hThis ease comes to us on direct appeal pursuant to La. Const, art. V, § 5(D)
FACTS AND PROCEDURAL HISTORY
During the 2012 Regular Session, the legislature passed Act 1. The title of Act 1 provides:
To amend and reenact R.S. 17:54(B)(l)(b)(I) and (iii), 81(A) and (P)(l), 81.4, 229, 414.4, 441, 442, 443, and 444(B)(1), to enact R.S. 17:418 and 532(C), and to repeal R.S. 17:44, 45, 81(1), 154,2, 235.1(E), 346.1, 419, 419.1, 420, 421, 421.1, 421.2, 421.3, 421.5, 422, 422.1, 422.2, 422.3, 422.4, 422.5, 431, 444(A) and (B)(2) and (3), 446, 461 through 464, and 1207, relative to elementary and secondary education; to provide with respect to teachers and other school employees; to provide with respect to local school superintendents, their employment, and their duties and responsibilities; to provide relative to local school | gboards and their functions and powers; to provide relative to school personnel decisions; to provide relative to school board reduction in force policies; to provide with respect to salaries and compensation of teachers and other school employees; to provide relative to tenure for school employees and the removal of tenured and nontenured teachers; to provide for effectiveness; and to provide for related matters.
As stated in the title, Act 1 of 2012 amended, reenacted and repealed various statutes in Title 17, which are described below.
Section 1 amended and reenacted multiple provisions in La. R.S. 17:54, 17:81, 17.81.4, 17:229 and 17:414.1. La. R.S. 17:54(B), is entitled “Officers of boards; election; superintendents, qualifications, appointment and removal.” La. R.S. 17:54(B)(l)(b)(i)(aa) requires failing school systems to establish specific performance targets in a superintendent’s contract for student achievement, graduation rates, and the percentage of teachers who are rated “effective” and “ineffective,” and induces
La. R.S. 17:81, entitled “General powers of local public school boards.,” requires superintendents and principals to make employment related decisions based on performance and effectiveness. La. R.S. 17:81(A)(1) is a new provision requiring school boards to serve in a policy making capacity focused on student achievement, financial efficiency and workforce development. La. R.S. 17:81(A)(2) retains the | c-authority of school boards to determine the number and location of schools, and the number of personnel employed, but changes the law by delegating the authority to make employment decisions, to fix salaries, and to ensure compliance with state laws to local superintendents. La. R.S. 17:81(A)(3) requires school boards to delegate the authority for the hiring and placement of all school personnel to the local superintendent, provides that the superintendent is responsible for ensuring that all personnel are properly certified and qualified, and repeals the authority of school boards to reject choices made by a superintendent. La. R.S. 17:81(A)(4)(a) requires local superintendents to delegate all decisions regarding the hiring and placement of school personnel to the school’s principal. La. R.S. 17:81(A)(6) is a new provision requiring that superintendents and principals make all employment-related decisions based upon “performance, effectiveness, and qualifications as applicable to each specific position,” and requires that effectiveness “shall be used as the primary criterion for making personnel decisions” and prohibits “seniority or tenure” from being used as the primary criterion. La. R.S. 17: 81(P)(1) removes the requirement thaf personnel decisions are to be approved or disapproved by school boards.
La. R.S. 17:81.4, entitled “Reductions in force; dismissal of teachers and other school employees,” requires reduction in force (“RIF”) decisions be based on performance and effectiveness and provides seniority or tenure shall not be included as the primary criterion in a RIF policy. La. R.S. 17:81.4(A) requires school boards to delegate RIF decisions to superintendents. La. R.S. 17:81.4(B) repeals a provision requiring that RIF policies be based on “certification seniority, tenure and academic preparation,” and replaces it with the requirement that RIF policies be based solely upon demand, performance, and effectiveness, as determined by the effectiveness rating in La. R.S. 17:3881-3905. La. R.S. 17:81.(C) requires that RIF policies related l4to dismissal of employees who are not subject to evaluation under La. R.S. 17:3881-3905 must be based upon performance and effectiveness. La. R.S. 17:81.4(D) provides rules for notice to employees of RIF policies, and deletes seniority and tenure from consideration in RIF policies.
La. R.S. 17:229 is entitled “Appointment of visiting teachers, or supervisors of child welfare and attendance.” La. R.S. 17:229 delegates the authority to appoint visiting teachers and supervisors of child welfare and attendance to local superintendents rather than school boards, and removes
La. R.S. 17:414.1 is entitled “Public elementary and secondary school principals; duties,” and amends the prior statute to delegate the authority to appoint and direct principals to superintendents rather than school boards.
