Christian Heyne v. Metropolitan Nashville Board of Public Education, 380 S.W.3d 715

Heyne, an 18-year-old Hillsboro High School senior and football co-captain, backed a car toward a group of freshman players, then drove forward when they attempted to scatter, injuring one student.
After the incident, Denzel A. and others reported to Principal Manuel; Heyne’s parents and the public records influenced the investigation, including statements and a written account provided by Heyne's father.
Manuel suspended Heyne for ten days pending investigation; subsequent referral cited three infractions and a potential further discipline beyond ten days.
A four-member hearing board convened on September 23, 2008; it found two infractions were not proven and that Heyne’s conduct constituted reckless endangerment, resulting in the ten-day suspension and probation.
Heynes pursued multiple appeals culminating in Board review; Board denied further review, leaving the ten-day suspension and probation in effect.
Heynes filed a state-court petition for common-law writ of certiorari seeking judicial review; the trial court allowed additional evidence about procedures and bias not in the record and found procedural due process violations, awarded fees, and expungement.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Dual role of Perry violated due process?	Heyne contends Perry’s prosecutor/decision-maker role biased outcome.	Board argues no per se rule; dual role may be permissible in school procedures.	No per se violation; dual role alone insufficient.
Bias evidence supports due process violation?	Trial court found bias and prejudice against Heyne; bias tainted review.	Record shows good-faith actions; no intolerable risk of bias.	Insufficient special facts; presumption of good faith stands.
Record supports recklessness conviction?	Trial court erred in discounting potential risk or intent; record insufficient.	Record shows substantial risk and reckless disregard; supported by evidence.	There is material evidence supporting recklessness; Court of Appeals correct.
Trial court had authority to award attorneys’ fees?	If constitutional rights violated, fees may be recoverable.	No constitutional violation found; fees not recoverable.	Attorneys’ fees not recoverable; affirmed.

Goss v. Lopez, 419 U.S. 565 (U.S. 1975) (due process for short suspensions; minimal notice and opportunity to be heard)
Morrissey v. Brewer, 408 U.S. 471 (U.S. 1972) (due process framework for parole-like proceedings)
Mathews v. Eldridge, 424 U.S. 319 (U.S. 1976) (three-factor test for due process adequacy)
State v. Lane, 254 S.W.3d 349 (Tenn. 2008) (abuse-of-discretion review in certiorari; limited judicial review)
Harding Acad. v. Metropolitan Gov’t of Nashville & Davidson Cnty., 222 S.W.3d 359 (Tenn. 2007) (scope of certiorari; grounds for reversal)
Leonard Plating Co. v. Metropolitan Gov’t of Nashville & Davidson Cnty., 213 S.W.3d 898 (Tenn. Ct. App. 2006) (material evidence standard in certiorari review)
Stewart v. Schofield, 368 S.W.3d 457 (Tenn. 2012) (certiorari scope and standards reiterated)
Lafferty v. City of Winchester, 46 S.W.3d 752 (Tenn. Ct. App. 2000) (de novo review of material-evidence standard)
Wright ex rel. Wright v. Wright, 337 S.W.3d 166 (Tenn. 2011) (abuse-of-discretion framework in review)
Tennessee Small Sch. Sys. v. McWherter, 851 S.W.2d 139 (Tenn. 1993) (education as state interest; due process alignment with Roth)
Roth, Board of Regents of State Colleges v., 408 U.S. 564 (U.S. 1972) (property interest created by state law; entitlement analysis)