Johnson v. Blytheville School District Ex Rel. Board of Directors
2017 Ark. App. 147
| Ark. Ct. App. | 2017Background
- Alice Johnson, an LPN, alleges Blytheville School District employees told her she was hired for an LPN position, that she resigned her prior job in reliance, completed personnel forms, was fingerprinted, and worked about 1.5 days before being told not to return.
- The alleged primary contact was Letroy Gathen, Executive Director of Support Services, who Johnson says promised her the job and a $29,330 annual salary.
- Johnson sued the district asserting breach of employment contract, promissory estoppel, and constructive fraud; no written employment contract was alleged.
- The district moved to dismiss under Ark. R. Civ. P. 12(b)(6); the trial court granted the motion and dismissed for failure to state a claim.
- On appeal, Johnson argued (1) promissory estoppel/constructive fraud based on Gathen’s promises and her reliance; (2) that Gathen acted with unclean hands/without authority; and (3) constitutional due-process and equal-protection violations. The appellate court affirmed dismissal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether promissory estoppel or constructive fraud can bind the district where an employee-agent allegedly promised hiring and plaintiff relied | Johnson: she reasonably relied on Gathen’s promise, resigned, completed forms, and worked—so estoppel/constructive fraud should apply | District: only the board may enter initial written employment contracts under Ark. law; oral promises by employees cannot bind the district | Held: Dismissed. Reliance was not reasonable because persons dealing with public agents must inquire into their authority; statutory scheme requires written board-approved contracts |
| Whether acts like completing forms, fingerprinting, and brief work create enforceable employment obligations | Johnson: those acts corroborate reliance and hiring | District: such acts cannot substitute for the statutorily required written board contract | Held: Not enough; those facts do not overcome statutory requirement for written board-approved contracts |
| Whether agency/unclean-hands of Gathen prevents application of statutory bar | Johnson: Gathen knew he lacked authority, so the board’s exclusive contracting power should not preempt her claim | District: Government subdivisions cannot be bound beyond agents’ actual authority; estoppel against public entities is disfavored | Held: Rejected—public-policy and precedent require inquiry into agent authority; no relief |
| Whether Johnson’s due-process and equal-protection claims were preserved and meritorious | Johnson: denial of constitutional rights due to application of statutory rule | District: issues were not ruled on below and thus not preserved; no developed argument below | Held: Not preserved for appeal; trial court did not rule on constitutional claims |
Key Cases Cited
- Smith v. May, 2013 Ark. 248 (standard for testing Rule 12(b)(6) dismissal)
- Scott v. Scott, 2016 Ark. App. 390, 499 S.W.3d 653 (abuse-of-discretion standard for dismissal)
- Hankins v. City of Pine Bluff, 217 Ark. 226, 229 S.W.2d 231 (estoppel unavailable against public agent beyond actual authority)
- Woodward v. Campbell, 39 Ark. 580 (public-agent power to bind principal limited; party dealing must inquire into authority)
- F.E. Compton & Co. v. Greenwood Sch. Dist., 203 Ark. 935, 159 S.W.2d 721 (school district not liable on contract not approved by board)
- CMS Inv. Holdings, LLC v. Estate of Wilson, 2016 Ark. App. 545, 506 S.W.3d 292 (issues not preserved when trial court made no ruling)