Humphries v. Lorain City School Dist.
2017 Ohio 8429
| Ohio Ct. App. | 2017Background
- Aliceson Humphries, a long‑time Lorain City School District employee, served as Director of Lorain Digital Academy under an administrative limited contract and also held a continuing teaching contract; she was terminated in 2016 for conduct at a May 6, 2015 school track event.
- At the event Humphries intervened in a dispute between her sister and niece (a student); a physical confrontation occurred and Humphries struck her niece while security escorted the student.
- The Board investigated, held preliminary hearings, and initiated termination proceedings; Humphries demanded a hearing before a referee under R.C. 3319.16/3319.161.
- The referee held a four‑day hearing, found there was just cause for discipline but recommended discipline short of termination.
- The Board rejected the referee’s recommendation, asserted the referee omitted or misfound numerous material facts, and voted to terminate Humphries.
- The common pleas court affirmed the Board; the appellate court reversed and remanded, finding the trial court abused its discretion by failing to review whether the Board properly rejected the referee’s factual findings as being against the weight of the evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Board and common pleas court failed to give due deference to the referee’s factual findings and recommendation | Humphries: the Board and trial court disregarded the referee’s findings and recommendation and failed to afford required deference, making the termination against the weight of the evidence | Board: it had discretion to accept or reject the referee’s recommendation and properly concluded the referee omitted/ignored material facts and reached incorrect findings | Court: Reversed. Trial court abused discretion by not determining whether the Board properly rejected the referee’s factual findings as against the weight of the evidence; remanded for further proceedings |
| Whether the Board may substitute its factual findings for the referee’s without analysis | Humphries: Board cannot alter referee’s findings unless they are against the greater weight of evidence and must articulate reasons | Board: Board may reject findings/recommendation and interpret facts; it provided reasons for rejecting referee | Court: Board effectively altered/rejected referee’s findings; trial court failed to review that alteration and must do so on remand |
Key Cases Cited
- Aldridge v. Huntington Local School Dist., 38 Ohio St.3d 154 (1988) (referee's findings of fact must be accepted unless against the greater weight of the evidence; board may accept or reject recommendation unless contrary to law)
- Graziano v. Bd. of Edn., 32 Ohio St.3d 289 (1987) (appellate review of R.C. 3319.16 proceedings is limited; due deference must be given to referee where credibility issues exist)
- Univ. of Cincinnati v. Conrad, 63 Ohio St.2d 108 (1980) (deference to factfinder who observed witness demeanor)
- Hale v. Bd. of Edn., 13 Ohio St.2d 92 (1968) (common pleas court may reverse board order if not supported by or against the weight of the evidence)