Justia Education Law Opinion Summaries

The Supreme Court held that a claim for wrongful termination of employment could not be asserted under the Teacher Tenure Act, Tenn. Code Ann. 49-5-501 to -515, by classifying a tenured teacher's resignation as a constructive discharge rather than a voluntary quit.After Plaintiff, a tenured teacher, quit her teaching position she sued for wrongful termination under the Teacher Tenure Act, alleging that she was constructively discharged. The amended complaint also asserted other claims. The trial court granted summary judgment against Plaintiff. The appellate court reversed the trial court's dismissal of Plaintiff's wrongful discharge claim under the Act, concluding that the doctrine of constructive discharge could give rise to a wrongful termination claim under the Act. The court of appeals otherwise affirmed the trial court. The Supreme Court reversed in part, holding (1) constructive discharge is not applicable to wrongful termination claims under the Act; and (2) the lower courts properly dismissed Plaintiff's remaining claims. View "Lemon v. Williamson County Schools" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing the judgment of the trial court upholding the transfer of a tenured teacher (Plaintiff), working as a school administrator, to a teaching position because Plaintiff did not have an administrator license, holding that Plaintiff failed to prove that the transfer decision was not made in good faith and was arbitrary, capricious, or improperly motivated.In reversing the trial court, the court of appeals held that a regulation required the director of the school system to review the administrative duties Plaintiff had performed in the past in order to determine whether an administrator license was required, and the director's failure to do so rendered his transfer decision arbitrary and capricious. The Supreme Court reversed, holding (1) Plaintiff pointed to no provision in the Teacher Tenure Act that prevents a school system from establishing instructional leadership by school administrators as a priority; (2) consistent with the school system's priorities, Plaintiff was precluded from having administrative duties in the upcoming school year that involved more than fifty percent instructional leadership absent an administrator license; and (3) consequently, the director's failure to consider Plaintiff's past work did not render the transfer decision either arbitrary or capricious. View "Geller v. Henry County Board of Education" on Justia Law