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Vail v. Board of Education of Paris Union School District Number 95
Facts
A search committee for the Board of Education of Paris Union School District No. 95 (“Defendant”)went to Joliet, Illinois to recruit Jesse Vail (“Plaintiff”) to be an athletic director and football coach. Plaintiff had been living with his family in Joliet for thirteen years and had been working at a correctional facility for ten years. Plaintiff was worried about joining the committee because he had concerns about job security, the length of the contract, and the time needed to fix deficits in the school district’s athletic program. Still, committee stated that it was not able to make a commitment for more than one year and that the full board would determine the length of his contract. On June 1980, the board came to a resolution, and decided to extend Plaintiff’ an employment offer, which would secure his position for two years. At that time, the board guaranteed Plaintiff that the board would renew his contract at the completion of his first year. Plaintiff completed a written contract for the position, for a salary that was lower than his pervious position. Nonetheless, in March 1981, the board decided that it did not want to renew Plaintiff’s employment contract, but the board did not provide Plaintiff with a reason for his termination. Plaintiff brought suit against Defendant under 42 U.S.C. § 1983 on he grounds that Plaintiff had a property interest in his job and the board had deprived him of that interest without due process of law. The district court held that, because Plaintiff had a constitutionally protected interest in continued employment, board’s action constituted a violation of Plaintiff’s due process when the board terminated Plaintiff without cause before the expiration of his employment period. Subsequently, the district court granted Plaintiff $19,850.99 in damages. On appeal, the board alleged Plaintiff only had a subjective expectation that his employment would continue, Illinois law was the governing law of Plaintiff’s rights, and the proper remedy is not damages. Instead, the court should issue a hearing assess whether termination was justified or a remand to require Plaintiff to prove his damages.
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