Heyl Royster

Teacher's Employment Reinstated after Appellate Court finds her Dismissal was Unfounded

January 13, 2016

Lynne Beggs, a full-time high school teacher at Murphysboro Community School District No. 186, never received an unsatisfactory evaluation, but the school board elected to dismiss her after she took frequent absences during the 2011 school year to care for her dying mother.

After Beggs' father passed in 2011, her mother's health deteriorated quickly, and Beggs was absent from school frequently that year. The school's administration became increasingly frustrated by her late arrivals and failure to prepare lesson plans for the substitute teacher.

Eventually, the board suspended her without pay and adopted a resolution to issue a notice of remedial warning pursuant to the Illinois School Code. The notice required Beggs to correct her conduct by reporting to work by 8:15 a.m., to begin teaching by 8:30 a.m., and to have lesson plans prepared for the substitute teacher for days she was absent. Any violation would lead to dismissal.

As her mother's health continued to decline, Beggs elected to use additional sick leave. When she returned to work, she was immediately suspended from her teaching position. The board adopted a resolution to dismiss Beggs pursuant to the Illinois School Code. Beggs mother died shortly after her dismissal.

After her dismissal, Beggs requested a hearing before an impartial hearing officer, who recommended that Beggs' employment be reinstated because her dismissal was unfounded. The hearing officer found that the school board did not give Beggs a "reasonable opportunity" to correct her job performance deficiencies.

Contrary to the hearing officer's decision, the board found that Beggs' dismissal was warranted and issued a written order to that effect. The board established that Beggs violated her notice of remedial warning because she did not teach from "bell to bell" on March 19, she failed to timely report to work by 8:15 a.m. on March 20, and she neglected to have lesson plans for the substitute teacher on March 21 and 22 by 8:30 a.m. The board believed that Beggs performance issues were detrimental to the school district and harmful to the best interests of the students.

Beggs appealed the school board's decision to an Illinois state court, and based on the evidence presented, the court found that her dismissal was unwarranted and ordered the school to reinstate Beggs to her full-time teaching position with back wages and benefits.

The school district appealed the court's decision to the Appellate Court of Illinois Fifth District. The appellate court affirmed the circuit court's decision that required Beggs to be reinstated. In its written decision, the appellate court explained that the reasons the school board used to dismiss Beggs were "arbitrary, unreasonable, and unrelated to service." Beggs v. The Board of Education of Murphysboro Community Unit School Dist. No. 186, 2015 IL App (5th) 150018.

The appellate court noted poignantly that "[a]fter years of dependable service, the plaintiff's work product suffered during one of the most emotionally difficult periods of her life ... no one's work is tested in a vacuum, and the school districts and their employees may be better served by working together to provide that a remediation period begins after such critical events have concluded." Beggs, 2015 IL App (5th) 150018, ¶ 49.

Situations like the one described in the Beggs decision can be difficult to navigate. According to the appellate court, the school board may have been better served to issue a notice of remedial warning after Beggs difficult situation had passed, especially in light of her stellar work history.

The attorneys at Heyl Royster can advise school districts and boards about notices of remedial warnings for performance-related issues, notices of dismissal, and other employment and education-related matters.

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