Harrah Independent School District v. Martin

PETITIONER: Harrah Independent School District, et al.
RESPONDENT: Mary Jane Martin
LOCATION: Harrah High School

DOCKET NO.: 78-443
DECIDED BY: Burger Court (1975-1981)
LOWER COURT: United States Court of Appeals for the Tenth Circuit

CITATION: 440 US 194 (1979)
DECIDED: Feb 26, 1979
GRANTED: Feb 26, 1979

Facts of the case

Mary Jane Martin, a tenured teacher at Harrah Independent School District, was required to earn five college credits every three years as continuing education. Martin refused to comply with this requirement and did not receive a pay increase each year her contract was renewed. The Oklahoma legislature passed a law requiring a mandatory pay increase every year regardless of compliance with the continuing education. Looking for an alternative consequence, the school board warned Martin that they would not renew her contract the following year if she did not complete her continuing education. Martin refused, and the school board voted to terminate her for “willful neglect of duty”.

After unsuccessfully attempting to obtain administrative relief, Martin sued the school district for Fourteenth Amendment violations. The district court dismissed the case, but the U.S. Court of Appeals for the Tenth Circuit reversed, holding that the termination violated the Equal Protection and Due Process Clauses of the Fourteenth Amendment.

Question

Did the failure to renew Martin’s contract violate the Fourteenth Amendment?