Section 2 of Act 1 enacts an entirely new provision of law, La. R.S. 17:418, tying compensation to effectiveness, demand and experience. La. R.S. 17:418(A)(1), entitled “Salaries; teachers and other school employees,” requires the establishment of salary schedules and provides that these salaries shall be considered full compensation for all work performed. La. R.S. 17:418(A)(2) requires that salaries be established by January 1, 2013 and be effective as to all school employees not later than the 2013-2014 school year. La. R.S. 17:418(B)(l)(a)-(e) requires that salary schedules be based on effectiveness as determined by the performance evaluation program, demand, and experience, with no one criteria accounting for more than 50% of the formula. La. R.S. 17:418(B)(2) provides that no teacher or administrator who is rated “ineffective” shall receive a raise or a higher salary in the year following evaluation than he or she received in the prior year. La. R.S. 17:418(0(1) guarantees Isthat an annual salary may not be reduced below the salary received in the preceding year, nor can it be reduced during an academic year. La. R.S. 17:418(0(2) requires that vocational agriculture teachers teach 12 month programs for 12 month budget periods and be paid a proportional salary according to the salary schedule. La. R.S. 17:418(C)(3)(a)-(c) provides that the limitations on the reduction of salary is not applicable to the correction of accounting errors, to the reduction of a local salary supplement from a revenue source requiring voter approval when such approval hasn’t been obtained, or to a teacher/employee who has been demoted to a lower position in accordance with law or policy. La. R.S. 17:418(D) exempts classified civil service employees.
Section 3 of Act 1 amended La. R.S. 17:441, 17:442, 17:443, 17:444(B)(1), and 17:532(C). La. R.S. 17:441, entitled “Definitions,” changes the definition of “teacher” to include employees at state special schools and to prohibit certain employees within that definition hired after July 1, 2012 from acquiring tenure.
La. R.S 17:442(A)(l)(a) provides that any tenure acquired prior to September 1, 2012 is retained, subject to provisions of the section. La. R.S. 17:442(A)(l)(b) provides that only teachers rated as “highly effective” for five years within a six year period based upon performance evaluations may acquire tenure. La. R.S. 17:442(A)(2) provides that teachers paid with federal funds are not eligible for tenure. La. R.S. 17:442(B) requires superintendents to notify teachers in writing when tenure has been awarded and provides that a teacher who has not acquired tenure remains an at-will employee. La. R.S. 17:442(0(1) establishes that beginning with the 2013-2014 school year, a teacher who receives an “ineffective” rating pursuant to the performance evaluation program shall immediately lose tenure. La. R.S. 17:442(0(2) provides that a teacher may reacquire tenure if the “ineffective” rating Lis reversed or if the teacher is subsequently rated “highly effective” for five out of six year.
La. R.S. 17:443 is entitled “Removal of teachers; procedure; right to appeal,” provides the procedure for removal of teachers with tenure. These amendments to La. R.S. 17:443 were dramatically rewritten and replaced by 2014 Acts No. 570.
La. R.S. 17:444(B)(1) is entitled “promotions to and employment into positions of higher salary and tenure,” and was
La. R.S. 17:532(C), entitled “Probationary term and tenure,” was amended to prohibit non-teacher employees of the Iberville Parish School Board hired after July 1, 2012 from tenure eligibility.
Section 4 of Act 1 repealed twenty-eight statutes — La. R.S. 17:44, 17:45, 17:81(1), 17:154.2, 17:235.1(e), 17:346.1, 17:419, 17:419.1, 17:420, 17:421, 17:421.1, 17:421.2, 17:421.3, 17:421.5, 17:422, 17:422.1, 17:422.2, 17:422.3, 17:422.4, 17:422.5, 17:431, 17:444(A) and (B)(2) and (3), 17:461-464, and 17:1207. All of the repealed statutes dealt with a specific area covered by Act 1, such as compensation, acquiring permanent status, or related employment policies.
