Lawrence County School District v. Peggy Bowden

Summary

The Supreme Court of Mississippi held that the chancery court erred by sua sponte declaring the Education Employment Procedures Law unconstitutional and dismissing Peggy Bowden’s appeal from a school board decision not to renew her employment contract. The court held that appeals from school board decisions fall within the chancery court’s jurisdiction over matters in equity, declared the statutory scheme constitutional, and reversed and remanded for limited judicial review.

Holdings

1. A court may not consider the constitutionality of a statute unless the issue is specifically pleaded; the chancery court exceeded its powers by raising and deciding the statute's constitutionality sua sponte.
2. The Education Employment Procedures Law is constitutional, and chancery courts have jurisdiction to review final school board decisions involving aggrieved school employees.

Questions Presented

1. Whether the chancery court erred by sua sponte considering and deciding the constitutionality of the Education Employment Procedures Law when neither party pleaded the issue.
2. Whether Mississippi Code sections 37-9-101 to 37-9-113 unconstitutionally confer jurisdiction on chancery courts to review final school board decisions concerning school employees.

Disposition

reversed_and_remanded