## Facts

- Dr. Cynthia Martinek served as the district’s elementary (PK–6) principal since 1993 and held advanced degrees and multiple administrative licenses.
- She worked under a two-year administrator contract beginning with the 2005–2006 school year.
- The school district faced declining enrollment and related financial pressure affecting revenues and expenditures.
- The district notified Martinek it intended to terminate her employment effective June 30, 2007, citing declining enrollment, budget problems, reduction of positions, and realignment of school organization.
- As part of the realignment:
  - The prior 7–12 principal became superintendent and part-time elementary principal.
  - The former superintendent became assistant superintendent, part-time elementary principal, and construction supervisor for a new elementary school, with some compensation allegedly paid from construction funds.
  - Shortly after Martinek’s termination, the district hired a new 7–12 principal/activities director.
- Martinek contended the district was not truly reducing administrative staffing and that the stated reasons were a pretext, so “just cause” was not proven.

## Issues

1. Whether a preponderance of competent evidence supported the school board’s decision that “just cause” existed under Iowa Code § 279.24 to terminate Martinek based on declining enrollment, budget concerns, staffing reductions, and administrative realignment.

## Decision

- The Iowa Supreme Court affirmed the district court’s judgment upholding the school board’s termination decision.
- The court held that a preponderance of competent evidence supported termination due to declining enrollment, budget concerns, and essential staff reductions implemented through administrative realignment.
- The court rejected Martinek’s claim that the district’s reasons were pretextual, concluding the record supported the board’s finding that the restructuring was financially motivated and nonarbitrary.

## Legal Principles

- Iowa Code § 279.24 permits termination of an administrator contract only for “just cause.”
- “Just cause” may be established by legitimate, nondisciplinary grounds such as declining enrollment, bona fide budget constraints, and necessary staffing reductions or reorganizations, if supported by the record and not shown to be discriminatory or made in bad faith.
- On judicial review, courts assess whether the school board’s decision is supported by a preponderance of competent evidence in the administrative record, not whether the court would make the same staffing decision.

## Conclusion

The court upheld the termination because the record supported the school district’s determination that declining enrollment and fiscal pressures required an administrative reorganization that reduced or consolidated administrative functions, satisfying the statutory “just cause” standard under Iowa law.


Martinek v. Belmond-Klemme Cmty. Sch. Dist., 772 N.W.2d 758 (Iowa 2009)