Connelly v. Steel Valley School District
706 F.3d 209
| 3rd Cir. | 2013Background
- Steel Valley School District uses a salary scale based on education and years of teaching experience.
- Connelly, hired in Sept 2006, had nine years of Maryland teaching experience but received only 1 year of credit.
- Other teachers with similar out-of-state experience but not in Steel Valley receive more credit; Connelly’s pay remained substantially lower.
- By 2010–11, Connelly earned about $22,000 less than he would have with full credit.
- Connelly sued in June 2011 under 42 U.S.C. § 1983 alleging violations of the Privileges and Immunities Clause and Equal Protection.
- The District Court dismissed the complaint under Rule 12(b)(6) as failing to state a cognizable Fourteenth Amendment claim.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| What equal protection standard applies? | Connelly argues strict scrutiny should apply due to travel rights. | Steel Valley argues rational basis review governs since no fundamental right or suspect class is involved. | Rational basis review applies. |
| Does the policy burden the right to interstate travel? | Connelly contends the policy penalizes interstate mobility. | Steel Valley contends it treats all residents similarly and does not discriminate based on residency. | Policy creates no substantial burden on travel; rational basis applies. |
| Is the classification based on location of experience constitutional under rational basis? | Classification discriminates against those with out-of-state experience. | Classification rationally related to administering a PA education system and DOE standards. | Classification is rationally related to legitimate state interests. |
| Was denial of leave to amend an abuse of discretion? | Connelly should have opportunity to amend. | Amendment would be futile; no material deficit in facts. | District court did not abuse its discretion; no futile amendment. |
Key Cases Cited
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (Supreme Court 2007) (plausibility pleading standard)
- Ashcroft v. Iqbal, 556 U.S. 662 (Supreme Court 2009) (plausibility required for claims)
- Maldonado v. Houstoun, 157 F.3d 179 (3d Cir. 1998) (classification must bear rational relation to legitimate end unless affects fundamental right)
- Saenz v. Roe, 526 U.S. 489 (Supreme Court 1999) (right to travel components; new-resident protections concern)
- Schumacher v. Nix, 965 F.2d 1262 (3d Cir. 1992) (right to travel rational basis when no residency-based distinction)
- Shapiro v. Thompson, 394 U.S. 618 (Supreme Court 1969) (fundamental right to travel; strict scrutiny if durational residency)
- Mem'l Hosp. v. Maricopa Cnty., 415 U.S. 250 (Supreme Court 1974) (durational residency requirements and travel rights context)
- Dunn v. Blumstein, 405 U.S. 330 (Supreme Court 1972) (one-year waiting periods implicating right to vote and residency)
- Ramsgate Ct. Townhome Ass’n v. West Chester Borough, 313 F.3d 157 (3d Cir. 2002) (rational basis review; broad consideration of purposes)
- Romer v. Evans, 517 U.S. 620 (Supreme Court 1996) (equal protection rationality review framework)