863 F.3d 1030
8th Cir.2017Background
- McGuire was hired as Woodbury High School varsity girls’ basketball coach (2012–2014); parent complaints about his conduct and playing time led to an investigation and his placement on paid administrative leave in January 2014.
- The District retained outside counsel to investigate; McGuire alleges he was not given the investigation report, the identities of complainants, or supporting evidence, and that the investigation was a pretext.
- The School Board voted in March 2014 not to renew McGuire’s annual coaching contract; the non-renewal letter cited investigation results and administrative dissatisfaction, though McGuire alleges the true basis was parental complaints.
- McGuire requested reasons and an opportunity to respond; he addressed the Board in May 2014 and presented supporting statements but received no evidentiary hearing and no renewal.
- McGuire sued under 42 U.S.C. § 1983 alleging violation of procedural due process based on a claimed property interest in contract renewal created by Minn. Stat. § 122A.33 (as amended in 2013). The district court granted judgment on the pleadings for defendants; McGuire appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Minn. Stat. § 122A.33 (2013 amendment) creates a constitutionally protected property interest in renewal of an annual coaching contract | McGuire: the 2013 amendment (prohibiting sole reliance on parental complaints) imposes a substantive limit that creates a legitimate entitlement to renewal and thus due process protection | District: statute leaves broad discretion to the school board (it may or may not renew "as the board sees fit"), so no entitlement exists and no due process right arises | Court: No. The amendment does not sufficiently constrain the board’s discretion; it bars only one sole ground for nonrenewal and leaves considerable discretion, so no protected property interest exists |
Key Cases Cited
- Bd. of Regents v. Roth, 408 U.S. 564 (U.S. 1972) (property interests defined by state law; entitlement required for due process)
- Cleveland Bd. of Educ. v. Loudermill, 470 U.S. 532 (U.S. 1985) (state law creates property interests; constitutional law defines whether interest is protected)
- Town of Castle Rock v. Gonzales, 545 U.S. 748 (U.S. 2005) (federal law determines if state-created interest is a legitimate entitlement)
- Ky. Dep’t of Corr. v. Thompson, 490 U.S. 454 (U.S. 1989) (to create entitlement, statute must mandate outcome when criteria met)
- Dunham v. Wadley, 195 F.3d 1007 (8th Cir. 1999) (two-part test: substantive standards plus mandatory language required to create property interest)
- Austell v. Sprenger, 690 F.3d 929 (8th Cir. 2012) (reciting Roth standard for property interests)
- Mulvenon v. Greenwood, 643 F.3d 653 (8th Cir. 2011) (expectancy of reappointment is insufficient for property interest)
- Batra v. Bd. of Regents, 79 F.3d 717 (8th Cir. 1996) (mere subjective expectancy does not create property interest)
- Snaza v. City of Saint Paul, 548 F.3d 1178 (8th Cir. 2008) (same principle regarding discretion and expectancy)
- Forrester v. Bass, 397 F.3d 1047 (8th Cir. 2005) (statutory limits that leave outcome to board discretion do not create entitlement)
- Stevenson v. Blytheville Sch. Dist. #5, 800 F.3d 955 (8th Cir. 2015) (statute barring consideration of certain factors still left discretion and created no property interest)
- Wallace v. Robinson, 940 F.2d 243 (7th Cir. 1991) (prohibiting only one ground of action leaves too much discretion to create entitlement)