## Facts

- Dennis Cullinan was employed by an Iowa school district under separate contracts as a high school teacher and head boys’ basketball coach; only the coaching contract was terminated.
- After Cullinan’s first season, parents and players complained that he used profanity, threats, and intimidation; several players quit during the season.
- The athletic director extended Cullinan’s probation and issued written warnings requiring a less threatening environment and no use of threats or intimidation as motivation.
- Additional complaints continued over subsequent seasons; administrators investigated and found complaints had merit based on interviews and written statements.
- The district imposed a remediation plan requiring, among other things, that individual “corrections” of players occur only with another adult present and that Cullinan not meet one-on-one with student-athletes.
- In December 2003, following a game, Cullinan met alone in a hallway with a player to “correct” him, contrary to the remediation directives; the player reported feeling intimidated.
- The district investigated, suspended Cullinan for two games, used anonymous player surveys and interviews, and concluded that intimidation concerns persisted and that the remediation plan had been violated.
- The superintendent recommended termination, and the board unanimously terminated Cullinan’s coaching contract for failure to lead the program effectively and failure to remediate leadership deficiencies.

## Issues

1. Whether substantial evidence supported the school board’s finding of “just cause” under Iowa Code §§ 279.15–.19A to terminate Cullinan’s coaching contract.
2. Whether a documented history of coaching misconduct may be considered, together with a later remediation-plan violation, to establish just cause even if past misconduct alone is insufficient.
3. Whether the board acted unreasonably, arbitrarily, or capriciously in treating the December 2003 one-on-one meeting as a serious breach warranting termination.

## Decision

- The Iowa Supreme Court vacated the court of appeals decision, reversed the district court’s affirmance of the adjudicator, and reinstated the board’s termination of Cullinan’s coaching contract.
- The court held the board had just cause, supported by a preponderance of the evidence, when the full record was considered.
- The court concluded the board’s decision was not unreasonable, arbitrary, or capricious given the prior documented problems, the targeted remediation plan, and Cullinan’s violation of a core remediation requirement.

## Legal Principles

- In reviewing a school board termination decision under Iowa Code chapter 279, courts assess whether the decision is supported by a preponderance of the evidence and whether it is unreasonable, arbitrary, or capricious.
- Past misconduct may not, by itself, be the sole ground for termination, but it may be considered to evaluate whether deficiencies were corrected and to gauge the seriousness of a later violation.
- A remediation plan term aimed at preventing recurrence of documented misconduct is not merely technical; violating a central remedial restriction can constitute evidence of failure to remediate and support just cause.
- Substantial deference is owed to a school board’s personnel judgments where student welfare and program environment are implicated.

## Conclusion

The Iowa Supreme Court upheld the school board’s termination of a coaching contract for just cause, relying on a sustained record of intimidation-related concerns, explicit remedial conditions imposed to correct them, and a later breach of a key remediation requirement demonstrating that the deficiencies had not been corrected.


Bd. of Dirs. of Ames Cmty. Sch. Dist. v. Cullinan, 745 N.W.2d 487 (Iowa 2008)