## Facts

- Gerald Whaley was employed by the district for 19 consecutive years, serving as a teacher and former principal, and later as a reading teacher for grades 4–6.
- The school board issued Whaley a statutory notice of deficiency on May 5, 1980 under Minn. Stat. § 125.12, subd. 6 (1980), supplementing an earlier 1978 deficiency notice.
- The notice identified multiple alleged performance problems, including poor rapport with students, inadequate communication with parents and staff, misuse of class time, lack of punctuality, failure to follow the adopted reading program, irrational grading, and lack of student progress.
- During the 1980–81 school year, administrators observed Whaley’s classroom six times and met with him after observations as part of the evaluation process.
- On February 10, 1981, the board served a notice of proposed termination citing inefficiency, neglect of duty, and unfitness to teach, and alleging continued problems including lack of rapport, lack of student progress, and inadequate disciplinary techniques.
- Whaley requested a hearing; after receiving evidence, the board issued 44 findings of fact and concluded Whaley was inefficient, neglected duties, failed to follow instructions, and was unfit to teach, including findings that he relied heavily on worksheets, did not implement the district reading program, and that his students progressed more slowly than comparable students.

## Issues

1. Whether the school board’s termination decision under Minn. Stat. § 125.12, subd. 6 for inefficiency, neglect of duty, and unfitness to teach was supported by sufficient evidence in the record.
2. Whether the district court exceeded the proper scope of judicial review by substituting its assessment of teaching performance for the school board’s judgment.

## Decision

- The Minnesota Supreme Court reversed the district court and reinstated the school board’s termination of Whaley’s continuing-contract position.
- The court held the board’s decision was supported by evidence reasonably tending to sustain statutory cause, including a documented pattern of deficient performance and lack of student progress.
- The court held the district court erred by reweighing evidence and substituting its judgment on evaluative and pedagogical questions committed to the school board.

## Legal Principles

- Under Minn. Stat. § 125.12, subd. 6 (1980), a continuing-contract teacher may be terminated for cause, including inefficiency in teaching, neglect of duty, and unfitness to teach.
- Judicial review of a school board’s termination decision is deferential; courts may not reweigh evidence or replace the board’s evaluation of teaching performance when the decision is supported by the record.
- “Unfitness to teach” may be shown by a sustained pattern of documented deficiencies (e.g., failure to follow required curriculum, persistent classroom-management problems, and demonstrated lack of student progress), not only by isolated misconduct.

## Conclusion

The court upheld the board’s discharge of a continuing-contract teacher because the board developed detailed findings showing ongoing performance deficiencies after notice and evaluation, and reviewing courts must defer to a board’s fact-finding and educational judgments when supported by the record.


Whaley v. Anoka-Hennepin Indep. Sch. Dist. No. 11, 325 N.W.2d 128 (Minn. 1982)