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Teacher Tenure Case. Dr. Adrienne Lancaster v. Carlynton School District. Background. Dr . Adrienne Lancaster Curriculum Director of Carlynton School District Position Eliminated Demoted to Director of Pupil Services Appealed to the Secretary of Education. Timeline of Events .

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teacher tenure case

Teacher Tenure Case

Dr. Adrienne Lancaster


Carlynton School District

  • Dr. Adrienne Lancaster
    • Curriculum Director of Carlynton School District
  • Position Eliminated
    • Demoted to Director of Pupil Services
    • Appealed to the Secretary of Education
timeline of events
Timeline of Events
  • June 29, 2004- Position of Curriculum Director was to be eliminated effective August 1, 2004
  • June 30, 2004- Dr. Lancaster sent a letter to the District requesting a hearing on the demotion
timeline continued
Timeline Continued
  • July 6, 2004- Dr. Lancaster received letter
    • Position was eliminated due to budgetary reasons
  • March 7, 2005- A hearing was held
    • Board gave no reason as to why the hearing was delayed to that date
    • Board decided they would uphold the demotion to June 22, 2005
  • Kirby Christy- District’s Business Manager
    • testified that three positions were eliminated from the District for the 2004-2005 school year
      • one being Dr. Lancaster’s position of Curriculum Director
      • would save the district approximately $185,000
hearing continued
Hearing Continued
  • Dr. Lancaster presented evidence that two other district employees, both being principals, transferred positions and took their salaries with them.
  • The District stated that these two employees transferred from one principal position to another, and that nothing in the records shows that these were demotions.
  • A demotion, by its very definition, involves reassignment to a position that has less authority, prestige or salary.
  • Once a demotion is found to be procedurally and substantively proper, all aspects of itare considered procedurally and substantively proper, including the loss in authority, prestige and/or salary associated with the demotion.
demotion continued
Demotion Continued
  • Hearing on the demotion of a professional employee
    • two questions are brought before the school board:
      • (1) whether or not the professional employee has been demoted
      • (2) in the event the professional employee has been demoted, the reason for such demotion must be made clear and apparent
  • A valid reason for eliminating positions or demoting employees is the need to reduce the district’s budget.
hearing continued1
Hearing Continued
  • Dr. Lancaster agreedthe position of Curriculum Director being eliminated was a procedurally sound demotion
    • She argued that the reduction in salary was improper
  • Dr. Lancaster sought relief in the form of salary reinstatement to the level at which she was paid as Curriculum Director, plus the recent increase granted to her for the 2005-2006
hearing continued2
Hearing Continued
  • Dr. Lancaster also sought“damages in the form of back pay up to the date of her salary reinstatement.”
  • The parties then agreed to waive oral argument and submit the matter to the Secretary on briefs.
  • Both the District and Dr. Lancaster submitted briefs in support of their respective positions.
hearing continued3
Hearing Continued
  • It wasdetermined that Dr. Lancaster’s demotion was procedurally and substantively proper .
  • The only consideration remaining waswhen the demotion became effective.
    • A demotion cannot become effective until after the hearing has taken place.
  • Dr. Lancaster had failed to meet her burden of establishing that her demotion was arbitrary, discriminatory or based on improper considerations
    • Demotion was affirmed
  • Demotion was not effective until June 22, 2005
    • Dr. Lancaster was hereby awarded back pay in the amount that she would have received from the period of time between August 1, 2004 and June 22, 2005, during which time she was demoted without a hearing.