Plaintiffs, the Louisiana Federation of Teachers, East Baton Rouge Federation of Teachers, Jefferson Foundation of Teachers, Nellie Joyce Meariman, and Kevin Joseph DeHart, filed a petition for declaratory judgment against the State of Louisiana (“State”), alleging Act 1 was passed in violation of the “single object” requirement of La. Const. Art. Ill, § 15(A) and (C). In particular, the petition alleged the legislature amended and re-enacted nine different statutes, enacted two new distinct statutes, and ^repealed twenty-eight statutes, and went beyond those stated objects, including: (1) school board contracts with superintendents (La. R.S. 17:54); (2) the general powers of local school boards to make policy and delegate powers to the superintendent (La. R.S. 17:81); (3) reductions in force (La. R.S. 17:81.4); (4) appointment of visiting teachers and supervisors of child welfare (La. R.S. 17:229); (5) duties of principals (La. R.S. 17:414.1); (6) salaries of teachers and other school employees (La. R.S. 17:418); (7) tenure/removal of teachers (La. R.S. 17:441 et seq.); and (8) promotions (La. R.S. 17:444).
Subsequently, plaintiffs filed a motion for summary judgment, arguing Act 1 is an unconstitutional violation of the single object requirement set forth in La. Const. Art. Ill, § 15(A) and (C), which provide:
Section 15. (A) Introduction; Title; Single Object; Public Meetings. The legislature shall enact no law except by a bill introduced during that session, and propose no constitutional amendment except by a joint resolution introduced during that session, which shall be processed as a bill. Every bill, except the general appropriation bill and bills for the enactment, rearrangement, codification, or revision of a system of laws, shall be confined to one object. Every bill shall contain a brief title indicative of its object. Action on any matter intended to have the effect of law shall be taken only in open, public meeting.
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(C) Germane Amendments. No bill shall be amended in either house to make a change not germane to the bill as introduced.
Plaintiffs argued Act 1 sets forth at least eight legislative objects that have no reasonable relationship to each other, except for the happenstance that they fall within the rubric of elementary and secondary education. According to plaintiffs, the title does not reflect school board contracts with superintendents, placement of teachers, reductions in force, appointments of visiting teachers, supervisors of child welfare, and several other provisions. The State filed a cross-motion for summary | ¿judgment, seeking dismissal of plaintiffs’ claims and also opposed plaintiffs’ motion for summary judgment.
After a hearing, the district court, Judge Michael Caldwell presiding, granted plain
Thereafter, plaintiffs filed a motion for new trial claiming that Act 1 in its entirety was unconstitutional. Plaintiffs maintained Act 1 does not have one, main single object or purpose because both the title and content of Act 1 contain a multitude of objects. The State also filed a motion for new trial, arguing the amendments to La. R.S. 17:81.4, 17:81, 17:229, and 17:414.1 address the general powers of local schools boards in conformity with HB 974. In addition, the State pointed out the evaluation program set forth in La. R.S. 17:81.4 is the same program referenced in Sections 2 and 3 of Act 1, which the district court upheld. After a hearing, the district court granted plaintiffs’ motion for new trial and denied the State’s motion for new trial, thereby declaring Act 1 unconstitutional in its entirety in violation of La. Const. Art. Ill, § 15(A).
The State then directly appealed to this Court. On May 31, 2014, prior to doeket-ing the case, this Court summarily remanded it to the district court.
Pretermitting the merits of the appeal, we find the parties and the district court did not have the benefit of our recent opinion in Louisiana Federation of Teachers v. State of Louisiana, 13-0120, 13-0232, 13-0350 (La.5/7/13),118 So.3d 1033 . Because our opinion clarifies the law in this area, we conclude it would be beneficial to remand the |9case to the district court for reconsideration of its ruling in light of our opinion, after appropriate briefing and argument by the parties.
On remand, plaintiffs filed a first supplemental and amending petition, alleging Act 1 violates due process rights pursuant to La. Const, art. I, § 2,
Thereafter, the district court held a second trial to determine the constitutionality of Act 1. At the conclusion of trial, the district court declared Act 1 unconstitutional in violation of the single object requirement set forth in La. Const, art. Ill, § 15(C). The district court stated in a written judgment:
*843 IT IS ORDERED, ADJUDGED AND DECREED that Plaintiffs are entitled to judgment declaring that Act 1 of the 2012 Regular Session of the Louisiana Legislature violates Article III, § 15A of the Louisiana Constitution, and that Act 1 of the 2012 Regular Session of the Louisiana Legislature be and is hereby-declared to be unconstitutional in its entirety.
