Federal Court Dismisses Administrator’s Constitutional Arguments on Validity of Contract Due to Lack of Contract Goals
The United States District Court for the Northern District of Illinois, Eastern Division, recently decided a case where a Superintendent claimed that his 14th Amendment due process rights had been violated when he was dismissed after one year of service without a hearing. 42 U.S.C. § 1983 states that any person who deprives another person of rights (or a property interest) is liable in a court of law for damages he or she causes. Courts have stated that continued employment is a protected property interest. The question in this case was whether the Superintendent had that protected property interest in the form of a valid multi-year contract. Wynn v. Board of Education of School District No. 159, 2011 WL 1882454 (2011).
In a narrow holding addressing only the Superintendent’s constitutional claims, the court held that the Superintendent did not have a valid contract, because the Illinois School Code requires all superintendent contracts that last more than one year to include performance goals and indicators. In this instance, the contract did not have any performance goals when it was adopted and contained language that “goals shall be established by the mutual agreement of the Superintendent and the Board . . . no later than October 1, 2008.” The court held that because the contract was entered on July 1, 2008, and there were no specific performance goals at the adoption of the contract, the contract did not comply with the specific requirements of the Illinois School Code regarding multi-year contracts and, therefore, could only be valid for one year. “The plain language of the statute requires that a multi-year, superintendent agreement include the goals and indicators of student performance at the time of the agreement’s execution.” Because the contract was not in compliance with the Illinois School Code when executed, Superintendent Wynn did not have a property interest in his continued employment, and, therefore, there could be no violation of the 14th Amendment. Further, he had no property interest based on an implied contract because contracts that are contrary to statutes are unenforceable.
This decision by the District Court looked solely at the federal constitutional claims that the Superintendent brought before the court. The court did not address any state law claims that the Superintendent brought.
This decision is a reminder for school districts to carefully review employee contracts and confirm that the contracts conform to Illinois and federal law. Because the state law claims remain unsettled in this case, and because those claims may ultimately be dispositive on the merits of this case, school districts should be cautious about using this decision as a basis for taking action.
Read the rest of our Fall 2011 Newsletter HERE.