Randy Arnwine v. Union County Board of Education, et al.

Summary

The Tennessee Supreme Court held that a local school board lacked statutory authority to enter into a four-year employment contract with an assistant superintendent. Applying Dillon’s Rule and the education statutes governing teacher employment, the court classified the assistant superintendent as a teacher and concluded that the statutes did not authorize multi-year contracts for that position. The court affirmed the Court of Appeals’ judgment invalidating the contract.

Holdings

1. An assistant superintendent fits within the statutory category of a supervisor and therefore is a teacher for purposes of the Tennessee education statutes governing employment contracts.
2. A local school board lacks statutory authority to enter into a multiyear employment contract with an assistant superintendent because an assistant superintendent is a teacher and the education statutes do not expressly or impliedly authorize multiyear teacher contracts.
3. Tennessee Code Annotated section 7-51-903 does not authorize a school board to enter into a multiyear employment contract with a teacher or assistant superintendent because the specific education-employment statutes control over the general municipal contracting statute.

Questions Presented

1. Whether a local school board has statutory authority to enter into a multiyear employment contract with an assistant superintendent.
2. Whether Tennessee Code Annotated section 7-51-903, which generally authorizes municipalities to enter into long-term contracts, authorizes a school board to enter into a multiyear employment contract with an assistant superintendent.

Disposition

affirmed