Pratt v. Bd. of Ed. of Uintah Cty. Sch. Dist.

564 P.2d 294, 1977 Utah LEXIS 1131
CourtUtah Supreme Court
DecidedMay 4, 1977
Docket14469
StatusPublished
Cited by21 cases

This text of 564 P.2d 294 (Pratt v. Bd. of Ed. of Uintah Cty. Sch. Dist.) is published on Counsel Stack Legal Research, covering Utah Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Pratt v. Bd. of Ed. of Uintah Cty. Sch. Dist., 564 P.2d 294, 1977 Utah LEXIS 1131 (Utah 1977).

Opinions

MAUGHAN, Justice:

Plaintiff brought this action against the Board of Education of the Uintah County School District, hereafter defendant. Plaintiff sought damages for breach of contract, and reinstatement to his teaching position. His prayer for relief was granted. We affirm. Costs to plaintiff. All statutory references are to U.C.A.1953.

Plaintiff was employed by defendant as a tenured teacher at the Whiterocks School. He had taught there for a period of fourteen years. He was informed in the spring of 1973 that Whiterocks was being closed, and he must make a written application, if he desired to continue employment with defendant. In a letter, dated April 1, 1973, plaintiff applied for a teaching position at the new school, which was being constructed to replace Whiterocks. The superintendent, employed by defendant, spoke with plaintiff and expressed concern about plaintiff’s experience with team teaching. This technique was to be used at the new school. Precisely what occurred at this meeting became an issue of fact, which was resolved by the jury adversely to defendant.

Plaintiff was not given a contract for the 1973-1974 school year. After exhausting his administrative remedies, pursuant to the Utah Orderly School Termination Procedures Act, Chapter 51, Title 53, as enacted 1973, plaintiff filed his action.

His claim for breach of contract was predicated on a policy of defendant, incorporated by reference into plaintiff’s employment contract. Under this policy, the board had the right, when it was necessary, to decrease the number of tenured teachers. However, a tenured employee was not to be dismissed; while a non-tenured employee was retained, or employed, to render a service the tenured employee was certificated and competent to render.

There is no dispute between the parties that plaintiff was a tenured teacher and that non-tenured teachers were employed by the district to perform services, plaintiff was qualified to render. Defendant’s sole defense to the asserted breach was that plaintiff had voluntarily resigned. This issue was submitted to the jury which by special verdict found plaintiff had not resigned.

Defendant asserted unsuccessfully in a motion to dismiss and a motion for summary judgment that plaintiff’s claim was barred for failure to comply with the notice provision of Sec. 63-30-13, as enacted 1965, of the Governmental Immunity Act. The trial court ruled the act did not apply to this case. Defendant contends such a ruling was erroneous.

Under defendant’s theory, which it asserted before the trial court, timely compliance with Sec. 63-30-13, required plaintiff to file his notice of claim of breach of contract, within ninety days after the superintendent informed him his contract was terminated. The parties disagreed as to whether the date plaintiff was so notified was April 27 or May 11, 1973. Defendant’s position was plaintiff did not file a notice of his claim, which complied with the requirements set forth in Scarborough v. Granite School District,1 until September 24, 1973. Since this was more than ninety days after the alleged oral notice of termination, even if it were assumed to have occurred on May 11, 1973 as claimed by plaintiff, defendant asserted plaintiff’s claim was barred as a matter of law.

The trial court did not err in its ruling as applied to the facts of this case. In making this determination the court had before it the pretrial order with a statement of un-controverted facts. They were:

[296]*296On June 27, 1978, a letter was received by defendant from the Uintah Education Association requesting a hearing on behalf of the plaintiff regarding his termination. On August 14, 1973, a second request for hearing was received from Mr. Pratt personally, and the hearing was then held on September 5, 1973. At the hearing, Mr. Pratt was again informed that he was terminated and that there were no new openings. On September 24, 1973, the plaintiff sent a letter to the Board demanding reinstatement and claiming wrongful termination. The Board responded to plaintiff’s letter with another letter dated September 25, 1973, and again gave its reasons for not renewing plaintiff’s teaching contract. No other or further correspondence or notices were received by defendant from the plaintiff until December 14, 1973, when plaintiff’s attorney wrote to the Uintah County School District demanding that his client be reinstated and that he be compensated for wages he would have received from September to December of 1973. The Uintah School District declined to take affirmative action on the plaintiff’s demand letter inasmuch as they felt the plaintiff had been properly terminated and that such termination had been in accordance with the plaintiff’s expressed intentions as communicated to Superintendent Evans. Plaintiff disagreed and this action was filed on April 19, 1974.

Plaintiff, under defendant’s personnel policies, had a reasonable expectation of employment in successive years. Under the Utah Orderly School Termination Procedures Act, supra, plaintiff was entitled to a fair hearing, q. v. Sec. 53-51-5(1). If the trial court had sustained defendant’s assertion, the ninety-day period of Sec. 63-30-13 would have passed prior to the hearing defendant was required to give plaintiff pursuant to Sec. 53-51-5(1). Section 53-51-2, provides:

The purpose of this act is to require school districts to adopt orderly termination procedures and to specify standards of due process and causes for termination.

To effect these purposes the legislature provided for an administrative hearing. Under the particular facts of this case, the action of defendant constituted both an improper termination and a breach of contract. There was a prescribed administrative remedy for the threatened injury to plaintiff, which he timely sought. Until defendant held the hearing and issued its written determination on September 25, 1973, plaintiff’s claim for a breach of contract did not mature. The trial court properly ruled that plaintiff’s failure to file a notice of claim, within ninety days after May 11, 1973, did not bar his claim.

Defendant contends the trial court erred in ordering plaintiff’s reinstatement. Defendant characterizes the order as one for specific performance of an employment contract, and invokes the doctrine of mutuality of remedies.2 The effect of the order of the court was to enforce a negative covenant, viz., defendant would not dismiss a tenured teacher and employ or retain a non-tenured teacher. The order of the court nullified the dismissal of plaintiff.

. there is support for the rule that breach of a negative covenant should be enjoined even though its effect would be indirectly to enforce the affirmative promise to employ, which type of promise, standing alone, will not be specifically enforced as noted above.3
The case, however, remains where the negative performance of the defendant must precede the performance of the plaintiff. There seems little suggestion that the injunction would be denied on the ground of lack of mutuality of remedy-
The defense of allowing the injunction must therefore be that its allowance will probably result in the full performance of [297]

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Pratt v. Bd. of Ed. of Uintah Cty. Sch. Dist.
564 P.2d 294 (Utah Supreme Court, 1977)

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Bluebook (online)
564 P.2d 294, 1977 Utah LEXIS 1131, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pratt-v-bd-of-ed-of-uintah-cty-sch-dist-utah-1977.