In early December, a unanimous Illinois Supreme Court held that a Board of Education’s decision to terminate a tenured high school teacher’s employment was “arbitrary, unreasonable, and unrelated to the requirements of service,” affirming an earlier order that she be reinstated with back pay and benefits. The Court affirmed a decision from the Fifth District in Beggs v. Board of Education of Murphysboro Community Unit School District No. 186. Our report on the underlying facts and lower court decisions in Beggs is here.
The plaintiff in Beggs began her employment at the high school as a full-time math teacher during the 1993-94 school year. Beginning in 2011, her mother’s health began to deteriorate, resulting in frequent hospitalizations. School administrators were aware of the plaintiff’s mother’s health issues. Nevertheless, they became increasingly concerned about the plaintiff’s late arrivals, failure to submit lesson plans on some occasions when she was absent, and the generally slow progress of her first hour geometry class. The Principal issued a “Letter of Concern” in late January 2012, noting plaintiff’s propensity to arrive late for work and the issues with lesson plans. She allegedly arrived late the next two days after receiving the letter. After further late arrivals, she was suspended with pay from February 10 to February 21, 2012. The Superintendant wrote the school board a letter requesting that they authorize the issuance of a notice of remedial warning. The Board did so, as well as converting her earlier suspension into one without pay. Plaintiff was given a leave of absence from February 27 to March 14, 2012, but her alleged absences continued into March after her return to work. On April 30, 2012, the Board adopted a resolution authorizing her dismissal.
Plaintiff timely requested a hearing before an impartial hearing officer. Following a full evidentiary hearing with several witnesses testifying, the hearing officer recommended that the plaintiff be reinstated with no loss of seniority and full back pay and benefits. The Board reviewed the hearing officer’s findings of fact and recommendation, made supplemental findings, and in July 2013, made a final decision to dismiss the plaintiff notwithstanding the hearing officer’s decision.
The plaintiff filed a complaint seeking administrative review. The circuit court held that the Board had given inadequate deference to the hearing officer’s decision, and that the Board’s finding were arbitrary, unreasonable and unrelated to service. The circuit court ordered the plaintiff’s reinstatement, and the Fifth District affirmed.
In an opinion by Justice Thomas, the Supreme Court unanimously affirmed the Appellate Court. The Court began by addressing the Board’s argument that the plaintiff had failed to properly invoke the court’s jurisdiction via administrative review because she incorrectly identified the Board’s president and mailed the complaint and summons to the previous address of the Board. The Court noted that the Act specifically bars the dismissal of an action for failure to correctly name a Board president when the Board itself is properly named. Given that the Board received the papers within the thirty-five day statutory limit, the Court held that the Board had not been prejudiced by the error.
The Court then turned to the issue of the proper standard of review. The plaintiff argued that the Appellate Court had properly given deference to the hearing officer’s decision, but the Board argued that its own decision was the one entitled to deference for purposes of appellate review. The Court concluded that the Board’s view was correct. Although this “does not mean that the hearing officer does not pay a strong role in the process,” administrative review as of the Board’s decision, not the hearing officer’s.
Nevertheless, the Court concluded that the Board’s supplemental factual findings were against the manifest weight of the evidence. The Board had pointed to the plaintiff’s late arrival of March 20, but the Court noted that her lateness had been excused by the superintendant. The Board relied in part on issues with transmission of lesson plans on two days in March, but the Court found that the plans had been received at school by 8:30 a.m. both days. The Court did not find the Board’s third principal finding to be against the manifest weight of the evidence, but noted that the Board’s conclusion “appears troubling when considered in the context of other undisputed evidence.” Given that the two of the Board’s three principal findings were against the weight of the evidence and the third appeared to be an “understandable and minor breach,” the Court held that the Board’s decision to dismiss the plaintiff was clearly erroneous.