Davis v. Greenwood School District 50, 365 S.C. 629

Summary

The Supreme Court of South Carolina affirmed summary judgment for Greenwood School District 50 in a dispute over financial incentives for teachers who obtained national board certification. The court held that the district was not bound by the ten-percent incentive as a contract, that the teachers could not establish reasonable reliance for promissory estoppel, and that the school board did not breach a fiduciary duty. The court also held that the district complied with the South Carolina Payment of Wages Act by providing timely notice of the incentive change.

Holdings

1. The District was not liable for breach of contract because the incentive was subject to the Board's annual approval and, in any event, the alleged agreement was not in writing or signed as required by the Statute of Frauds.
2. The teachers could not recover under promissory estoppel because their reliance on the superintendent's statement was unreasonable when they had been told that the incentive was subject to annual Board approval.
3. The District did not breach its fiduciary duty because the Board's decision to replace the percentage-based incentive with a $3,000 payment was within its discretion and was not shown to involve bad faith, malice, corruption, or a clear abuse of power.
4. The District did not violate the Act because it notified the teachers of the wage-policy change well in advance of the statutory seven-day requirement.

Questions Presented

1. Whether summary judgment was properly granted on the teachers' breach-of-contract claim.
2. Whether the teachers established promissory estoppel based on statements that they would receive a ten-percent salary increase for national board certification.
3. Whether the school district breached a fiduciary duty by changing the incentive from a ten-percent salary increase to a $3,000 annual payment.
4. Whether the District violated the South Carolina Payment of Wages Act by changing the incentive policy.

Disposition

affirmed