Unified School District No. 446, Independence, Kansas v. Sandoval

Facts

Defendant began her employment with Plaintiff on September 1, 2000. During the 2007-08 school year, she taught Spanish at Independence High School. On February 22, 2008, the school principal informed her that he was recommending Plaintiff not renew her teaching contract for the 2008-09 school year. During a school-board meeting, Defendant’s union representative verbally negotiated a settlement agreement with the school board. Defendant, through her representative, accepted an offer which constituted 180 days of paid leave to qualify for KPERS disability benefits, which would require her to leave the classroom on March 28, 2008; paid insurance on the bottom tier for 5 years; and a lump-sum payment of $20,000 in the event that she did not qualify for disability benefits. District policy stated that the board could consider the resignation of an employee that was submitted to the board in writing. The minutes from the school-board meeting did not mention Defendant’s resignation. After the meeting, the school superintendent emailed the union representative a draft of the agreement and the two exchanged emails regarding modifications to the agreement. Defendant then informed the union that she had changed her mind and wanted to proceed with a due-process hearing. After being notified by the union representative, the superintendent sent Defendant a letter stating that because Defendant changed her mind about the agreement, the board would proceed with a resolution to non-renew Defendant’s contract. Defendant went to the school and taught her class as she usually did. Plaintiff provided no substitute teacher for her classroom on that day or any of the following days. She finished her teaching assignment for the 2007-08 school year. On April 14, 2008, Plaintiff’s board adopted a resolution of nonrenewal of Defendant’s contract, including a clause reserving the right to enforce the oral agreement.

After the end of the school term, Plaintiff filed a petition in Montgomery County District Court, seeking a declaratory judgment that Defendant had entered into an oral contract governing the terms of her separation from Plaintiff. The trial court agreed with Plaintiff, holding that Defendant had entered into a binding oral contract and thus had waived her statutory due process hearing. The appeals court affirmed the decision. Defendant then appealed to the state supreme court.