Baldwin v. Board of Supervisors, 156 So. 3d 33

Baldwin entered a written contract as head football coach at UL, term ending January 31, 2003.
On November 27, 2001, Baldwin was relieved of head coaching duties effective November 26, 2001, yet UL continued his salary and benefits.
Baldwin filed suit July 21, 2003, alleging termination violated Section 11 and seeking damages.
Section 11 requires 30 days' notice if the agreement is terminated without just cause and provides liquidated damages; Section 12 states no guaranteed continued employment.
Trial court held the contract was not terminated and payment fulfilled obligations, granting summary judgment for defendants.
Court of Appeal reversed, finding a breach based on failure to provide notice; the supreme court reversed the appellate court and reinstated the trial court’s summary judgment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did relieving Baldwin of head coaching duties terminate the contract triggering notice?	Baldwin asserts termination occurred when UL removed him as head coach.	UL maintains no termination occurred; only duties changed and payments continued.	No termination occurred; notice not triggered.
Does Section 12's acknowledgement of payment negate termination and notice obligations?	Payment of salary/benefits shows contract termination implied by the appellate court.	Section 12 creates no guaranteed employment; payments fulfilled payment obligations, not termination.	Contractual obligations to pay continued; no termination under Section 11.
Do continued salary and benefits mean Baldwin remained a paid employee rather than terminated?	Maintaining benefits implies continued employment beyond head coaching duties.	Employment status as head coach ended; Baldwin remained a payroll employee.	Yes, Baldwin remained a paid employee; no breach of notice.
Is Section 11's notice provision applicable when employment continues in another capacity?	Notice should apply to any termination affecting employment terms.	Notice applies only if the contract is terminated, which did not occur.	Notice not triggered under these facts.

Sims v. Mulhearn Funeral Home, Inc., 956 So.2d 583 (La. 2007) (contract interpretation when instrument clear and complete)
Baldwin v. Board of Supervisors for University of Louisiana System, 138 So.3d 650 (La.App. 1 Cir. 2014) (contractual termination and notice analysis with Section 12 distinction)
Baldwin v. Board of Supervisors for University of Louisiana System, 11 So.3d 1247 (La.App. 1 Cir. 2009) (unpublished opinion; discussed notice/liquidated damages context)