IT IS FURTHER ORDERED, ADJUDGED AND DECREED that because this Court declares Act 1 of the 2012 Regular Session of the Louisiana Legislature to be unconstitutional in its entirety, this Court does not rule on Plaintiffs’ claims that La. R.S. 17:443 violates the due process clause of Article I, § 2 of the Louisiana Constitution and 5th and 14th Amendments of the United States Constitution.
jinIn oral reasons for judgment, the district court indicated it reconsidered its pri- or ruling declaring Act 1 unconstitutional in light of this court’s decision in Louisiana Federation of Teachers v. State of Louisiana, 13-0120, 13-0232, 13-0350 (La.5/7/13),
And with regard to the “single object” challenge, I have reviewed the Supreme Court’s decision in the Act 2 case several times, and it is clear from that decision that the court, now requires a much broader and more expansive review of a statute and its title.
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Now, in this instance, Act 1, the title reads as follows: to amend and reenact various listed statutes, to enact certain statutes, and to repeal certain statutes, quote, relative to elementary and secondary education; to provide with respect to teachers and other school employees; to provide with respect to local superintendents, their employment, and their duties and responsibilities, and so forth and so on, with various listed clauses as to what this Act is to provide. So after examining that title, I did examine again the body of the Act. And while I would not, from that title, and particularly not from the first clause of that title, identify a “unifying object” of the bill, I did notice from some, but not all, of the provisions some meager semblance of a unifying theme. That seemed to be an attempt to require school boards and superintendents to make hiring, firing, and compensation decisions based'upon the effectiveness of the teachers and other school employees and not on other factors. However, I was unable to glean that object from all portions of the Act or from its title. The word “effectiveness” is thrown in as the last proposed clause of the title, but it is not tied to the others in any meaningful way. More importantly, as I already noted, that “object” was not apparent, at least to me, in several provisions of the Act. Thus, even after a thorough review of the Supreme Court’s decision in the Act 2 case and a thorough re-review, perhaps, of Act 1 and its title, I am still of the opinion that the Act violates the single object requirement and is thus unconstitutional in its entirety. Having said that, I do not feel it is necessary for me to address the due process challenge to a portion of the Act.'
I,-,The State then sought a direct appeal in this Court pursuant to this Court’s appellate jurisdiction under La. Const. Art. V, § 5(A).
DISCUSSION
We first consider whether the enactment of Act 570 in 2014 renders our consideration of the constitutionality of Act 1 moot. In Cat’s Meow, Inc. v. City of New Orleans through Dept. of Finance,
We acknowledge the legislature, through Act 570 of 2014, changed the policy regarding removal and discipline of tenured teachers, which superceded the prior policy set forth in Act 1 of 2012. As the 2014 legislation does not have retroactive effect, however, we agree that there could be situations where a ruling on the constitu
LsThis case is before us after a judgment by the district court that Act 1 violates the one-object requirement of La. Const. Art. Ill, § 15. This court reviews judgments declaring legislative instruments unconstitutional de novo.
Quite recently, in the Act 2 case,
In the Act 2 case, we explained that the one-object requirement is a restraint on the legislature, aimed at preventing the dilution of the majority vote through “logrolling,” which is the “practice of procuring diverse and unrelated matters to be passed on as one ‘omnibus’ through the consolidated votes of the advocates of each separate measure when perhaps no single measure could have passed on its own merits,” and
We explained that the “object” of a bill is “the aim or purpose of the enactment, its general purpose, the matter or thing forming the groundwork of the bill,” and that “while the constitution requires unity of object in legislation, it does not restrict the permissible breadth of a bill.”
A one-object analysis begins with identifying the main purpose or object of the bill, and then examining each provision to determine whether its parts have a natural connection and reasonably relate, directly or indirectly, to that purpose.
To amend and reenact R.S. 17:64(B)(1)(b)(D and (iii), 81(A) and (P)(l), 81.4, 229, 414.4, 441, 442, 443, and 444(B)(1), to enact R.S. 17:418 and 532(C), and to repeal R.S. 17:44, 45, 81(1), 154,2, 235.1(E), 346.1, 419, 419.1, 420, 421, 421.1, 421.2, 421.3, 421.5, 422, 422.1, 422.2, 422.3, 422.4, 422.5, 431, 444(A) and (B)(2) and (3), 446, 461 through 464, and 1207, relative to elementary and secondary education; to provide with respect to teachers and other school employees; to provide with respect to local school superintendents, their employment, and their duties and responsibilities; to provide relative to local school boards and their functions and powers; to provide relative to school personnel decisions; to provide relative school board reduction in force policies; to provide with respect to salaries and compensation of teachers and other school employees; to provide relative to tenure for school employees and the removal of tenured and nontenured teachers; to provide for effectiveness; and to provide for related matters.
