District seeks sanctions against teacher who resigned mid-year over health issue

A school district filed a complaint against a teacher with the State Board for Educator Certification, alleging that the teacher's certificate should be sanctioned due to contract abandonment. The teacher requested a hearing before the State Office of Administrative Hearings.

At the hearing, the evidence introduced showed that the teacher was employed as a second-grade teacher under a term contract for the 2021-22 school year, with the first day of instruction on Aug. 23, 2021. The teacher's classroom had about 26-28 students.

The teacher testified that her job was the best job she ever had, but it changed dramatically after the COVID-19 pandemic. She noted that she was dealing with more student behavioral issues than before and that she observed significant education gaps. She testified that one day, based on stress, she was feeling dizzy at school and thought she had an anxiety attack. She visited the nurse’s office, but no one was there so she visited a counselor who took a blood pressure measurement. She was told it was too high and she needed to go home. She could not finish the school day and immediately went to see her physician.

She had numerous medical tests conducted — including a CT brain scan, EKG, and several blood cultures — and the tests indicated she was healthy except that she had high blood pressure. The teacher concluded that stress from work was the reason for her health condition, and she decided she needed to resign.

Five days later, she submitted a Voluntary Separation Form through an online portal. The district then notified the teacher that, because it received the resignation after the penalty-free resignation period of 45 days before the first day of instruction, it was authorized to report her to SBEC for sanctions.

In the letter, the district also requested that the teacher submit any medical documentation from a treating physician attesting to a medical or health issue within three days. That same day, the teacher submitted a letter from her physician to the district, which stated that the teacher "has been seen in the office for elevated blood pressure. She is not currently on medication, but she is being followed for this condition.” The teacher testified her health improved after her resignation because her stress level went down. She was on blood pressure medication for a short period of time but was able to stop taking it after her resignation.

The principal testified at the hearing, stating that the teacher was a caring, excellent teacher. The principal stated that the teacher's resignation caught the school off guard because she had not given anyone notice of any health issues prior to her resignation. She noted that the teacher did not seek any medical leave or time off. Further, to the principal's knowledge, the teacher did not consult any professionals about how to deal with stress and anxiety. Given that it was in the middle of the school year, the school did not have enough notice to find a replacement teacher and it had to hire an hourly worker to fill in for the classroom for the rest of the semester.

The district's board of trustees met and found that good cause did not exist for the teacher to abandon her contract and filed a complaint with SBEC against her.

The teacher argued that she resigned mid-year based on a “serious illness or health condition,” which under SBEC's rules is considered good cause to abandon her contract and would protect her from sanctions.

The administrative law judge, after hearing all of the evidence, disagreed.

Although there is no dispute that, generally, high blood pressure is a concerning health condition, in this case the teacher's physician did not recommend any specific treatments, behavioral changes, or medications to treat the condition. There was no indication that the doctor believed that the teacher should quit work.

In short, elevated blood pressure, itself, was not enough evidence to categorize the teacher's condition as “serious” to support “good cause” for her resignation, the judge ruled.

Based on the above, the administrative law judge found that the teacher did not have good cause to abandon her contract and recommended that the teacher's certification be suspended for one year.