State Ex Rel. Carna v. Teays Valley Local School District Board of Education
131 Ohio St. 3d 478
Ohio2012Background
- Carna, principal of Ashville Elementary, had a two-year contract starting June 2006 with Teays Valley Local School District, with favorable evaluations in 2006–2007.
- In spring 2007, after test-alteration allegations, Carna was placed on administrative leave and not renewed; the board retained Thompson’s evaluations and statements against her.
- Written evaluations in Dec. 2007 and Feb. 2008 notified nonrenewal for 2008–09; the Ohio Department of Education investigation followed.
- On March 17, 2008, the board voted not to renew before final evaluation; no executive session or advance notice of nonrenewal meeting occurred.
- Carna sought mandamus relief; the trial court and Court of Appeals ruled against her, leading to discretionary review by the Ohio Supreme Court.
- The issue centers on whether RC 3319.02(D)(4) requires an executive-session meeting upon a nonrenewal notice, regardless of final evaluations.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether RC 3319.02(D)(4) requires an executive-session meeting after nonrenewal is disclosed | Carna argues the board must meet in executive session upon learning of nonrenewal | Teays Valley contends meeting timing is tied to final evaluation/impending decision | Yes; board must hold executive-session meeting after nonrenewal is disclosed |
| Whether meeting timing can precede final evaluation | Carna maintains timing not tied to final evaluation | Board argues meeting only after impending decision | Timing not limited to post-evaluation; meeting can be requested when nonrenewal is known |
| Whether failure to provide the meeting triggers automatic reinstatement | Carna seeks automatic reinstatement for failure to grant meeting | Board argues no automatic remedy without proper procedure | Remedy includes automatic reinstatement where meeting is not provided |
| Whether the remedial construction preserves statutory meaning without gamesmanship | Plaintiff emphasizes liberal construction of remedial statute | Defendant cautions against misapplication of timing | Statute read to require meeting upon learning of nonrenewal; not constrained by timing concerns |
Key Cases Cited
- State ex rel. Cassels v. Dayton City School Dist. Bd. of Edn., 69 Ohio St.3d 217 (Ohio Supreme Court 1994) (mandamus/administrative contract decisions; liberal construction for admins)
- State ex rel. Russell v. Thornton, 111 Ohio St.3d 409 (Ohio Supreme Court 2006) (read words in context; avoid superfluous terms in statutes)
- State ex rel. Myers v. Spencer Twp. Rural School Dist. Bd. of Edn., 95 Ohio St.3d 367 (Ohio Supreme Court 1917) (avoid meaningless constructions; statutory interpretation principles)
- State v. S.R., 63 Ohio St.3d 590 (Ohio Supreme Court 1992) (reading statutory provisions in their plain meaning)