Langdon v. Ohio Dept. of Edn.
2017 Ohio 8356
| Ohio Ct. App. | 2017Background
- Michelle Langdon, a licensed intervention specialist for Lakota School District, resigned in 2013 amid an internal investigation and allowed her license to lapse. She applied to renew in 2014.
- The Ohio Department of Education (through the State Board of Education) charged Langdon with eight counts of "conduct unbecoming" under R.C. 3319.31(B)(1); six counts were pursued at hearing (including inappropriate comments, breach of IEP confidentiality, improper physical contact, creating a hostile environment, and calling a nurse a "wildebeest").
- Langdon timely requested a hearing, participated in a seven-day administrative hearing, presented witnesses and exhibits, and contested due process and evidentiary sufficiency.
- The hearing officer found five of six contested counts proved and recommended revocation/denial and a five-year bar to reapplication; the Board adopted findings but instead allowed reapplication after a 2018 fitness evaluation and anger-management training.
- Langdon appealed to the Butler County Court of Common Pleas, which reversed the Board, finding due process deficiencies and insufficient evidence. The Department of Education appealed to the Court of Appeals.
- The Twelfth District reversed the common pleas court, holding Langdon received constitutionally adequate notice and a full hearing, and that the Board’s decision was supported by reliable, probative, and substantial evidence.
Issues
| Issue | Plaintiff's Argument (Langdon) | Defendant's Argument (Ohio Dept. of Ed.) | Held |
|---|---|---|---|
| Whether Langdon was afforded due process (notice and opportunity to be heard) | Notice lacked sufficient particularity (dates, identities) and Code of "conduct unbecoming" was too vague | Notice listed eight specific counts, named students/staff via key, provided right to hearing and full discovery; Administrative Code and Licensure Code define "conduct unbecoming" | Court: Due process satisfied — notice and hearing were adequate under Mathews test; Langdon fully participated and defended against specific allegations |
| Whether "conduct unbecoming" was too vague to afford fair notice | Term undefined in notice, depriving Langdon of fair warning | Ohio Admin. Code 3301-73-21 and Board’s Licensure Code supply definitional factors and standards | Court: Not unconstitutionally vague — parties and hearing officer applied O.A.C. standard; no due process violation |
| Whether the common pleas court properly reviewed the Board’s factual findings | Common pleas court found several Board witnesses unreliable and reversed on that basis | Board argues trial court failed to defer to administrative factfinding and credibility determinations | Court: Common pleas court abused its discretion by substituting its judgment for Board; appellate court reinstates Board decision |
| Whether the Board’s findings were supported by reliable, probative, substantial evidence | Langdon urged that positive teaching history outweighs allegations and that some charges were unproven | Dept. emphasizes multiple admissions by Langdon and corroborating witness testimony for several counts | Court: Record contains ample reliable, probative, substantial evidence to support findings on five counts; sanctions reinstated |
Key Cases Cited
- Troxel v. Granville, 530 U.S. 57 (recognition of Due Process principles)
- Mathews v. Eldridge, 424 U.S. 319 (framework for balancing procedural due process protections)
- Arlen v. Ohio State Med. Bd., 61 Ohio St.2d 168 (agency expertise in setting professional standards)
- University of Cincinnati v. Conrad, 63 Ohio St.2d 108 (deference to administrative factfinding on credibility)
- Ohio Historical Soc. v. State Emp. Relations Bd., 66 Ohio St.3d 466 (requirements for overturning agency factual findings)
- Our Place, Inc. v. Ohio Liquor Control Comm., 63 Ohio St.3d 570 (definitions of reliable, probative, substantial evidence)
- Rossford Exempted Village School Dist. Bd. of Edn. v. State Bd. of Edn., 63 Ohio St.3d 705 (appellate scope reviewing common pleas review of agency decisions)
- Blakemore v. Blakemore, 5 Ohio St.3d 217 (standard for abuse of discretion)