832 N.W.2d 62
S.D.2013Background
- Huth taught fifth grade and coached girls’ basketball in Beresford SD; she held continuing contract status at start of 2011 negotiations.
- Budget shortfalls in March 2011 led Field to propose staff reductions, including eliminating Huth’s fifth-grade position.
- The 2010-2011 Agreement contains a Staff Reduction Policy that governs RIF decisions and takes precedence over other policies.
- Huth argued the 2006 RIF policy should apply, not the 2010-2011 policy.
- Board applied the 2010-2011 RIF policy to determine which teachers to retain or terminate; BEA challenged this application.
- Circuit court affirmed the Board’s decision, and Huth appeals to the Supreme Court of South Dakota.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Which RIF policy governs Huth’s termination | Huth argues 2006 policy applies | Board argues 2010-2011 policy governs | 2010-2011 policy governs |
| Whether the 2010-2011 RIF policy was properly applied | Policy misapplied to Huth | Board followed articulated criteria (needs, endorsements, etc.) | Policy properly applied; not arbitrary or capricious |
| Whether procedural requirements were met and decision was legal | Procedural regularities not followed | Procedures followed; decision legal | Procedural requirements met; decision legal and not an abuse of discretion |
Key Cases Cited
- Scheller v. Faulkton Area Sch. Dist. No. 24-3, 2007 S.D. 42 (2007 S.D.) (two-pronged legality test; review of procedural regularity and arbitrariness)
- Hicks v. Gayville-Volin Sch. Dist., 2003 S.D. 92 (2003 S.D.) (abuse of discretion standard; due regard for evidence)
- Blondo v. Bristol Sch. Dist. #18-1, 2007 S.D. 8 (2007 S.D.) (legality requires review of procedural regularity)
- Hanson v. Vermillion Sch. Dist. No. 13-1, 2007 S.D. 9 (2007 S.D.) (contracts in teacher negotiations; contract principles apply)