State ex rel. Smith v. Etheridge

1992 Ohio 13, 65 Ohio St. 3d 501
CourtOhio Supreme Court
DecidedDecember 15, 1992
Docket1991-2483
StatusPublished
Cited by24 cases

This text of 1992 Ohio 13 (State ex rel. Smith v. Etheridge) is published on Counsel Stack Legal Research, covering Ohio Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State ex rel. Smith v. Etheridge, 1992 Ohio 13, 65 Ohio St. 3d 501 (Ohio 1992).

Opinions

A. William Sweeney, J.

I

In case No. 91-2483, we are asked whether R.C. 3319.02 requires a board of education to vote on the nonrenewal of an administrator’s actual position before the board can nonrenew his or her contract. In our view, the statute requires that we answer this issue in the affirmative and, therefore, we reverse the judgment of the court of appeals below.

R.C. 3319.02(C) directs a board of education to “ * * * execute a written contract of employment with each assistant superintendent, principal, assistant principal, and other administrator it employs or reemploys. * * * ” This provision also deems an administrator reemployed if the board does not notify him or her in writing of its intention not to reemploy such person on or before March 31 of the year in which the contract expires.

In State ex rel. Brennan v. Vinton Cty. Local Bd. of Edn. (1985), 18 Ohio St.3d 208, 18 OBR 271, 480 N.E.2d 476, and State ex rel. Luckey v. Etheridge (1992), 62 Ohio St.3d 404, 406, 583 N.E.2d 960, 962, we held that R.C. 3319.02 is a remedial statute that must be liberally construed in favor of administrators.

With this in mind, we first note that R.C. 3319.02 required the board to issue appellant Smith a written contract for the position of principal, but the board either failed or refused to issue a correct contract for the position to which Smith was promoted. The record indicates that the board’s personnel office threatened to withhold Smith’s paycheck unless and until he signed the contract which listed his former position as a senior high assistant principal. Subsequently, Smith signed the senior high assistant principal’s contract, but served as the principal of Monroe Middle School. Thereafter, the board notified Smith that he was nonrenewed for a senior high assistant principal’s position that he did not then hold. Under these circumstances, and given the [505]*505remedial nature of R.C. 3319.02, we believe that since the board voted not to renew Smith’s contract for a position he did not hold, he was automatically renewed, by operation of the statute, for the position he actually did hold, which was principal of the middle school.

Contrary to the reasoning of the court of appeals below and appellees, we find R.C. 3319.08 to be inapplicable to Smith’s contract status. Ordinarily, R.C. 3319.08 will validate a contract where the board does not put such contract in writing but the employee performs his or her duties as though a written contract were present. However, in this case, Smith not only did not have a written contract for the principal’s position, he was not provided sufficient or timely notice that his position as principal was to be nonrenewed. Under a clear reading of R.C. 3319.08, the board is not relieved of the requirement to provide a written contract or to provide an administrator with sufficient notice of nonrenewal.

Accordingly, we reverse the judgment of the court of appeals in case No. 91-2483, and remand the cause to that court to issue the requested writ of mandamus to validate Smith’s administrative contract as a principal, as well as grant him lost wages and any other appropriate relief.

II

Turning our focus to case No. 91-2484, we note that in Luckey, supra, this court held in the syllabus:

“Pursuant to R.C. 3319.02(C), a board of education must provide written notice of its intention not to reemploy an assistant superintendent, principal, assistant principal or other administrator on or before the last day of March of the year in which the contract of employment expires.”

A careful review of the record indicates that none of the appellants herein, except Cauley and Durbin, was given sufficient notice of nonrenewal of his or her administrative contract pursuant to the syllabus law announced in Luckey, supra.

Accordingly, we reverse the judgment of the court of appeals with respect to appellants Brown, Buxton, Payne, Pollock, Saunders, Smith, Taracko, Wehner, White and Woodford, and remand the cause to that court to issue the requested writ of mandamus which entitles these appellants to a renewal of their respective administrative contracts, lost wages and any other relief deemed appropriate.

Ill

Given our disposition above, the only remaining issues of relevance in these appeals are as follows: (1) whether R.C. 3319.02 grants a public school [506]*506administrator the right to be advised of the reasons for his or her recommended nonrenewal; and (2) whether R.C. 3319.02 requires a board of education to base a decision to nonrenew an administrative contract on the administrator’s evaluation. For the reasons that follow we answer both of these questions in the negative and, therefore, affirm the judgment of the court of appeals in case No. 91-2484 on these particular issues.

A

With respect to the issue of whether R.C. 3319.02 grants administrators the right to be advised of the reasons for nonrenewal of their administrative contracts, we find that under R.C. 3319.02(C), administrators are to “be employed or reemployed in accordance with nominations of the superintendent of schools of the district except that a city * * * board of education, by a three-fourths vote, may reemploy any assistant [administrator] whom the superintendent refuses to nominate after considering two nominees for the position. * * *”

Furthermore, an administrator is deemed reemployed unless the board, on or before March 31 in the last year of the contract, gives him or her written notice of nonrenewal. In addition, R.C. 3319.02(D) states in part:

“Before taking action to renew or nonrenew the contract of an assistant superintendent, principal, assistant principal, or other administrator under this section and prior to the last day of March of the year in which such employee’s contract expires, the board of education shall notify each such employee of the date that his contract expires and that he may request a meeting with the board. Upon request by such an employee, the board shall grant the employee a meeting in executive session to discuss the reasons for considering renewal or nonrenewal of his contract.”

Appellants argue that R.C. 3319.02 requires a board of education to provide an administrator with reasons for its intention to nonrenew the administrator’s contract and to discuss these reasons at the administrator’s meeting with the board. Appellees deny this but argue, alternatively, that the board satisfies any such requirement if, as here, the administrator knows that the superintendent has recommended nonrenewal, since that recommendation is the “reason” for the board’s considering nonrenewal.

In State ex rel. Saltsman v. Burton (1950), 154 Ohio St. 262, 267, 43 O.O. 136, 138, 95 N.E.2d 377, 379, this court held that a superintendent is not entitled to a continuing contract as a superintendent merely because he had tenure as a teacher, and we explained the practical and statutory differences between an administrator and a teacher. According to our decision in Salts-man, teacher tenure Acts protect qualified teachers and prevent their arbi[507]*507trary dismissal.

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

Related

Cynthia Hopkins v. Canton City Board of Education
477 F. App'x 349 (Sixth Circuit, 2012)
E. Canton Edn. Assn. v. McIntosh
1999 Ohio 282 (Ohio Supreme Court, 1999)
East Canton Education Ass'n v. McIntosh
85 Ohio St. 3d 465 (Ohio Supreme Court, 1999)
State ex rel. McGinty v. Cleveland City School District Board
690 N.E.2d 1273 (Ohio Supreme Court, 1998)
Naylor v. Cardinal Local School Dist. Bd. of Edn.
1994 Ohio 22 (Ohio Supreme Court, 1994)
Naylor v. Cardinal Local School District Board of Education
630 N.E.2d 725 (Ohio Supreme Court, 1994)
State ex rel. Zonders v. Delaware County Board of Elections
630 N.E.2d 313 (Ohio Supreme Court, 1994)

Cite This Page — Counsel Stack

Bluebook (online)
1992 Ohio 13, 65 Ohio St. 3d 501, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-ex-rel-smith-v-etheridge-ohio-1992.