Migra v. Warren City School District Board Of Education

Facts

P was employed by D from August 1976 to June 1979. She served as supervisor of elementary education. Her employment was on an annual basis under written contracts for successive school years. On April 17, 1979, at a regularly scheduled meeting, the Board, with all five of its members present, unanimously adopted a resolution renewing Pa's employment as a supervisor for the 1979-1980 school year. P accepted the renewed appointment by letter dated April 18 delivered to a member of the Board on April 23. Early the following morning her letter was passed on to the Superintendent of Schools and to the Board's President. The Board held a special meeting, called by its President, on the morning of April 24. Four of the five members of the Board were present. The President read P's acceptance letter. Then, after disposing of other business, a motion was made and adopted, by a vote of 3 to 1, not to renew P's employment for the 1979-1980 school year. P was given written notice of this nonrenewal and never received a written contract of employment for that year. P sued the Board and its three members (Ds) who had voted not to renew her employment for breach of contract by the Board and wrongful interference by the individual members. The state court, after a bench trial, 'reserved and continued' the 'issue of conspiracy' and did not reach the question of the individual members' liability. It ruled that P had accepted the employment proffered for 1979-1980, that this created a binding contract and the subsequent actions purporting not to renew the employment had no legal effect. P was ordered to be reinstated to her position and compensatory damages. P them moved the state trial court to dismiss without prejudice 'the issue of the conspiracy and individual board member liability.' That motion was granted. The Ohio Court of Appeals affirmed. Review was denied by the Supreme Court of Ohio. P then filed the present action in federal court. P alleged that she had become the director of a commission appointed by the Board to fashion a voluntary plan for the desegregation of the District's elementary schools; that she had prepared a social studies curriculum; that the individual defendants objected to and opposed the curriculum and resisted the desegregation plan; that hostility and ill will toward P developed; and that, as a consequence, the individual defendants determined not to renew petitioner's contract of employment. P claimed that Ds' actions were intended to punish her for the exercise of her First Amendment rights. She also claimed that the actions deprived her of property without due process and denied her equal protection under the First, Fifth, and Fourteenth Amendments and 42 U. S. C. §§ 1983 and 1985. P requested injunctive relief and compensatory and punitive damages. Ds moved for summary judgment on the basis of res judicata and the bar of the statute of limitations. The District Court granted summary judgment for Ds and dismissed the complaint. The appeals court affirmed. D appealed. 

Issues

Rule of Law

Holding and Decision

Legal Analysis

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