## Facts

- Stanley Oneal, a public school teacher, signed an employment contract with Colton Consolidated School District No. 306 for the 1974–75 school year.
- During summer 1974, Oneal’s diabetic condition caused worsening eyesight that left him unable to perform essential teaching duties.
- On July 24, 1974, Oneal submitted a written resignation seeking release from the contract after using 27.5 days of accumulated sick leave.
- The District did not act on the resignation before the school year began, and Oneal did not report for work.
- On September 20, 1974, the District rejected Oneal’s conditional resignation tied to sick leave.
- On September 25, 1974, Oneal reiterated he would resign only if he received the accumulated sick leave benefit.
- On October 3, 1974, the District both (a) discharged Oneal for probable cause and (b) accepted his resignation while refusing to pay accumulated sick leave.
- Oneal appealed to superior court under RCW 28A.58.515 and sought damages including sick leave; the superior court upheld the District’s actions.

## Issues

1. Whether the teaching contract ended by resignation, by district discharge, or by discharge by operation of law due to impossibility of performance.
2. Whether Oneal was entitled to payment or use of 27.5 days of accumulated sick leave based on his conditional resignation or inability to perform.
3. Whether the superior court abused its discretion by denying Oneal attorney’s fees.

## Decision

- The Court of Appeals held Oneal’s duty to teach was discharged by operation of law through impossibility of performance caused by medical incapacity.
- The District’s formal discharge for cause was improper and was reversed.
- The denial of accumulated sick leave benefits was affirmed.
- The denial of attorney’s fees was affirmed because no abuse of discretion was shown.

## Legal Principles

- A teacher’s employment relationship with a school district is contractual, and general contract principles govern the parties’ rights and duties.
- A contractual duty may be discharged by impossibility when a supervening incapacity or disability, not caused by the promisor’s fault, makes performance objectively impossible.
- Discharge of a duty by impossibility excuses nonperformance but does not, by itself, create entitlement to additional monetary benefits beyond those provided by statute or contract (including accumulated sick leave).
- Appellate review of a trial court’s decision on attorney’s fees in teacher–district disputes is for abuse of discretion.

## Conclusion

The court treated the teacher–district relationship as a contract and concluded that medical incapacity rendered performance impossible, discharging the teacher’s duty by operation of law and requiring reversal of the district’s discharge action, while leaving intact the denial of sick leave benefits and attorney’s fees.


Oneal v. Colton Consol. Sch. Dist. No. 306, 16 Wash. App. 488, 557 P.2d 11 (Ct. App. 1976)