La. Const. Art, III, § 15(A) provides that “[ejvery bill shall contain a brief title indicative of its object.”
While we interpreted “relative to school choice” as “providing expanded ‘school choice,’ ” in the Act 2 case,, from the title here, we can identify the general subject matter of Act 1 as “elementary and secondary education.” However, that is not an object, it’s simply the general subject matter of the bill. The “object” and “subject” of a bill are not the same thing. “The ‘object’ of a law is the aim or purpose of the enactment.”
In the body of Act 1, the legislature amends and reenacts nine statutes, enacts two statutes, and repeals twenty-nine statutes. Though numerous, Act 2 was even more so, amending and reacting twenty-seven statutes, enacting twenty new statutes, and repealing three statutes. We pointed out in the Act 2 case that it does not matter 11s“how comprehensive the act may be or how numerous its provisions; ...”
Thus, we examine the statutory provisions of Act 1 to further determine the main general purpose of the bill. The provisions of Section 1 require performance based standards for superintendents and delegate to them the authority to make employment related decisions, all of which must be based on performance and effectiveness. The provisions of Section 2 relate to salaries which must be based on effectiveness. The provisions of Section 3 relate to tenure, removal, and promotions, all of which must also be based on effectiveness. The provisions of Section 4 simply repeal statutes that are now covered by Sections 1-3 of the Act. An analysis of the statutory provisions encompassed by Act 1 leads us to the conclusion that the main general purpose of Act 1 is improving elementary and secondary education through tenure reform and performance standards based on effectiveness.
Having identified the object of the Act, we next examine its provisions to determine whether its parts have a natural connection and reasonably relate, directly or indirectly, to that purpose. Plaintiffs point to several provisions which they claim either constitute separate objects, or have no natural connection or reasonable relationship to the object of improving elementary and secondary education through tenure reform and performance standards based on effectiveness.
The first involves provisions in La. R.S. 17:54 which require (1) that contracts between the local school boards and local superintendents in school systems with performance letter grades of “C,”
Plaintiffs also complain about La. R.S. 17:81(A)(1), which gives the local school boards policymaking authority over schools, rather than administrative authority, and requires that school boards choose superintendents who would prioritize student achievement and act in the best interests of all students. This is simply a means of delegating authority over employment decisions to superintendents, which decisions will be guided by standards of effectiveness. Evidently, the legislature is of the opinion that local superintendents are better |2nsituated to make these decisions based on effectiveness, and it is not our role to question the legislature’s rationale in this analysis.
In addition, plaintiffs argue that La. R.S. 17:81(A)(2) and (3), which delegate the administrative authority to local superintendents, “constitutes a significant transfer of power and authority,” and is therefore either a separate object or not necessary to carry out the object of improving elementary and secondary education through tenure reform and performance standards based on effectiveness. Plaintiffs argue these provisions are not necessary because the school boards could have retained their administrative authority and utilized effectiveness in making employment decisions. Again, the legislature felt that superintendents were in a better position to make employment decisions based on effectiveness; thus, the transfer of this administrative authority was necessary to accomplish this.
Plaintiffs complain that La. R.S. 17:229, which delegates the authority to appoint visiting teachers and supervisors of child welfare and attendance to local superintendents, is not necessary to the object of improving elementary and secondary education through tenure reform and performance standards based on effectiveness. However, it is just another means of transferring hiring authority to local superintendents, which the legislature has determined is necessary to accomplish its goal. Just because this statute deals with a distinct type of teacher or employee does not render it unnecessary to accomplish the single object. As we have stated, “a statute that deals with several branches of one subject does not thereby violate the constitutional provision,” and the constitution “does not mean that each and every means necessary to accomplish an object in the law must be provided for by a separate act relating to it alone.”
Finally, plaintiffs complain that La. R.S. 17:442, which made broad changes to the Teacher Tenure Law, and La. R.S. 17:443, which amended the due process requirements in the Teacher Tenure Law, were not necessary to accomplish the stated object. However, the object is improving elementary and secondary education through tenure reform and performance standards based on effectiveness, and these statutes which reformed the Teacher Tenure Law are certainly necessary to accomplish that tenure reform.
