## Facts

- Deborah Marvel, a certified teacher, worked for Coal Hill Public School District during the 1979–80 school year as part-time classroom teacher and part-time librarian.
- Her daily schedule consisted of a full teaching day (teaching five periods and serving as librarian for additional periods) and included typical teacher duties such as meetings, supervision, and administrative responsibilities.
- Arkansas law required districts to file a salary schedule setting minimum pay based on experience and qualifications; Coal Hill’s filed schedule set Marvel’s minimum full-time salary at $11,450.
- Marvel signed a written contract providing $9,800 for the year, and the district paid her that amount while accepting her services.
- The district argued that federal Title I funding used for part of her assignment restricted paying a higher salary.
- The trial court enforced the written contract and denied Marvel recovery of the difference between her pay and the minimum salary.
- Marvel appealed seeking the salary shortfall plus interest.

## Issues

1. Whether a teacher who performs full-time duties is entitled to the state-mandated minimum salary and the district’s filed salary schedule rate, notwithstanding a contract for less pay.
2. Whether a school district may justify paying below the statutory minimum by citing limitations associated with federal Title I funding.

## Decision

- The Arkansas Supreme Court reversed and remanded with instructions to enter judgment for Marvel.
- The court held Marvel qualified as a full-time teacher based on her actual schedule and responsibilities.
- The district was required to pay at least the minimum salary stated in its filed schedule and applicable statutes.
- Neither the lower-salary contract nor asserted Title I funding constraints excused noncompliance.
- Marvel was entitled to recover the difference between the minimum salary and what she was paid, plus applicable interest.

## Legal Principles

- A school district that employs a teacher performing full-time duties must pay no less than the statutory minimum salary reflected in the district’s filed salary schedule.
- Statutory minimum teacher-salary requirements are not waived or defeated by a teacher’s contract accepting a lower salary.
- Federal program funding mechanisms (including Title I) do not permit a district to pay below state-law minimum salary obligations; the district must cover any shortfall from other funds.
- Full-time status turns on actual duties and work schedule, not job labels used by the district.

## Conclusion

The court required the district to treat Marvel as a full-time teacher and pay her the statutory minimum salary under the district’s filed schedule, rejecting both the lower contract rate and Title I funding limitations as defenses.


Marvel v. Coal Hill Pub. Sch. Dist., 276 Ark. 369, 635 S.W.2d 245 (Ark. 1982)