28 F. Supp. 3d 1207
N.D. Fla.2014Background
- Florida's Student Success Act (2011) required teacher evaluations to include "student learning growth" measured by statewide assessments or district assessments; Commissioner provided a value‑added model (VAM) for FCAT‑tested subjects.
- Districts (Alachua, Escambia, Hernando) adopted policies approved by the DOE that applied the FCAT VAM to: Type A teachers (FCAT subjects), Type B teachers (teachers of students who take FCAT but in other subjects), and Type C teachers (teachers whose students do not take FCAT) using school‑component or school‑wide scores.
- Type B evaluations used VAM outputs (teacher effect) applied to students' FCAT scores in subjects the teacher did not teach; Type C evaluations used the school component (same score for all teachers at a school).
- Plaintiffs challenged the district policies under substantive due process and equal protection (facial and as‑applied), arguing the policies are arbitrary and irrational to evaluate teachers on students/subjects they did not teach.
- Court evaluated the policies under rational basis review, considering whether the DOE and districts could rationally believe the policies advanced the legitimate state interest of increasing student learning growth.
- The court granted summary judgment to the State Defendants, denied Plaintiffs’ motion, dismissed federal claims for Plaintiffs, and declined supplemental jurisdiction over a state‑law claim concerning Alachua County.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Substantive due process — use of FCAT scores to evaluate Type B teachers | Evaluating teachers based on tests in subjects they did not teach is arbitrary and irrational | Rational to believe teachers can affect overall student performance and that including student growth incentivizes better teaching | Upheld: policies survive rational‑basis; districts could rationally believe the policies advanced student learning growth |
| Substantive due process — use of school‑wide FCAT for Type C teachers | Evaluations based on students the teacher never taught are arbitrary and irrational | Rational to believe professional teachers influence schoolwide achievement and incentives will improve outcomes | Upheld: rational basis satisfied for Type C evaluations |
| Equal protection — classification between FCAT and non‑FCAT teachers | Policy creates unequal classes with no rational basis (facial challenge) | Classification reflects practical lack of uniform measures and is rationally related to improving student growth | Upheld: classification passes rational‑basis; incremental reform permissible |
| As‑applied challenges | Plaintiffs seek relief limited to themselves for the same alleged irrationality | Defendants rely on same rational‑basis defenses; no disputed material facts identified | Upheld: as‑applied claims fail; policies are rational as applied to individual plaintiffs |
Key Cases Cited
- Snowden v. Hughes, 321 U.S. 1 (constitutional infirmity of local acts treated like state legislation)
- FCC v. Beach Communications, Inc., 508 U.S. 307 (rational‑basis review tolerates hypothetical or speculative justifications)
- Schilb v. Kuebel, 404 U.S. 357 (government may implement reform incrementally; equal protection does not require comprehensive action)
- Doe v. Moore, 410 F.3d 1337 (rational‑basis standard for classifications not involving suspect classes)