Court Rejects Challenges to Teacher Layoffs: Proper Teacher Evaluation Procedures Are Essential
In Garden City Education Ass'n v. School District of the City of Garden City , Docket 12-14886 (E.D. Mich. 2013) a U.S. District Court dismissed claims filed by the Garden City Education Association and two tenured teachers alleging violations of constitutional due process rights as well as Sections 1248 and 1249 of the Michigan Revised School Code. Plaintiffs' claims arose from layoff decisions made by the school district in June 2012 based on results from annual teacher evaluations mandated by Section 1249. Plaintiffs requested lost salaries and benefits, plus interest, costs and attorney's fees, and an injunctive order directing the school district to immediately discontinue use of the evaluation instruments and remove all 2011-2012 evaluation materials from all teacher files.
Finally, the Court rejected the Plaintiffs' due process claim stating due process is not required for a tenured teacher who is laid off unless the reduction in personnel is not bona fide . The Plaintiffs never alleged or argued that the school district's reduction in personnel was not bona fide , nor did they claim their layoffs were a subterfuge to avoid protections of the Teachers' Tenure Act. Since there was no evidence suggesting that the matter involved anything more than a necessary reduction in personnel, there was no violation of due process rights.
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