## Facts

- Ethel Hatton was a long-serving, contract sixth-grade teacher in the Columbus Municipal Separate School District in Mississippi.
- Principal Marshall Wicks met with Hatton, two other available sixth-grade teachers, a 13-year-old student with disciplinary problems, and the student’s mother.
- Wicks asked the student to choose among the three teachers; the student chose Hatton, and Wicks stated the student would be placed in her class.
- When the student’s mother attempted enrollment the following Monday, Hatton refused to enroll the student.
- Later that day, Wicks told Hatton she was obligated to accept the student; Hatton refused and left the meeting.
- Wicks later scheduled a follow-up conference for ten days later; Hatton did not attend.
- The student was assigned to another teacher.
- Hatton was terminated for two alleged instances of insubordination: refusing the student and refusing to cooperate in conferences.
- Hatton pursued administrative review before the superintendent, the school board, and the state education department; each upheld the discharge.
- About five years later, Hatton sued under 42 U.S.C. § 1983, alleging the discharge violated substantive due process under the Fourteenth Amendment.

## Issues

1. Whether terminating a tenured public school teacher for refusing a principal-directed student assignment and refusing to participate in administrative conferences violates substantive due process under the Fourteenth Amendment, actionable under 42 U.S.C. § 1983.

## Decision

- The Fifth Circuit affirmed judgment for the defendants.
- The court held Hatton failed to show substantial evidence of a substantive due process violation.
- The discharge, based on insubordination tied to classroom assignment and cooperation with administration, did not amount to arbitrary or constitutionally impermissible governmental action.

## Legal Principles

- Section 1983 does not convert routine public-employment disputes into federal constitutional claims.
- School administrators have broad discretion over student placement and classroom management decisions.
- A public employee’s termination violates substantive due process only if the governmental conduct is arbitrary in the constitutional sense (commonly described as conscience-shocking) or infringes a recognized constitutional interest.
- Absent allegations such as discrimination or interference with protected constitutional rights, discipline for insubordination generally does not support a substantive due process claim.

## Conclusion

The Fifth Circuit concluded that a tenured teacher’s dismissal for refusing a principal’s student-assignment directive and declining to engage in scheduled administrative meetings was a managerial discipline matter within school authority and did not rise to a substantive due process violation under the Fourteenth Amendment.


Hatton v. Wicks, 744 F.2d 501 (5th Cir. 1984)