Foreman School District No. 25 v. Steele

Summary

The Supreme Court of Arkansas held that a school district’s attempted nonrenewal of a probationary principal’s contract was void because the district failed to strictly comply with the Arkansas Teacher Fair Dismissal Act’s requirement that the hearing occur within ten days of the teacher’s request. The contract therefore automatically renewed, and the district breached the renewed contract by failing to reinstate the principal or pay his salary. The court affirmed summary judgment awarding the contract salary less mitigation wages.

Holdings

1. The district's failure to hold the required hearing within ten days of Steele's written request, absent a written mutual agreement postponing the hearing, violated the Act's strict-compliance requirement.
2. The district's attempted nonrenewal was void, and Steele's contract automatically renewed on May 1, 1994 under the terms of the original contract.
3. Steele's action was a common-law breach-of-contract claim properly filed in circuit court, not an appeal from a school board's nonrenewal decision.
4. Steele established the existence of a renewed contract and the district's breach by failing to reinstate him or pay his salary, and his claim was timely under the five-year statute of limitations for written contracts.

Questions Presented

1. Whether the school district's failure to hold Steele's nonrenewal hearing within ten days of his request, without a written agreement postponing the hearing, rendered the attempted nonrenewal void under the Teacher Fair Dismissal Act.
2. Whether the attempted nonrenewal's invalidity automatically renewed Steele's employment contract for the 1994–1995 school year.
3. Whether Steele could pursue a common-law breach-of-contract claim in circuit court rather than appeal a school board nonrenewal decision under the Teacher Fair Dismissal Act.
4. Whether summary judgment for Steele was proper on the existence and breach of the renewed employment contract.

Disposition

affirmed