Lincoln County School District v. Mayer

591 P.2d 755, 39 Or. App. 99, 1979 Ore. App. LEXIS 2541
CourtCourt of Appeals of Oregon
DecidedMarch 5, 1979
DocketCA 11840
StatusPublished
Cited by9 cases

This text of 591 P.2d 755 (Lincoln County School District v. Mayer) is published on Counsel Stack Legal Research, covering Court of Appeals of Oregon primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Lincoln County School District v. Mayer, 591 P.2d 755, 39 Or. App. 99, 1979 Ore. App. LEXIS 2541 (Or. Ct. App. 1979).

Opinions

[101]*101BUTTLER, J.

Lincoln County School District (petitioner) seeks judicial review of an order of respondent Fair Dismissal Appeals Board (FDAB) setting aside the petitioner’s dismissal of respondent Robert L. Mayer as a permanent teacher and further ordering his reinstatement.

Mr. Mayer was employed as an elementary teacher by petitioner from 1962 until his dismissal in the spring of 1977. He taught at Oceanlake Elementary School until the fall of 1972, when he was transferred to Waldport Elementary School where he taught until his dismissal. During that entire period of time, there were numerous complaints concerning Mr. Mayer’s performance and behavior as a teacher, and in October of 1976, his school principal and the area director for petitioner met with Mr. Mayer for several hours to discuss their concerns and to give him certain written performance goals, at which time he was advised that failure to meet any of the goals would constitute failure to meet his teaching obligation and would be the basis for his dismissal.

Problems continued, and on May 23,1977, a notice of dismissal was served on Mr. Mayer, pursuant to ORS 342.895, in which petitioner assigned as statutory grounds for dismissal (ORS 342.865(1)), inefficiency, insubordination, neglect of duty and inadequate performance. The notice contained a statement of facts, in accordance with ORS 342.895,1 setting forth [102]*102the reasons supporting the statutory grounds, together with detailed facts relating to those reasons. At the conclusion of the hearing before the FDAB, that board found generally that the facts charged were true and substantiated. In addition to the general finding, the FDAB specifically mentioned some of the facts, which are set forth in the margin.2

[103]*103The FDAB concluded, however, that the facts relied upon by the petitioner, although true and substantiated, did not justify the statutory grounds for dismissal. It appears from the Ultimate Findings and [104]*104Conclusion of the FDAB that it exercised its independent judgment in making its determination, and the threshhold question on this appeal is whether FDAB exceeded its authority in so doing.

The relevant statutory provisions are ORS 342.895(1) and 342.905(1) and (7). ORS 342.895(1) provides:

"(1) Authority to dismiss a permanent teacher is vested in the district school board subject to the provisions of the fair dismissal procedures of ORS 342.805 to 342.955 and only after recommendation of the dismissal is given to the district school board by the superintendent.”

ORS 342.905(1) and (7) provide:

"(1) If the district school board dismisses the teacher, the teacher or the teacher’s representative may appeal that decision to the Fair Dismissal Appeals Board established under ORS 342.930 * * *.
"(7) If the Fair Dismissal Appeals Board panel finds the facts relied on to support the recommendation of the district superintendent true and substantiated, and that those facts justify the statutory grounds cited as reason for the dismissal and so notifies the permanent teacher, the district superintendent, the district school board and the Superintendent of Public Instruction in writing, the dismissal becomes final on the date of the notice.”

Respondents contend that under the terms of ORS 342.905(7) FDAB conducts a proceeding de novo by which it not only determines whether the facts relied cn to support the dismissal are true, but also to make an independent judgment of its own as to whether those facts justify the statutory grounds cited as the reason for the dismissal. While that subsection of the law may arguably lend some support to respondents’ contention, respondents’ interpretation would be inconsistent with the clear legislative expression contained in ORS 342.895 that the authority to dismiss a permanent teacher is vested in the district school [105]*105board subject to the provisions of the fair dismissal procedures. To the extent that there is an inconsistency between the two provisions, we must harmonize them if possible. It is clear from the Fair Dismissal Law that the FDAB must conduct a formal hearing (ORS 342.905), but the fact-finding function of that hearing is confined to determining whether the facts relied on to support the recommendation of the district superintendent to dismiss the teacher are true. The formal hearing before the FDAB is the first statutorily required hearing relating to the dismissal. To that extent, then, the fact-finding hearing conducted by the FDAB is de novo in the sense that it does not review a prior record made before the school board to determine if that record contains substantial evidence to support its stated reasons. The FDAB is the primary fact-finder.

The real question is whether the judgmental aspect of FDAB’s function on "appeal” stands in the same posture. First, we observe that authority to dismiss a permanent teacher is vested in the district school board, and that so long as the statutory (ORS 342.895) procedure is followed, the dismissal takes effect on or after the date of the board’s action, as specified by the board. Second, if no appeal is taken within ten days from receipt of notice of the board’s action, ORS 342.905(1), that is the end of the matter. Third, the characterization of the FDAB proceedings as an "appeal” suggests, although it may not dictate, that there be some review aspects to its functions, and since it is clear there is no review of fact-finding, the review function must relate to the remedial, or judgmental, authority of FDAB.

Such an analysis tends to harmonize any apparent inconsistency between ORS 342.895(1) and 342.905 by giving effect to the phrase "subject to the provisions of the fair dismissal procedures of ORS 342.805 to 342.955” which follows immediately the language vesting in the school board authority to dismiss.

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Lincoln County School District v. Mayer
591 P.2d 755 (Court of Appeals of Oregon, 1979)

Cite This Page — Counsel Stack

Bluebook (online)
591 P.2d 755, 39 Or. App. 99, 1979 Ore. App. LEXIS 2541, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lincoln-county-school-district-v-mayer-orctapp-1979.