Ellis v. Tupelo Public School District, 1:12-cv-00234

Background

Calvin Ellis was a Tupelo High School music teacher/show-choir director under an annual contract; he was placed on administrative leave after a student “pranking” incident and other allegations in Oct. 2011 and terminated by the superintendent on Oct. 28, 2011 based on multiple misconduct charges.
Ellis requested a public hearing under Mississippi law; the school board appointed a hearing officer, produced a record of over 2,000 pages, and the officer and board concluded the termination was a proper employment decision based on a valid educational reason.
Ellis declined to appeal the board’s final decision to Lee County Chancery Court (statutorily available) and instead filed suit in federal court asserting breach of contract, tortious breach of contract, procedural due process, equal protection, and tortious interference claims.
Defendant moved for summary judgment, arguing (inter alia) res judicata/collateral estoppel for several claims and arguing the remaining claims fail on the merits.
The district court held Ellis’s breach of contract, tortious breach of contract, and procedural due process claims were barred by res judicata because they were or could have been litigated in the administrative proceeding and declined to reach their merits.
The court also granted summary judgment to the District on Ellis’s equal protection and tortious-interference claims for failure to raise genuine disputes of material fact and for pleading/justification deficiencies.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether breach-of-contract, tortious-breach, and procedural-due-process claims are barred by res judicata after Ellis declined statutory judicial review	Ellis contends he seeks remedies not available in the statutory appeal and thus res judicata shouldn't bar his federal suit	Board says the administrative decision became final because Ellis declined the statutorily provided chancery-court appeal; res judicata/collateral estoppel therefore precludes relitigation	Held: Res judicata bars those claims — the administrative hearing and final board decision precluded relitigation of issues that were or could have been raised
Whether the statutory distinction between nonrenewal and mid-year termination violates equal protection	Ellis argues treating nonrenewed teachers differently (pre-hearing discovery rights) from terminated teachers is arbitrary and lacks rational basis	District argues the distinction is legislative (not a District policy) and there is a rational basis: differing burdens (teacher vs. superintendent) and differing permissible justifications for nonrenewal vs. termination	Held: Equal-protection claim fails — Ellis did not identify District action and cannot show absence of any rational basis for the legislative classification
Whether the District tortiously interfered with Ellis’s private tutoring contracts by sending letters to parents suspending private lessons	Ellis says Meadows mailed letters to parents that effectively terminated Ellis’s contracts and caused economic loss; claims interference was intentional and malicious	District says any interference was privileged/justified because Ellis’s employment was subject to district policies and the superintendent was enforcing ethics/policy and had a legitimate interest	Held: Tortious-interference claim fails — no genuine issue that the District acted with legal/social justification; privilege negates actionable malice
Whether summary judgment was otherwise inappropriate given the record	Ellis relies on alleged procedural defects and factual disputes about notice, discovery, and motive	District points to the administrative record, statutory process not pursued, and lack of evidence of improper motive	Held: Summary judgment appropriate for all claims addressed — res judicata for several counts; merits-based grants for remaining counts

Key Cases Cited

Celotex Corp. v. Catrett, 477 U.S. 317 (summary judgment standard)
Black v. N. Panola Sch. Dist., 461 F.3d 584 (5th Cir.) (preclusion analysis of state administrative decision and identity-of-claims framework)
A & F Prop. v. Madison Co. Bd. of Supervisors, 933 So. 2d 296 (Miss.) (administrative decisions preclude relitigation under res judicata)
Univ. of Tenn. v. Elliott, 478 U.S. 788 (administrative factfinding by a state agency is given preclusive effect by federal courts when parties had adequate opportunity to litigate)
Medina v. INS, 993 F.2d 499 (5th Cir.) (definition and preclusive effect of res judicata)