 Pa. D. & C.3d 175 (Huber v. Mars Area School District) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Butler County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Huber v. Mars Area School District, 3 Pa. D. & C.3d 175, 1977 Pa. Dist. & Cnty. Dec. LEXIS 256 (Pa. Super. Ct. 1977).

Opinion

KIESTER, P.J.,

Donald A. Huber was employed by the Mars Area School District in September of 1974, as an elementary school guidance counselor and teacher coordinator for the cooperative diversified program. His status was that of a temporary professional employe as defined by the Public School Code of March 10, 1949, P.L. 30, sec. 1101, as amended, 24 P.S. §11-1101. At the end of the second year of employment, Mr. Huber was notified in writing by the superintendent, Dr. Anthony Rago, that he was recommending to the school board that the employment contract not be renewed and that he be dismissed as a temporary professional employe on the grounds of an unsatisfactory rating. Mr. Huber was also notified that he had the right to a hearing before the school board. A school board hearing was convened on July 31, 1976, to consider the recommendations of Dr. Rago. After six witnesses, fifteen exhibits and 314 pages of testimony the school board made various findings, concluding that the unsatisfactory rating was fully supported by the evidence, and ordered the dismissal of Mr. Huber.

From the “adjudication” by the school board, Mr. Huber appealed to this court under the provi[177]*177sions of the Local Agency Law of December 2, 1968, P.L. 1133, 53 P.S. §11301. Counsel filed legal briefs and oral arguments were heard by the court on December 10, 1976.

Appellant, Donald A. Huber, states the first, issue as follows: “The constitutional rights of the appellant were violated by the Chairman of Mars Area School Board’s refusal to allow counsel for the appellant the right to voir dire each member of the Mars Area School Board to determine if each member of the Board was impartial and unbiased.”

Since counsel was not permitted to examine the members of the school board relative to knowledge, interest, competency, bias, prejudice, etc., the argument is made that the constitutional rights of appellant were violated. It is the position of appellant that he was entitled to a fair trial before competent, impartial and unbiased school directors and that voir dire was the procedure to determine qualifications. If a voir dire had been permitted it is not clear who appellant would have accepted as the person to rule upon the qualifications of a challenged director. The directors had been selected by the electors of the school district. The legislature had designated the school directors as the hearing board in such matters. Who would have the right to disqualify a challenged director?

The right to voir dire the members of a school board sitting as a hearing board is not authorized either by statute or case law. Appellant has cited no precedent in support of his position. The United States Supreme Court has held that prior knowledge by a board does not prevent the board from hearing the charges and adjudicating them: Withrow v. Larkin, 421 U. S. 35, 95 S. Ct. 1456 (1975). [178]*178The Commonwealth Court reached the same result when it declared that due process rights were not violated when “ . . . the hearing was conducted before a board which had conducted an investigation, prepared ‘charges,’ and made a preliminary determination of‘guilt’ prior to granting a hearing. ...” Rayne v. Edgewood School District, 19 Pa. Commonwealth Ct. 353, 339 A.2d 151 (1975).

The Public School Code has given both the professional employe and the temporary professional employe considerable protection. In the absence of bad faith, arbitrary, capricious, or unlawful action the decision of a school board cannot be reversed. It is quite inconceivable that a court would permit an attack on the qualifications of a school board member through a voir dire proceeding. The impact of voir dire on the functioning of the system in situations such as the one before this court would be devastating.

I believe that it is the duty of a school board member either to investigate complaints or to order that complaints about personnel and the operation of the system be investigated. In our representative form of government, it must be assumed that people of honesty and integrity have been elected to office. School board members cannot be placed on trial as to their bias, prejudice, etc. in the manner proposed by appellant.

As already indicated, appellant’s motion to take additional evidence of the members of the school board by voir dire will be denied. If other evidence was intended to be offered it is not supported by affidavit and a further hearing will be denied.

The next issue raised by appellant is stated as follows: “The final ratings of the Appellant compiled by Dr. Anthony Rago, Superintendent of the [179]*179Mars Area School District, on May 27, 1976, are not in accordance with the standards and regulations for such scoring as defined by the DEBE-333 rating card prepared by the Department of Public Instruction.”

The Public School Code provides for the establishment of a rating system by the Department of Public Instruction (now Department of Education) in rating the services of a temporary professional employe, “which shall give due consideration to personality, preparation, technique, and pupil reaction, in accordance with standards and regulations for such scoring as defined by rating cards to be prepared by the Department of Public Instruction . . 24 P.S. §11-1123. (Emphasis supplied.)

The department promulgated a rating form referred to as DEBE-333 together with a requirement that the rating be supported by “anecdotal records.”

The school board found and the record establishes that James Duerr, the immediate supervisor of appellant, gave him a marginal satisfactory rating on February 4, 1975, and on March 4, 1975, an unsatisfactory rating on March 2, 1976 and on May 13, 1976, and a satisfactory rating .on May 19, 1976.

Dr. Rago observed appellant in the classroom on May 20, 1976, and advised appellant orally and in writing of the unsatisfactory evaluation. A formal unsatisfactory rating was filed on May 27, 1976. In addition to the classroom visitation on May 20, 1976, Dr. Rago testified that the unsatisfactory rating was based on the supervisor’s reports and his observation of the performance of Mr. Huber at conferences and meetings relating to his professional duties.

[180]*180James Duerr testified that on May 19, 1976, he changed appellant’s rating from unsatisfactory to satisfactory because of compassion for him and his physical disability.

The record establishes that numerous oral and written suggestions were furnished appellant by Mr. Duerr in an attempt to help him improve his rating.

Nevertheless, appellant maintains that the failure of Dr. Rago to attach the “anecdotal record” to the DEBE-333 completed on May 27, 1976, is a fatal defect in the proceedings.

The requirement of an “anecdotal record” is a salutary one which should be obeyed according to one appellate court decision: Mulhollen Appeal, 155 Pa. Superior Ct. 587, 39 A.2d 283 (1944). Appellant relies on the decision of the Commonwealth Court in New Castle Area School District v. Bair, 28 Pa. Commonwealth Ct. 240, 368 A.2d 345 (1977), which is distinguishable in several respects from the instant case.

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Related

Withrow v. Larkin
421 U.S. 35 (Supreme Court, 1975)
Mulhollen Appeal
39 A.2d 283 (Superior Court of Pennsylvania, 1944)
Rayne v. Edgewood School District
339 A.2d 151 (Commonwealth Court of Pennsylvania, 1975)
New Castle Area School District v. Bair
368 A.2d 345 (Commonwealth Court of Pennsylvania, 1977)

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Bluebook (online)
3 Pa. D. & C.3d 175, 1977 Pa. Dist. & Cnty. Dec. LEXIS 256, Counsel Stack Legal Research, https://law.counselstack.com/opinion/huber-v-mars-area-school-district-pactcomplbutler-1977.