v. Poudre School Dist R-1

2020 COA 27
CourtColorado Court of Appeals
DecidedFebruary 13, 2020
Docket18CA2345, Stanczyk
StatusPublished

This text of 2020 COA 27 (v. Poudre School Dist R-1) is published on Counsel Stack Legal Research, covering Colorado Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
v. Poudre School Dist R-1, 2020 COA 27 (Colo. Ct. App. 2020).

Opinion

The summaries of the Colorado Court of Appeals published opinions constitute no part of the opinion of the division but have been prepared by the division for the convenience of the reader. The summaries may not be cited or relied upon as they are not the official language of the division. Any discrepancy between the language in the summary and in the opinion should be resolved in favor of the language in the opinion.

SUMMARY February 13, 2020

2020COA27

No. 18CA2345, Stanczyk v. Poudre School Dist R-1 — Education — Teacher Employment, Compensation, and Dismissal — Nonprobationary Portability

A division of the court of appeals considers whether a school

district may restrict a teacher’s right under section 22-63-203.5,

C.R.S. 2019, to transfer his or her nonprobationary status from one

school district to another, known as nonprobationary portability.

The division concludes that a school district may not impose

unreasonable restrictions on a teacher’s exercise of the right to

nonprobationary portability. If a teacher complies with the

statutory requirements for nonprobationary portability, the hiring

school district must grant the teacher nonprobationary status. In

this case, the defendants’ restrictions on a teacher’s right to

exercise the right to nonprobationary portability were unreasonable because they allowed defendants to decide unilaterally whether the

teacher could obtain nonprobationary status.

Because the defendants unreasonably restricted the teacher’s

ability to exercise the statutory right to nonprobationary portability,

the district court erred in awarding summary judgment in favor of

the defendants. The division holds that the plaintiffs are entitled to

summary judgment on their claim that the defendants’ restrictions

violated the teacher’s right to nonprobationary portability and

remands for further proceedings on the plaintiffs’ remaining claims. COLORADO COURT OF APPEALS 2020COA27

Court of Appeals No. 18CA2345 Larimer County District Court No. 17CV30480 Honorable Gregory M. Lammons, Judge

Patricia Stanczyk and Poudre Education Association,

Plaintiffs-Appellants,

v.

Poudre School District R-1 and Poudre School District R-1 Board of Education,

Defendants-Appellees.

JUDGMENT AFFIRMED IN PART, REVERSED IN PART, AND CASE REMANDED WITH DIRECTIONS

Division III Opinion by JUDGE LIPINSKY Webb and Dunn, JJ., concur

Announced February 13, 2020

Brooke Copass, Rory Herington, Charles Kaiser, Denver, Colorado, for Plaintiffs-Appellants

Semple, Farrington, Everall, & Case, P.C., M. Brent Case, Jonathan Fero, Mary Barham Gray, Denver, Colorado, for Defendants-Appellees

Philip J. Weiser, Attorney General, Julie C. Tolleson, First Assistant Attorney General, Jenna Zerylnick, Assistant Attorney General, Denver, Colorado, for Amicus Curiae Patricia Stanczyk and Poudre Education Association ¶1 In 2010, the Colorado General Assembly enacted sweeping

changes to the state’s teacher evaluation and compensation system

that, for the first time, tied a teacher’s nonprobationary status to

his or her performance. As with the prior concept of tenure, a

teacher who achieves nonprobationary status receives job

protections not available to other teachers, including protection

against unreasonable dismissal and hearing rights.

¶2 The General Assembly further provided that a

nonprobationary teacher has the right to transfer his or her

nonprobationary status from one school district to another by

submitting specified evidence of his or her effectiveness as an

educator. This statutory right is known as nonprobationary

portability.

¶3 In this case, we consider the narrow question whether a school

district may restrict a teacher’s ability to exercise the right of

nonprobationary portability through use of a job application and

form employment contract that require the teacher to relinquish the

right to nonprobationary portability as a condition of employment.

(We refer to such a job application and employment agreement as

the Restrictions.)

1 ¶4 Plaintiffs, Patricia Stanczyk and Poudre Education Association

(Association), allege that defendants, Poudre School District R-1

and Poudre School District R-1 Board of Education (the Poudre

Defendants), unlawfully stymied Stanczyk’s and similarly situated

teachers’ exercise of their right to nonprobationary portability

through use of the Restrictions. The Poudre Defendants deny that

their application form and form employment agreement are

unlawful. In the alternative, they assert that, under their

prerogative of local control, school districts may disregard the

statutory mandate of nonprobationary portability.

¶5 We affirm in part and reverse in part:

• We affirm the district court’s award of summary

judgment to the Poudre Defendants on Stanczyk and the

Association’s claim for violation of article XI, section 2 of

the Colorado Constitution.

judgment to the Poudre Defendants on Stanczyk’s claims

for breach of statutory contract, violation of due process

rights, and mandamus relief.

2 • We reverse the district court’s award of summary

Association’s claims for declaratory judgment.

• We hold that the Association is entitled to summary

judgment on both the declaratory judgment claims

because the Poudre Defendants’ use of the Restrictions is

unlawful and, under the nonprobationary portability

statute, the Poudre Defendants must provide a qualifying

teacher with nonprobationary status upon the teacher’s

compliance with the statutory requirements for

nonprobationary portability.

• We hold that Stanczyk is entitled to summary judgment

on the claim that the Poudre Defendants’ use of the

Restrictions unlawfully deprived her of the right to

nonprobationary portability, but that disputed issues of

material fact preclude the entry of summary judgment to

any party on the claim for a declaratory judgment that

she is entitled to nonprobationary status.

• We remand for further proceedings consistent with this

opinion.

3 ¶6 First, we discuss the history of the statute granting teachers

the right to nonprobationary portability. Second, we summarize the

factual and procedural background of the case. Third, we

determine whether Stanczyk and the Association have standing to

assert the claims they pleaded against the Poudre Defendants.

Fourth, we explain the standard of review applicable to this case.

Fifth, we consider the district court’s grant of summary judgment to

the Poudre Defendants on the Association and Stanczyk’s claims for

declaratory judgment. Sixth, we consider the Association and

Stanczyk’s remaining claims.

I. The History of the Nonprobationary Portability Statute

A. Nonprobationary Status Replaced Tenure in Colorado

¶7 Before 1990, a teacher received tenure if he or she was

continuously employed in the same school district for three

academic years. § 22-63-112(1), C.R.S. 1989. Once tenured, a

teacher could be dismissed only for certain, enumerated reasons

relating to cause. § 22-63-116, C.R.S. 1989. Thus, with limited

exceptions, a tenured teacher was “entitled to a position of

employment as a teacher.” § 22-63-115, C.R.S. 1989; see Johnson

v. Sch. Dist. No. 1, 2018 CO 17, ¶ 3, 413 P.3d 711, 713.

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2020 COA 27, Counsel Stack Legal Research, https://law.counselstack.com/opinion/v-poudre-school-dist-r-1-coloctapp-2020.