Sharita Giles v. Shaw School District
203 So. 3d 1165
| Miss. Ct. App. | 2016Background
- Sharita Giles served as principal of McEvans Elementary (hired 2008); her annual contract was not renewed by the Shaw School District (SSD) Board in Feb. 2013.
- SSD based nonrenewal primarily on McEvans’s persistently low academic performance under Giles (QDI/Growth Composite metrics showed two years "failing" and later only "academic watch").
- An MDE "At-Risk Action/Improvement Plan" set specific QDI benchmarks; McEvans failed to meet the plan’s benchmarks during Giles’s tenure.
- Superintendent Dr. Cederick Ellis recommended renewing Giles’s contract, but the Board voted 3–2 not to renew.
- Giles requested and received a multi-day evidentiary hearing before the Board, then appealed to chancery court; the chancellor affirmed the Board’s decision, and the Court of Appeals affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Board’s nonrenewal was supported by substantial evidence / was arbitrary or capricious | Giles: Board decision lacked substantial evidence and was arbitrary; school improvement under her leadership (e.g., moved to "academic watch") shows reasonableness | Board: Nonrenewal based on valid educational reason — consistent low QDI/GCV scores and failure to meet Improvement Plan benchmarks | Court: Affirmed — substantial evidence supported nonrenewal; decision not arbitrary or capricious |
| Whether Board’s rejection of superintendent’s renewal recommendation was arbitrary | Giles: Board’s refusal to follow Dr. Ellis’s recommendation shows arbitrariness | Board: Statute permits board to reject superintendent’s recommendation when good reason exists; poor school performance supplied such reason | Court: Affirmed — board may reject recommendation for good educational reasons |
| Whether Giles received a fair and impartial hearing (alleged bias by board members) | Giles: Ballard and Henry were prejudiced/biased against her (prior statements/votes) | Board: Members denied personal animosity; votes based on school data and performance concerns | Court: Affirmed — Giles failed to rebut presumption of board members’ honesty and integrity; no evidence of personal animosity or disqualifying bias |
Key Cases Cited
- Miss. Sierra Club Inc. v. Miss. Dep’t of Envtl. Quality, 819 So. 2d 515 (Miss. 2002) (standard of appellate review for agency actions)
- Smith Cty. Sch. Dist. v. Campbell, 18 So. 3d 335 (Miss. Ct. App. 2009) (definition of "substantial evidence" and arbitrary/capricious)
- Carter v. Cleveland Sch. Dist., 118 So. 3d 673 (Miss. Ct. App. 2013) (clarifying "arbitrary" and "capricious" standards)
- Harris v. Canton Separate Pub. Sch. Bd. of Educ., 655 So. 2d 898 (Miss. 1995) (board must give demonstrable reason for nonrenewal; plaintiff must show reason lacked factual basis)