McNaughton v. Charleston Charter SchoolAnnotate this Case
In late 2008, Cynthia McNaughton, who was in her early to mid 50's at the time, was accepted into the South Carolina Department of Education's Program of Alternative Certification for Educators (PACE program), which enabled individuals who earned a college degree but did not complete a traditional teacher preparation program, to become certified South Carolina public school teachers. When she was hired, Appellant Charleston Charter School of Math & Science, Inc. knew that McNaughton was participating in the PACE program, and that her completion of the program was contingent upon her fulfillment of further requirements, including the completion of an induction teaching year. McNaughton signed an employment agreement, which stated that McNaughton "agree[d] to be a full-time teacher at Charleston Charter School for Math and Science for the school year 2010–2011." The employment agreement further stated that it was "contingent on funding and enrollment." McNaughton received positive feedback from her students and their parents. Neither the principal nor any other faculty member experienced any problems with McNaughton's performance as a teacher, and McNaughton was never disciplined for any matter. However, on December 1, 2010 (in the middle of the school year) the principal informed McNaughton that the school was terminating her employment. The principal told McNaughton that Appellant needed to use the funds designated for McNaughton's salary to hire and pay a new math teacher because some of the students had performed poorly on a recent math achievement test. McNaughton sued and won on her wrongful termination/breach of contract complaint. The School appealed the trial court's decisions denying its motions for a directed verdict and judgment notwithstanding the verdict (JNOV); permitting the jury to award special damages; and granting attorney's fees to McNaughton. Finding no reversible error, the Supreme Court affirmed.