A teacher sued his employing school district, arguing that he had not been given sufficient time to review
and sign his contract for the upcoming school year.
The teacher worked part time, and his contract stated that his employment began on Aug. 5, 2019, and ended on May 13, 2020. When the school district decided to make his position a full-time role, the teacher expressed interest, and on June 10, 2020, the school board approved offering the teacher the full-time position.
On June 22, the teacher was informed that his contract for the upcoming school year was ready to be signed. On June 29, he was reminded that his contract needed to be reviewed and signed by July 1. The teacher was out of town but stated that he would come in as soon as he was able. On July 6, he went to the school office and reviewed the contract and was told that he needed to sign the contract that day if he still wanted the job. The teacher felt that he did not have enough time to consider the contract, and did not sign it before leaving that day. On July 8, the school district withdrew its offer of a contract.
The teacher sued the school district in federal court, arguing that the district
violated the due process clause of the 14th Amendment. The district court
dismissed the lawsuit and the teacher filed an appeal to the Fifth Circuit
Court of Appeals, which covers Texas.
On appeal, the teacher argued that he had a protected property interest in the position of full-time teacher that was offered to him. A teacher has a property interest in continued employment if there is a law, written contract or mutually explicit understanding, such as an implied contract. However, the court of appeals found that there is no property interest in prospective employment.
In this case, the teacher's previous
part-time contract with the district ended on May 13, 2020, so he was not
employed by the district when the school board approved offering him a full-time position on June 10. Although he did have a property interest in
his job during the contract term, that protection stopped when his contract
ended and he did not have a continued interest in his job after that point. The
court of appeals upheld the decision of the district court to dismiss the
The teacher in this case is from Missouri. However, this decision also applies to Texas and would likely apply to a contract signed by a teacher in Texas.
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