Pleasant Valley Education Ass'n v. Pleasant Valley Community School District

449 N.W.2d 894, 1989 Iowa App. LEXIS 325, 1989 WL 159695
CourtCourt of Appeals of Iowa
DecidedOctober 24, 1989
Docket88-1655
StatusPublished

This text of 449 N.W.2d 894 (Pleasant Valley Education Ass'n v. Pleasant Valley Community School District) is published on Counsel Stack Legal Research, covering Court of Appeals of Iowa primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Pleasant Valley Education Ass'n v. Pleasant Valley Community School District, 449 N.W.2d 894, 1989 Iowa App. LEXIS 325, 1989 WL 159695 (iowactapp 1989).

Opinion

SACKETT, Judge.

This action was brought by plaintiff-appellant, Pleasant Valley Education Association, seeking a declaratory judgment to the effect that defendant-appellee Pleasant Valley Community School District was legally and contractually prohibited from requiring physical education teachers to satisfactorily complete training in cardiac pulmonary resuscitation, the Red Cross series on water safety, specifically life-saving, and/or certification as a water safety instructor. The trial court did not grant the relief the teachers association requested and they have appealed. We affirm the trial court.

The problem arose when the Pleasant Valley Community School District added a swimming pool to its physical plant and began offering swimming classes to its students. Previously it did not have a swimming pool and did not offer swimming classes. The school notified its high school physical education teachers they would be assigned to attend in-service training in cardiac pulmonary resuscitation and lifesaving. This training was to be provided by the school during regular working hours at no cost to the teachers.

At the time the school employed four high school physical education teachers. Two teachers, Royce Duncan and Ed Merit, agreed to obtain the training. Teachers Jo Anne Kettman and Nicolette Overs take refused. The Pleasant Valley Education Association filed this action seeking a declaratory judgment that Kettman and Ov-erstake could not be assigned to the lifesaving training classes, as a matter of law. The matter was submitted to the district court.

The district court found the assignment of the high school physical education teachers to take cardiac pulmonary resuscitation and lifesaving training classes was not so extreme that it was beyond the scope of the school’s powers, contractually or legally. The court held the school could assign its physical education teachers to cardiac pulmonary resuscitation and lifesaving training, but could not require the teacher to actually become certified by the Red Cross if it were demonstrated the certification was beyond the physical capabilities of the teacher. The court found that the best evidence of the physical incapability of any particular teacher would be a good faith attempt by the teacher to complete the training class. Neither Kettman nor Ov-erstake made any attempt to complete the training. 1

The association contends the trial court erred in holding physical education instructors employed by Pleasant Valley School have any contractual obligation to satisfac *896 torily complete any training program in cardiac pulmonary resuscitation, the Red Cross series on water safety, specifically lifesaving, or to become or perform as a lifeguard. The association does not challenge the assignment of a physical education teacher to teach swimming classes.

The trial court held:

The assignment to teach swimming is not an abuse of discretion; becoming certified in CPR and Advanced Life Saving in order to become an effective and safe swimming teacher may be required as a necessary consequence of that assignment. The in-service training ordered does not require duties and responsibilities which go far beyond that which is contemplated in the contract.

The physical education instructors have employment contracts as “teachers,” which are defined and governed by Iowa Code sections 279.13-.19B (1987). The statute, in relevant part, provides:

Contracts with teachers, which for the purpose of this section means all certificated employees of a school district and nurses employed by the board, excluding superintendents, assistant superintendents, principals, and assistant principals, shall be in writing and shall state the number of contract days, the annual compensation to be paid, and any other matters as may be mutually agreed upon. The contract may include employment for a term not exceeding the ensuing school year, except as otherwise authorized.

Iowa Code § 279.13(1). The contracts of the individuals involved do not specifically provide the teachers agree to take training in cardiac pulmonary resuscitation or the Red Cross series on water safety.

We agree with the trial court’s conclusion that attainment of certification for cardiac pulmonary resuscitation and life-saving as a condition of continued employment was not a reasonable expectation of the teachers and the school district when they entered into the employment contracts. The association argues the trial court should have found the assignment was beyond the scope of the school district’s contractual powers. The association argues the training is not consistent with being a teacher or physical education instructor. The association contends the nature of the skills, and the lack of history of teachers involved agreeing to acquire such skills, along with the lack of evidence the teachers ever acquired such skills or performed such duties, show the training was never a part of any contract between the parties.

The school contends the issue is not one of contractual interpretation or state certification requirements, but of the authority of the school to assign work to its teacher employees and the limitations on that authority. The school points to language contained in the teachers’ contracts which provides:

Obligations to employee and employer: By the acceptance of this contract employee agrees to perform assignments as designated by the Board of Education or its designated agents.

The school contends with this language, it has reserved the right to assign work of its choosing to its teachers. We determine the school district has properly characterized the issue.

In Iowa, teachers’ contracts of employment are governed by statute. Gere v. Council Bluffs Community School Dist., 334 N.W.2d 307, 310 (Iowa 1983); McGuffin v. Willow Community School Dist., 182 N.W.2d 165, 168 (Iowa 1970). School districts, as public employers, are given broad powers in dealing with their staffs in order to achieve efficient governmental operations. Gere, 334 N.W.2d at 310. But the power to assign other duties is not unlimited. Id. The decision as to the assignment of teachers to other duties is in the discretion of the school authorities. Gere, 334 N.W.2d at 311.

As a court, we should intervene only where the school district transcends its bounds of discretion. Id. A good faith exercise of discretion will ordinarily not be disturbed. Id.; see also Board of Directors v. Green, 259 Iowa 1260, 1266, 147 N.W.2d 854, 857 (1967). We must give school districts sufficient latitude to *897 manage the district’s affairs. See Board of Educ. v. Great Neck Teachers Ass’n, 92 L.R.R.M.

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Related

Board of Directors of Independent School District v. Green
147 N.W.2d 854 (Supreme Court of Iowa, 1967)
Bunger Ex Rel. Bunger v. Iowa High School Athletic Ass'n
197 N.W.2d 555 (Supreme Court of Iowa, 1972)
Barnett v. Durant Community School District
249 N.W.2d 626 (Supreme Court of Iowa, 1977)
Gere v. Council Bluffs Community School District
334 N.W.2d 307 (Supreme Court of Iowa, 1983)
McFarland v. Board of Education
277 N.W.2d 901 (Supreme Court of Iowa, 1979)
McGuffin v. Willow Community School District
182 N.W.2d 165 (Supreme Court of Iowa, 1970)
Silver Lake Consolidated School District v. Parker
29 N.W.2d 214 (Supreme Court of Iowa, 1947)

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449 N.W.2d 894, 1989 Iowa App. LEXIS 325, 1989 WL 159695, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pleasant-valley-education-assn-v-pleasant-valley-community-school-iowactapp-1989.