122As we stated in the Act 2 ease, given the state constitution’s failure to specify the degree of particularity necessary to comply with the one-object rule:
[T]he courts should not embarrass legislation by technical interpretations based upon mere form or phraseology. The objections should be grave, and the conflict between the statute and the Constitution palpable, before the judiciary should disregard a legislative enactment upon the sole ground that it embraced more than one object, or if but one object, that it was not sufficiently expressed in the title. Inhabitants of Montclair Tp. v. Ramsdell,107 U.S. 147 , 155,2 S.Ct. 391 ,27 L.Ed. 431 (1883).
Just as in the Act 2 case, the plaintiffs have simply failed to establish that such a grave and palpable conflict exists between Act 1 and the one-object requirement of La. Const, art. Ill, § 15(A). All of the provisions of Act 1 are naturally connected with, and incidental or germane to the unifying object of improving education through tenure reform and performance standards based on effectiveness.
CONCLUSION
As we explained in the Act 2 case, the single object requirement of La. Const, art. Ill, § 15 is a restraint on the legislature aimed at preventing the dilution of the majority vote through “logrolling.” The term “object” is to be broadly interpreted, and while the constitution requires unity of object, a bill may be as broad as the legislature chooses, and may contain as many provisions as the legislature chooses, as long as nothing is written into the bill except what is naturally connected with, and is incidental or germane to, its one object. Looking first to the title, and then to the body, of Act 1, we glean that the subject of the act is elementary and secondary education, and the object of the act is improving elementary and secondary ed
DECREE
For the reasons stated herein, the judgment of the district court declaring Act 1 of 2012 unconstitutional pursuant to La. Const, art. Ill, § 15 is reversed and the case is remanded to the district court for further proceedings.
REVERSED AND REMANDED.
Notes
. La. Const, art. V, § 5(D)(1) provides: "Appellate Jurisdiction. In addition to other appeals provided by this constitution, a case shall be appealable to the supreme court if (1) a law or ordinance has been declared unconstitutional ...”
. Louisiana Federation of Teachers v. State, 13-1088 (La.5/31/13),
. La. Const, art. I, § 2 provides "[n]o person shall be deprived of life, liberty, or property, except by due process of law.”
. The first supplemental and amending petition alleged La. R.S. 17:443, which is contained in Act 1, violated La. Const, art. I, § 2, by failing to provide a pre-termination hearing and failing to grant teachers a meaningful employment hearing. In particular, plaintiffs alleged La. R.S.17:443 grants the superintendent the authority to terminate a tenured teacher prior to a hearing; provides a hearing after termination based on a three person panel that includes one person designated by the teacher, superintendent, and principal; and grants the hearing panel the authority to make an employment recommendation, but not a final decision, to the superintendent. In addition, the petition alleged La. R. S. 17:443 allows the superintendent to remove tenure without a prior hearing and place a teacher on probation without a prior hearing. The first supplemental and amended petition also sought to declare La. R.S. 17:81(A) (granting superintendent authority over employment-related decisions); La. R.S. 17:81.4 (governing reduction in force); La. R.S. 17:441 through 17:444 (governing probation and tenure); and Act 1, Section 4 (providing for the repeal of certain statutes) unconstitutional in violation of due process. The district court pretermit-ted consideration of these constitutional challenges after finding on remand that Act 1 violated the single object rule.
. In a related appeal, Deanne Williams v. Monroe City School Board., 14-CA-0899, was
.Act 570, assigned into law on June 9, 2014, amended and reenacted four statutes which were included in Act 1 of 2012. These four statutes, La. R.S. 17:441, La. R.S. 17:442(C), La. R.S. 17:443, and La. R.S.17:444(B)(4)(c)(iii), relate to teacher tenure. Essentially, Act 570 of 2014 changed the procedures for the discipline and removal of tenured teachers, providing for hearings and judicial review of such decisions.
. 98-0601 (La. 10/20/98),
. While this lawsuit complains that La. R.S. 17:443 allows the superintendent to remove tenure without a prior hearing and place a teacher on probation without a prior hearing, La. R.S. 17:443 as amended by the 2014 Act now provides detailed procedures for the discipline and removal of tenured teachers, including hearings and judicial review of such decisions.
