Dr. Tracy Smitherman, in her official capacity as Superintendent of the Alabama Department of Youth Services School District; and Robert Duke, Crissy Griffin, Gayla Caddell, and William McDowell, in their official capacities as members of the Alabama Department of Youth Services School District Education Committee v. Derrick Roberts

Summary

The Supreme Court of Alabama considers whether Derrick Roberts attained tenure under the Students First Act based on the date his employment with the Alabama Department of Youth Services became effective. The court holds that his employment became effective when he began required training and began receiving pay and benefits on October 7, 2019, rather than when he accepted the position in September 2019. The court also rejects estoppel principles as a basis for awarding tenure, reverses the Montgomery Circuit Court's judgment, and remands the case.

Holdings

1. Roberts's employment was not effective until October 7, 2019, when he was required to report, perform employment-related work, and began receiving pay and employment benefits. Because his employment was not effective before October 1, 2019, the 2019-2020 school year did not count as a complete school year, and Roberts did not attain tenure under Ala. Code § 16-24C-4(1).
2. Equitable estoppel did not apply because the record did not show that the DYS defendants misrepresented the circumstances under which Roberts could attain tenure, that Roberts relied on incorrect information from them, or that they engaged in conduct inconsistent with their position.

Questions Presented

1. Whether Roberts's employment with DYS was effective before October 1, 2019, under Ala. Code § 16-24C-4(1), such that the 2019-2020 school year counted toward tenure.
2. Whether equitable-estoppel principles barred the DYS defendants from denying that Roberts had attained tenure.

Disposition

reversed_and_remanded