Raymond J. German, Ltd. v. Brossart, 2012 ND 89

Before 2008, the District operated three K–8 elementary schools; accreditation was lost in 2008 necessitating reconfiguration.
The plan moved Garden Valley to an upper elementary (grades 7–8) and Round Prairie and Stony Creek to K–6, with multiple teacher transfers.
Lynch, who taught fifth grade at Stony Creek for 18 years, was transferred in June 2008 to Round Prairie to teach second grade.
On July 9, 2008, Lynch sought written reasons for the transfer and asked for reconsideration; the District replied that transfers were in students’ best interests and wouldn’t be changed.
On August 11–14, 2008, Lynch’s position was updated to a combined 2nd/3rd grade role; she signed the contract August 14 under duress, requesting the grievance process.
Lynch began work August 19, 2008, did not report, and purportedly resigned; the District held a public hearing and accepted the resignation.
Lynch sued for contract breach, reputational harm, and emotional damages; the district court granted summary judgment in favor of the District.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was Lynch entitled to notice of nonrenewal?	Lynch; District failed to provide nonrenewal notice.	District offered reasonable reemployment in good faith within qualified position.	No notice required; offer was reasonable and in good faith.
Did the District violate grievance procedures in the negotiated agreement?	July 9 letter triggered Level One formal grievance.	Letter did not initiate formal grievance; August 14 letter did.	No violation; no valid initiation of formal grievance.
Did the district court abuse its discretion in denying discovery?	Emails between Board and administrator should be produced.	Requested emails were overwritten and unobtainable; no recovery possible.	No abuse of discretion; discovery denial affirmed.

Enstad v. North Cent. of Barnes Pub. Sch. Dist. No. 65, 268 N.W.2d 126 (N.D. 1978) (right to reemployment is not the right to an identical contract; good faith and reasonable offer required)
Enstad, supra, 268 N.W.2d 126 (N.D. 1978) (teacher may be reassigned; board may assign duties in best interest as long as not a demotion)
Quarles v. McKenzie Pub. Sch. Dist. No. 34, 325 N.W.2d 662 (N.D. 1982) (nonrenewal procedures not mandatory for changes in duties absent salary cut; reassignment may occur)
Wenman v. Center Bd. of Valley City Multi-Dist. Vocational Ctr., 471 N.W.2d 461 (N.D. 1991) (salary reductions trigger nonrenewal rights; context of curricular changes matters)
Coles v. Glenburn Pub. Sch. Dist. No. 26, 436 N.W.2d 262 (N.D. 1989) (material salary impact required for nonrenewal considerations; not every change affects pay)
Rickert v. Dakota Sanitation Plus, Inc., 2012 ND 37 (N.D. 2012) (summary judgment standard and burden on opposing party)