In Re the Termination of the Coaching Contract of Hahn Ex Rel. Independent School District No. 378

386 N.W.2d 789, 32 Educ. L. Rep. 260, 1986 Minn. App. LEXIS 4343
CourtCourt of Appeals of Minnesota
DecidedMay 13, 1986
DocketC4-85-2109
StatusPublished
Cited by4 cases

This text of 386 N.W.2d 789 (In Re the Termination of the Coaching Contract of Hahn Ex Rel. Independent School District No. 378) is published on Counsel Stack Legal Research, covering Court of Appeals of Minnesota primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In Re the Termination of the Coaching Contract of Hahn Ex Rel. Independent School District No. 378, 386 N.W.2d 789, 32 Educ. L. Rep. 260, 1986 Minn. App. LEXIS 4343 (Mich. Ct. App. 1986).

Opinion

OPINION

SEDGWICK, Judge.

This appeal is from a school board decision not to renew relator’s basketball coaching contract. We affirm.

FACTS

Relator James Hahn is a tenured teacher employed by Independent School District No. 378, Dawson. For the past 10 years, including the 1984-85 school year, Hahn was head girls’ basketball coach for Dawson High School. His coaching duties were based on successive one-year contracts.

The last contract was for the 1984-85 school year. The agreement dated May 15, 1984 provides:

3. In addition, you have been assigned the following extra assignments) * * * for the 1984-85 school year:
*790 Head girls’ basketball coach $2,240.00.

The 1984-85 school year ran from August 23, 1984 through May 29, 1985. The girls’ basketball season began November 20, 1984 and ended March 16, 1985.

On May 14, 1985, the school board voted not to include the basketball coaching job in Hahn’s 1985-86 teaching contract. On May 15, 1985, he was notified of the action by letter, which stated:

This is to further notify you formally, that the school board passed the motion which, in effect, instructs me as School Superintendent, not to assign you to girl’s basketball coach for the 85-86 school year. Please feel free to confirm with me regarding any of the above.

Hahn then requested a school board hearing. The district agreed to a hearing although it did not believe he had a right to one under Minn.Stat. § 125.121 (1984). At the hearing, Hahn’s attorney attempted to question the hearing officer regarding his neutrality. The hearing officer refused to answer questions and denied Hahn’s motion for a continuance. The findings recommended the district relieve Hahn of his coaching duties. The school board accepted the hearing officer’s recommendation and reaffirmed its decision refusing to renew the coaching contract. The only reason given for non-renewal was that his coaching contract expired. This appeal by writ of certiorari followed.

ISSUES

1. Is the failure to renew a coach’s contract for a subsequent year a “termination of the coaching duties of an employee” within the purview of Miiin.Stat. § 125.121 (1984)?

2. Did the school district establish a reason for termination which was true based on substantial and competent evidence in the record?

3. Did the district violate Hahn’s due process rights by refusing to permit him to question the hearing examiner to establish bias?

ANALYSIS

1. Minn.Stat. § 125.121 (1984) provides in part:

Subdivision 1. Before a district terminates the coaching duties of an employee who is required to hold a license as an athletic coach from the state board of education, the district shall notify the employee in writing and state its reason for the proposed termination. Within 14 days of receiving this notification, the employee may request in writing a hearing on the termination before the board. If a hearing is requested, the board shall hold a hearing within 25 days according to the hearing procedures specified in section 125.12, subdivision 9, and the termination shall not be final except upon the order of the board after the hearing.
Subd. 2. Within ten days after the hearing, the board shall issue a written decision regarding the termination. If the board decides to terminate the employee’s coaching duties, the decision shall state the reason on which it is based and include findings of fact based upon competent evidence in the record. The board may terminate the employee’s duties or not, as it sees fit, for any reason which is found to be true based on substantial and competent evidence in the record.

(Emphasis added.)

Relator argues that the school district’s decision not to renew his basketball coaching contract constitutes termination and is covered by the hearing provision of Minn. Stat. § 125.121 (1984). He contends that although the district held a hearing it was after the school board had already terminated him.

Respondent school district argues that Minn.Stat. § 125.121 requires a hearing only when a coach is fired or dismissed midseason; that failure to renew a contract is not a termination under the statute.

The hearing officer concluded that relator’s contract expired by mutual agreement; hence the school board did not terminate relator’s coaching duties, which would *791 have triggered the notice and hearing provisions of Minn.Stat. § 125.121.

This court has previously held “[w]here the terms of the statute have a plain meaning, that meaning should be followed.” Crow Wing County Social Services v. McDermond, 368 N.W.2d 97, 99 (Minn.Ct.App.1985) (citations omitted). Further, it is fundamental that courts should engage in statutory construction or interpretation only when the statute is ambiguous. Waller v. Powers Department Store, 343 N.W.2d 655, 657 (Minn.1984) (citation omitted).

The language of § 125.121, subd. 1, is plain and unambiguous. The legislature has taken steps to provide a certain class of coaches with minimal due process rights when their coaching duties are terminated. A board decision not to offer an employee coaching duties for a subsequent year does not constitute a termination. It is the legislature’s prerogative, not that of this court, to broaden the scope of Minn.Stat. § 125.121.

2. Although no hearing was mandated, the school board did notify relator and provided him with a hearing at his request.

The district argued that the contract was not renewed for the reason that it had expired. They also argued that this met the “any reason” standard articulated in the statute. The hearing officer agreed, stating that the school district did not have to renew relator’s coaching assignment.

The due process requirements of § 125.121 do not rise to the level of those required by Minn.Stat. § 125.12 and Minn. Stat. § 125.17. Section 125.121 requires only that the district notify the employee in writing and state its reason for the proposed termination. The district’s May 15 letter notified relator that his contract had not been renewed because of a vote of the school board. This was sufficient notice.

Sections 125.12 and 125.17 allow discharge only based on specific grounds. In contrast, § 125.121 allows termination of coaching duties based on “any reason which is found to be true based on substantial and competent evidence in the record.”

Before the legislature enacted Minn.Stat. § 125.121 in 1978, coaches were not entitled to notice or a hearing even where they were relieved of coaching duties midsea-son. See Stang v. Independent School District No. 191, 256 N.W.2d 82 (Minn.1977); Chiodo v. Board of Education, 298 Minn.

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

Related

McGuire v. Independent School District No. 833
146 F. Supp. 3d 1041 (D. Minnesota, 2015)
Leland Melvin Otto v. City of Victoria
685 F.3d 755 (Eighth Circuit, 2012)
Christopher v. Windom Area School Board
781 N.W.2d 904 (Court of Appeals of Minnesota, 2010)
Coles v. Glenburn Public School District No. 26
436 N.W.2d 262 (North Dakota Supreme Court, 1989)

Cite This Page — Counsel Stack

Bluebook (online)
386 N.W.2d 789, 32 Educ. L. Rep. 260, 1986 Minn. App. LEXIS 4343, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-the-termination-of-the-coaching-contract-of-hahn-ex-rel-independent-minnctapp-1986.