Dallas Independent School District and Michael L. Williams, Commissioner of Education v. Adrian Peters
05-14-00759-CV
| Tex. App. | Dec 14, 2015Background
- Peters, an assistant principal at Spruce High School, faced termination under Texas Education Code Chapter 21 based on a 2011 incident involving a 15-year-old student who was pregnant.
- The independent hearing examiner found good cause to terminate and recommended dismissal; the DISD Board adopted the recommendation and voted to terminate in a closed session.
- Peters appealed to the Commissioner of Education, who upheld the good-cause termination but did not review a separate Open Meetings Act issue.
- Peters then sought judicial review; the district court voided the decision due to the closed-session vote, awarded back pay, and conditionally awarded attorney’s fees under the Open Meetings Act.
- On appeal, the Texas Court of Appeals reversed, upheld the Commissioner’s termination decision, found no reversible Open Meetings Act error, and vacated the fee award.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether substantial evidence supports termination for good cause | Peters argues the punishment was not supported by substantial evidence | DISD/Commissioner contend substantial evidence supports good cause | Yes, substantial evidence supports good cause |
| Whether the closed-session vote violated the Open Meetings Act and affected the outcome | Peters asserts the vote in closed session violated the OMA and should void the decision | DISD/Commissioner contend the error did not likely lead to an erroneous decision; standing issues bar relief | No reversible impact; open-meetings error did not void the decision; Peters lacks standing for the OMA claim separate from the appeal |
| Standing to pursue Open Meetings Act claims | Peters asserts standing as an interested person | Peters lacks statutory standing under the OMA | Peters lacks standing; cannot pursue OMA claim apart from the appeal |
| Attorney’s fees and costs under the Open Meetings Act | Peters should recover fees under the OMA because he substantially prevailed | No standing, so fee provision does not apply | Reversed district court’s conditional award of attorney’s fees and costs |
| Judicial review scope of district court’s voiding of board decision | District court’s voiding was proper due to OMA violation | Review limited to substantial-evidence and statutory standards; no reversal for procedural errors absent likelihood of erroneous decision | District court’s voiding reversed; Commissioner’s decision sustained |
Key Cases Cited
- Hogenson v. Williams, 542 S.W.2d 456 (Tex. Civ. App.—Texarkana 1976) (factors for reasonable force and discipline in schools)
- Montgomery Indep. Sch. Dist. v. Davis, 34 S.W.3d 559 (Tex. 2000) (objective reasonable-belief standard for force used by teachers)
- Groves v. City of Fort Worth, 746 S.W.2d 907 (Tex. App.—Fort Worth 1988) (standing under Open Meetings Act; public notice and opportunity to be heard)
- City of Bells v. Greater Texoma Util. Auth., 890 S.W.2d 6 (Tex. App.—Dallas 1990) (remedies for Open Meetings Act violations; vacatur of decisions)
- OAIC Commercial Assets v. Stonegate Village, 234 S.W.3d 726 (Tex. App.—Dallas 2007) (private right of action and standing considerations under public-information access)