McDaniel v. Hazlehurst City School District

The Fifth Circuit affirmed a district court ruling that a Mississippi school district violated an employee's procedural due process rights by failing to provide a hearing before non-renewing his contract. The court held that the employee's position required a state license, creating a property interest protected by state law and the Fourteenth Amendment.

Background

Todd McDaniel, a former principal and Director of Operations at Hazlehurst High School, was employed by the Hazlehurst City School District. In 2017, the district truncated his role and later attempted to reassign him. When the district offered a new at-will contract for the 2018-2019 school year, McDaniel requested a hearing under Mississippi law, which the district refused. McDaniel sued under Section nineteen eighty-three of Title forty-two of the United States Code, alleging a violation of procedural due process rights. The district court conducted a bench trial and awarded McDaniel damages and attorneys’ fees, finding he had a property interest in his employment.

The court’s reasoning

The Fifth Circuit reviewed the district court’s factual findings for clear error and legal questions de novo. The court determined that the contract governing McDaniel’s employment for the 2017-2018 school year was unambiguous and required a state license as a prerequisite of employment. Mississippi law requires written notice and a hearing when a contract for a licensed employee is not renewed. The court found no ambiguity in the contract, which was titled for an assistant superintendent, principal, or licensed employee. Regarding the school district’s argument that the contract was invalid because it was not fully spread across the minutes of a school board meeting, the court held that the minutes contained sufficient detail, including the job title and salary, to establish a valid contract eligible for renewal. The court concluded that the district court did not clearly err in finding McDaniel was entitled to a hearing.

What it means going forward

The decision reinforces that school district employees whose positions require state licensure possess a property interest in continued employment, entitling them to statutory notice and hearing procedures before non-renewal. It clarifies that meeting minutes need not contain every contract term to validate a public board’s contract, provided the essential terms are recorded.