Using the Internet, research Knox v. Board of School Directors of Susquenita School District.
Study the following outline of Knox v. Board of School Directors of Susquenita School District, which illustrates outlining a legal case. See also the Sample Outline for Legal Cases page in the Course Materials section.
Case name and citation
Knox v. Board of School Directors of Susquenita School District, 585 Pa. 171, 888 A.2d 640 (PA 2005)
Employee Homer Knox, worked for the Suquenita School District starting September 15, 1987 as a business administrator, and is classified a public employee. He did not have a written contract of employment. He was originally hired for a three year term. The school district claims that thereafter he was hired for successive one year terms and Knox claims he was then hired for an indefinite term.
He was terminated from his employment, without a hearing, as of June 30 1997, by letter dated June 11, 1997. The position of business manager was ended by the school board May 4, 1998. From July 1, 1997 until September of 2000, the duties of business manager were performed by an outside consultant.
Stage of legal process
The Supreme Court of Pennsylvania is hearing an appeal from The Commonwealth Court of Pennsylvania.
What happened in prior case stages
Knox sought a hearing before the school board and was denied. He filed a petition for review of the school board’s actions in the Court of Common Pleas, the trial court. The trial court determined that Knox was entitled to a hearing before the school board. The parties filed a joint request for reconsideration and the trial court made findings that Knox had a right to benefits from termination until May 4, 1998. The parties cross appealed to the Commonwealth Court, which reversed in an unpublished decision. Knox appealed to the Supreme Court of Pennsylvania.
Does Pennsylvania Statute section 10-1089(c) apply to give removal protections to a business administrator of a school district employed for a term of years without a contract and who is then terminated without cause?
Does a Pennsylvania public school business administrator without a contract have a property interest in his employment after the original term for employment has expired?
Pennsylvania Statute section 10-1089(c) does apply to give removal protections to a business administrator of a school district employed for a term of years without a contract and who is then terminated without cause.
The second legal issue was referred back to the Commonwealth court as neither accepted for review nor briefed. However, the court explained rules of law in dicta and indicated that a business administrator only has a property interest and a right to a hearing for the period of time covered by the term of employment. The statute 10-1089(c) does not give the administrator tenure or a right to continued employment or any hearing rights after the term of employment. That term is still disputed on the facts.
Vacated and Remanded to the Commonwealth Court for further consideration.
1. Why was it resolved that way?
Statutory construction showed that the Pennsylvania legislature did extend protections to all business administrators, not just those with a contract. Those protections afforded a hearing and a need for specific allegations of cause. The second issue was not fully decided, because the facts were not fully found and decided by the lower courts and that part of the case was not briefed or accepted for review. Nevertheless, the court indicated the rules of law involved.
2. How did the court apply or reconcile the legal principles involved?
The court showed that the language used in the statute did not specifically exclude those business administrators without a contract. A plain reading, logic, and context of other statutes showed that the legislature referred to contracts, but not to exclude those without a contract from protections. The contract language was there to allow for the fact that some contracts may specifically exclude notice and hearing for termination.
3. The court did not make a final decision on the second issue, but indicated that there is a distinction between termination and expiration of a term of employment. The Commonwealth Court will need to decide when the term of employment ended. These administrators do not have tenure to keep working indefinitely until discharged with a hearing, they have hearing rights during their agreed on term of employment.
4. Now it’s time to try your own outline. Following the same outline headings as those listed above, craft an outline of the legal case Asmus v. Pacific Bell. (Write in a Word document.)