Reynolds v. Douglas School District #51-1 and Douglas Board of Education

Summary

The Supreme Court of South Dakota affirmed summary judgment for Douglas School District in a dispute over the reassignment of a teacher from head high school track coach to middle school assistant track coach. The court held that the circuit court lacked jurisdiction because the superintendent, rather than the school board, had authority under the collective bargaining agreement to make the transfer. It also held that Reynolds had not exhausted the agreement's grievance procedure, which remained pending.

Holdings

1. The circuit court lacked jurisdiction to review a substantive transfer decision by the school board because the collective bargaining agreement vested transfer authority in the superintendent and contained no provision authorizing school-board approval or review of transfers.
2. Reynolds's failure to exhaust the four-step grievance procedure deprived the circuit court of jurisdiction because the grievance remained pending before the Department of Labor when he filed the appeal.

Questions Presented

1. Whether the circuit court had jurisdiction to review the school board's approval of Reynolds's transfer when the collective bargaining agreement vested transfer authority in the superintendent rather than the school board.
2. Whether Reynolds's appeal was jurisdictionally defective because he had not exhausted the collective bargaining agreement's grievance procedure.

Disposition

affirmed