This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
The Plaintiff, a nontenured teacher, was employed by the Defendant school board for the 1985-1986 school year. On April 22, 1986, the superintendent informed her that he would not recommend her reemployment for the following school year. The school board accepted this recommendation the same day. On May 20, 1986, the Plaintiff submitted written acceptance of reemployment for the 1986-1987 school year. However, on May 29, 1986, she received written notice of termination effective May 30, 1986, and that she would not be reemployed for the next school year (paras 2-3).
Procedural History
- District Court, (N/A): The Plaintiff's complaint alleging breach of contract was dismissed, and the Defendant school board was awarded costs.
Parties' Submissions
- Plaintiff-Appellant: Argued that the school board breached her employment contract by failing to provide timely written notice of termination as required by statute and regulation. She claimed this breach entitled her to reinstatement and compensatory and punitive damages. She also contended that her written acceptance of reemployment created a binding contract for the 1986-1987 school year (paras 1, 3, 7, 10).
- Defendants-Appellees: Asserted that they complied with the statutory requirements for notice of termination and that the Plaintiff, as a nontenured teacher, was not entitled to the remedies she sought. They argued that the regulation requiring fourteen days' notice did not apply to nontenured teachers and that the Plaintiff suffered no prejudice from the timing of the notice (paras 6, 9).
Legal Issues
- Did the school board breach its contract with the Plaintiff by failing to provide timely written notice of termination? (para 3)
- Was a binding contract for the 1986-1987 school year created when the Plaintiff submitted her written acceptance of reemployment? (para 3)
Disposition
- The Supreme Court of New Mexico affirmed the dismissal of the Plaintiff's complaint (para 11).
Reasons
Per Baca J. (Sosa CJ. and Ransom J. concurring):
The Court held that the school board complied with the statutory requirements under Section 22-10-12 by providing written notice of termination before the last day of the school year. The regulation requiring fourteen days' notice did not apply to the Plaintiff as a nontenured teacher, and its remedy was limited to appeals before the State Board of Education, which were unavailable to nontenured teachers (paras 6, 9).
The Court also found that the Plaintiff's written acceptance of reemployment was ineffective because no statutory "offer" of reemployment had been made. Section 22-10-13 only allows for acceptance after the school year ends without notice of termination, which was not the case here (para 10).
The Court concluded that the Plaintiff suffered no prejudice from the timing of the notice, as nontenured teachers are not entitled to hearings or additional procedural protections upon termination (para 9). Accordingly, the dismissal of the Plaintiff's claims was upheld (para 11).