Sapphire v. Board of Education

96 A.D.2d 1033, 466 N.Y.S.2d 439, 1983 N.Y. App. Div. LEXIS 19694

This text of 96 A.D.2d 1033 (Sapphire v. Board of Education) is published on Counsel Stack Legal Research, covering Appellate Division of the Supreme Court of the State of New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Sapphire v. Board of Education, 96 A.D.2d 1033, 466 N.Y.S.2d 439, 1983 N.Y. App. Div. LEXIS 19694 (N.Y. Ct. App. 1983).

Opinions

— In a CPLR article 78 proceeding, the Board of Education, Hastings Union Free School District, appeals from a judgment of the Supreme Court, Westchester County (Slifkin, J.), dated August 9, 1982, which, inter alia, directed it to reinstate petitioner' as a tenured guidance counselor with back salary, less certain deductions. Judgment affirmed, with costs. Appellant board of education dismissed petitioner from its employ on June 30, 1980, asserting that she was a probationary employee. Before the Supreme Court, appellant conceded that if the tenure provisions of the rules of the Board of Regents (8 NYCRR part 30) were applicable to teachers who acquired tenure prior to their effective date, then petitioner had acquired tenure by estoppel. Inasmuch as appellant disputes on appeal the facts it purportedly conceded before the Supreme Court, this court will make its own findings of fact. Petitioner seeks reinstatement in appellant’s school district as a tenured guidance counselor, together with back salary and other emoluments of employment, on the ground that her dismissal was unlawful. Her petition alleged that she had been, in appellant’s word, “reassign[ed]” by its resolution of October 24,1977 from her full-time elementary teaching duties to half-time elementary teaching duties and half-time guidance counselor duties, effective November 1, 1977. Petitioner lost her elementary teaching position upon a reduction in teaching positions in May, 1978, effective June 30, 1978. By resolution of the board of education on September 5, 1978, petitioner was appointed as a guidance counselor for the 1978-1979 school year, and she commenced serving as such, full time, in September, 1978. Petitioner was summarily dismissed from her position effective June 30, 1980 following a February 29, 1980 letter from the superintendent of schools, which informed her that he would not recommend her appointment to tenure as a guidance counselor and, therefore, that her employment as a guidance counselor would terminate on June 30, 1980. Petitioner claimed tenure by estoppel because she had already served as a guidance counselor for two years, measured from November 1, 1977. Appellant’s position was that petitioner’s 1977-1978 half-time guidance counseling service was that of a substitute rather than a probationer, and therefore could not be taken into account in determining the length of her probationary service within the school district. The record supports petitioner’s characterization of her November 1,1977 appointment as being probationary. Appellant argues that petitioner was hired on that date as a part-time substitute for the regular, full-time guidance counselor, who had been granted maternity leave for the 1976-1977 school year, whose leave was extended for the 1977-1978 school year. According to the superintendent of schools, a temporary full-time replacement was hired as a substitute for the 1976-1977 school year and was reappointed for the 1977-1978 school year. The documentary evidence offered in support of these facts, however, shows that the teacher hired for the 1976-1977 school year “as a one (1) year replacement” was formally appointed by [1034]*1034appellant’s resolution of September 13, 1976 to a three-year “probationary service” position, but resigned at the end of the first year. It was at this point, according to the superintendent of schools, that petitioner asked that she be allowed to “fill the opening on a half-time basis while maintaining her seniority and tenure rights in the elementary area by continuing to teach a fourth grade class on a half-time basis”. Therefore, according to him, the regular guidance counselor returned from maternity leave and undertook her duties on a half-time basis while petitioner undertook the remainder of the guidance counseling duties on a substitute basis. The record, however, shows that by a resolution dated October 10, 1977, appellant approved the regular guidance counselor’s return from maternity leave on a part-time basis with a comment “that the other 14 Guidance would be provided at Hillside [Elementary School, where petitioner worked] by a Hillside staff member once scheduling is rearranged”. By letter of October 19, 1977, parents of children in petitioner’s fourth grade class expressed concern about her pending reassignment from that class to a half-time kindergarten, half-time guidance counseling position. They suggested she either assume half-time guidance counseling in conjunction with half-time teaching of her fourth graders, or maintain her present full-time teaching and defer guidance counseling for a year, during which time the board could use a per diem substitute. Concurring with the parents, the school’s principal recommended the first alternative to the superintendent of schools by letter of the same date, noting that petitioner and the teacher with whom she would share teaching duties were both “willing to put forth the extra time necessary that is above the contractual expectations to make this work.” The principal added that this arrangement would permit petitioner “to advance in her career of guidance and to be placed as a part time guidance counselor at Hillside.” The superintendent of schools informed the board, by letter dated October 21,1977, that following a second meeting with the parents on October 20,1977, his recommendation was for petitioner to be appointed half-time to teaching her fourth-grade class and half-time to guidance counseling upon the regular guidance counselor’s return from maternity leave to work half-time at the district’s high school. The minutes of the appellant’s October 24, 1977 meeting “approve the assignment of [petitioner] as Vz time Elementary Guidance Counselor and Vz time Elementary teacher, Column III Step 12, effective Nov. 1, 1977”. This item was reflected in the minutes under the heading, “personnel: — Hillside Guidance.” The next item on the agenda, under the heading, “personnel: — Substitutes”, dealt with the appointment of two persons to the “Substitute Teacher List” for the school year on a per diem basis. By letter dated October 25, 1977, the superintendent of schools informed petitioner that appellant had approved her “reassignment” as a half-time teacher and half-time guidance counselor. The term substitute does not appear in its test. By letter dated May 25, 1978 to the superintendent of schools, petitioner noted that her elementary teaching position had been eliminated and asked that she be considered for a position with the district’s guidance counseling staff at the high school because of an opening created there by the retirement of a guidance counselor (who was not the regular guidance counselor bn leave or the replacement). The record next reflects that by resolution of September 5, 1978, appellant appointed petitioner as a guidance counselor for the 1978-1979 school year, column III, step 13, on probationary service for two years, until June 30, 1980, serving half time at Hillside and half time at another school. Appellant then appointed another person as full-time high school guidance counselor to replace the regular counselor on leave, and expressly characterized this appointment as one to “substitute service”. By letter dated September 6,1978, the superintendent of schools informed petitioner that appellant had “formally approved” her ap[1035]*1035pointment. Petitioner pointed out in her papers before the Supreme Court that at no point prior to appellant’s interposing its answer had anyone characterized her 1977-1978 guidance counseling services as substitute rather than probationary in nature. She further alleged that as a full-time tenured employee of the district, she would have refused the reassignment from full-time teaching had the guidance counseling position been on a substitute basis.

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Bluebook (online)
96 A.D.2d 1033, 466 N.Y.S.2d 439, 1983 N.Y. App. Div. LEXIS 19694, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sapphire-v-board-of-education-nyappdiv-1983.