Scribner v. Bd. of Educ. of U.S.D. No. 492

Summary

The Kansas Supreme Court upheld 2014 amendments to the Kansas Teacher Due Process Act that eliminated statutory requirements for school districts to state reasons for nonrenewal of elementary and secondary teachers’ contracts and to provide a due process hearing. The court held that the amendments did not violate federal or state due process protections, including because the legislative process generally supplies the process due when legislation alters statutory property interests. The court also held that the amendments did not cause a breach of the teachers’ employment contracts.

Holdings

1. The 2014 amendments did not violate the Due Process Clause of the Fourteenth Amendment or Sections 1 and 2 of the Kansas Constitution Bill of Rights. Even assuming the teachers possessed protected property interests, the Legislature could alter or eliminate the statutory entitlement, and the legislative process generally supplied all process constitutionally due for legislation affecting a broad class.
2. The Board did not breach the teachers' contracts because it complied with the statutory requirements in effect in May 2015, and the teachers did not base their claim on any express contractual term independent of the amended statute.

Questions Presented

1. Whether the 2014 amendments to the Kansas Teacher Due Process Act deprived the teachers of vested property rights without due process under the Fourteenth Amendment or Sections 1 and 2 of the Kansas Constitution Bill of Rights.
2. Whether the legislative process used to enact the amendments was so defective that it violated procedural due process.
3. Whether the Board breached the teachers' continuing-contract rights by not employing them for the 2015-2016 school year and thereafter.

Disposition

affirmed