North East Independent School District and Texas Commissioner of Education v. Dehann Riou

Summary

The Texas Supreme Court held that a school district may terminate a teacher's continuing contract for "good cause" under Education Code § 21.156(a) based on evidence that the teacher failed to comply with district policies implementing state and federal grading and testing requirements, without needing specific evidence from similarly situated districts. The court rejected the "good cause per se" exception as having no statutory basis, but found that state and federal laws themselves establish generally recognized professional standards. The teacher preserved her challenge by arguing insufficient evidence at the local level. Substantial evidence supported termination where the teacher failed to record grades or assess student progress for half the school year.

Questions Presented

1. Whether Riou preserved her challenge to the 'good cause per se' exception used by the hearing examiner and Commissioner.
2. Whether the Commissioner's 'good cause per se' exception is permissible under Education Code section 21.156(a).
3. Whether the statute always requires evidence from similarly situated school districts to establish good cause.
4. Whether substantial evidence supports the board's decision to terminate Riou's contract.