High school teacher petitioned for review of decision of board of trustees of county school district that terminated his teaching contract. The District Court affirmed. Teacher appealed.
The Supreme Court of Wyoming held that:
- A school board is not statutorily required to independently review the entire evidentiary record received by a hearing officer before accepting a recommended decision to terminate, suspend or dismiss a continuing contract teacher; and
- Due process did not require that school board independently review entire evidentiary record before accepting hearing officer’s recommendation to terminate teacher’s contract.
A school board is not required, under the provision of Wyoming’s Administrative Procedure Act (APA) applying to contested cases generally and a Wyoming statute applying specifically to contested cases before a school board, to independently review the entire evidentiary record received by a hearing officer before accepting a recommended decision to terminate, suspend, or dismiss a continuing contract teacher. Rather, those statutes, read together require only that a school board review a hearing officer’s findings of fact and conclusions of law, and any objections or exceptions thereto, before accepting a recommended decision.
Due process did not require that school board independently review entire evidentiary record before hearing officer before accepting hearing officer’s recommendation to terminate continuing contract high school teacher for insubordination. While teacher’s private interest was substantial, procedures used by board adequately safeguarded that interest, as teacher received notice of basis for contract termination and had an opportunity to be heard before neutral hearing officer and ultimately before the board, and voting members of the board reviewed hearing officer’s findings, conclusions, and recommended decision.