Scott Schneider v. Keokuk Community School District
16-0675
Iowa Ct. App.Feb 8, 2017Background
- Scott Schneider, a teacher, sued Keokuk Community School District alleging constructive discharge for union activities (Count I), breach of contract/nonrenewal in violation of Iowa Code chapter 279 (Count II), and unpaid wages/expenses (Count III).
- The district moved to dismiss; the district court granted dismissal of Counts I and II for failure to exhaust administrative remedies. Schneider voluntarily dismissed Count III.
- Count I alleges Schneider was constructively discharged and discriminated against because of union activity, claims that fall under the Public Employment Relations Board (PERB) jurisdiction under Iowa Code chapter 20.
- PERB handles prohibited practice complaints (including discrimination for union activities) and requires filing a complaint within 90 days; chapter 20 vests PERB with exclusive authority to resolve such disputes.
- Count II alleges nonrenewal/conditional renewal of Schneider’s contract in retaliation; chapter 279 provides an exclusive, nonjudicial appeal to an adjudicator from a school board’s termination/nonrenewal decision, with limited judicial review thereafter.
- The district court concluded Schneider failed to exhaust PERB and chapter 279 remedies; the Court of Appeals affirmed dismissal of Counts I and II.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Count I (constructive discharge for union activity) required exhaustion of PERB remedies under chapter 20 | Schneider argued exhaustion would be inadequate or fruitless and thus should be excused | District argued chapter 20/PERB exclusively adjudicates prohibited practice complaints and Schneider failed to file the required PERB complaint | Court: Exhaustion required; Schneider failed to file with PERB; futility/inadequacy not shown; dismissal affirmed |
| Whether Count II (contract nonrenewal/termination under chapter 279) required pursuing chapter 279’s adjudicative remedy before court | Schneider argued chapter 279 does not address breach claims and that adjudicators would be biased against him | District argued chapter 279 provides the exclusive remedy for nonrenewal/termination and restricts original district court review | Court: Chapter 279’s appeal to an adjudicator is the exclusive remedy for nonrenewal; Schneider’s allegations fall within chapter 279; futility exception inapplicable; dismissal affirmed |
Key Cases Cited
- Hedlund v. State, 875 N.W.2d 720 (Iowa 2016) (standard of appellate review)
- Christiansen v. Iowa Bd. of Educ. Exam’rs, 831 N.W.2d 179 (Iowa 2013) (purposes of administrative exhaustion: agency expertise, agency forum, judicial economy)
- Sioux City Police Officers’ Ass’n v. City of Sioux City, 495 N.W.2d 687 (Iowa 1992) (when controversy delegated to PERB, courts have no original authority)
- Walthart v. Bd. of Dirs. of Edgewood-Colesburg Cmty. Sch. Dist., 667 N.W.2d 873 (Iowa 2003) (appeal to adjudicator under chapter 279 is the exclusive remedy)