North East Independent School District v. Riou (Opinion)Annotate this Case
The Supreme Court reversed the judgment of the court of appeals affirming the judgment of the trial court reversing the decision of the Commissioner of Education upholding the decision of the North East Independent School District board to end Respondent's continuing teaching contract, holding that the record supported the board's and Commissioner's decisions.
At issue was whether state and federal laws requiring school districts to record grades and evaluate student progress provide standards of conduct for the teaching provision such that the teacher's failure to comply with district policies implementing those laws supports termination for "good cause." The Commissioner agreed that Respondent's conduct was "good cause per se" for termination. The trial court reversed. The court of appeals affirmed, concluding that "good cause per se" has no basis in Tex. Educ. Code 21.156(a)'s good cause definition. The Supreme Court revered, holding (1) Respondent preserved her complaint for judicial review; (2) the Commissioner erred in employing the "good cause per se" test, which has no basis in the Education Code's plain text; and (3) evidence of a failure to meet a district policy that implements state law supports a good cause determination.