. State v. All Property and Casualty Insurance Carriers Authorized and Licensed to do Business in the State, 06-2030 (La.8/25/06),
. State v. Citizen, 04-1841 (La.4/1/05),
. State v. Fleury, 01-0871 (La.10/16/01),
. Hondroulis v. Schuhmacher,
. World Trade Center Taxing District v. All Taxpayers, Property Owners, 05-374 (La.6/29/05),
. Caddo-Shreveport Sales and Use Tax Commission, supra at 780.
. Louisiana Federation of Teachers v. State, 13-0120, 13-0232, 13-0350 (La.5/7/13),
. Louisiana Federation of Teachers, supra at 1063-64 (citing NORMAN J. SINGER & J.D. SHAMBIE SINGER, STATUTES AND STATUTORY CONSTRUCTION § 17.1 at 7-8 (7th ed.2009)).
. Id. at 1064.
. Id. at 1070 (citing State v. Cooper,
. Id. (citing Bazley v. Tortorich,
. Id. (citing Wall v. Close,
Id at 1065
. Id- at 1065-1068.
. Whether the title of Act 1 is indicative of its object is not before us.
. To amend and reenact R.S. 17:22(7)(a), 158(A)(1), 3973(3) through (6), 3981(4), 3982(A)(1)(a) and (2) and (B), 3983(A)(2)(a)(I), (3)(a), and (4)(a), (b), and (d), (B)(2), and (D), 3991(B)(3) and (13), (C)(l)(c)(iv) and (6), (D)(2)(a)(I) and (H), 3992(A)(1), 3995(A)(l)(introductory paragraph) and (c) and (4)(a), 3996(C) and (G), 3998, 4001(A) and (C)(1) and (2), and Part I of Chapter 43 of Title 17 of the Louisiana Revised Statutes of 1950, to be comprised of R.S. 17:4011 through 4025, to enact R.S. 17:10.5(F), 3973(2)(b)(vi) and (7), 3974, 3981(7) and (8), 3981.1, 3981.2, 3982(A)(3), 3983(A)(2)(a)(iii) and (d) and (3)(d) and (E)(3), 3992(D), and Part VII of Chapter 42 of Title 17 of the Louisiana Revised Statutes of 1950, to be comprised of R.S. 17:4002.1 through 4002.6, and to repeal R.S. 17:3991(B)(9) and 3996(A)(16) and (B)(4), relative to school choice; to provide relative to reports by the superintendent of education; to provide relative to the Student Scholarships for Educational Excellence Program; to provide relative to program eligibility and participation requirements for students and schools; to provide relative to selection and enrollment of eligible students; to provide relative to funding and payments to eligible schools including eligible nonpublic schools; to provide for reports; to provide for the submission of petitions by parents requesting that a school be transferred to the Recovery School District under certain conditions; to require rules and regulations to be adopted by the State Board of Elementary and Secondary Education for the petition process; to change charter proposal submission time lines; to provide a mechanism for Type 1 and Type 3 charter schools to covert to a Type 2 charter school under certain conditions; to authorize the state board to allow the state superintendent of education and the superintendent of the Recovery School District to amend the charter of Type 5 charter schools to accommodate a unified enrollment system; to modify the initial charter period; to provide for charter school admission requirements; to allow foreign language immersion schools to establish special admission standards; to provide for the qualifications of teachers; to provide relative to the evaluation of charter school teachers and other school employees; to provide relative to teacher certification requirements; to remove the requirement that charter schools comply with laws relative to the length of the school year; to provide for the Course Choice Program; to provide for program definitions and funding; to provide for the powers of the State Board of Elementary and Secondary Education and local public school systems relative to course providers; to provide relative to entities that authorize charter schools; to provide for certification of certain state agencies and nonprofit corporations as charter authorizes; to provide relative to the responsibilities of the State Board of Elementary and Secondary Education with respect to certification of such authorizes; to provide relative to requirements, powers, responsibilities, and limitations of such authorizes; to provide relative to schools whose charter is authorized by such entities, including matters related to funding for such schools; to provide for procedures, processes, fees, and regulations; to prohibit persons who have been convicted of any crime defined as a felony from being a local charter authorizer, member, officer or director of a charter school; to require certain local charter authorizes to comply with the Open Meetings Law, the Public Records Law, and the ethics code; and to provide for related matters.
. Id.
. State v. Ferguson,
. Id.
. Louisiana Federation of Teachers,
. Id. at 1068.
. Louisiana Federation of Teachers, supra at 1070; Wall, supra at 25.