Harrah Independent School District v. Martin

Many professions require their members to obtain continuing education credits as a means of staying current and up-to-date with new techniques and research within their fields. Moreover, state educational policies often require teachers and administrators to earn staff development hours or credits annually to retain their certification for employment. To this end, states typically permit local boards of education to determine specific guidelines and programs for acquiring the continuing education credits. In Harrah Independent School District v. Martin (1979), the Supreme Court judged the reasonableness of public school professional development policies as well as teacher dismissal of those who fail to meet the district requirements.

Facts of the Case

Mary Jane Martin, hired by the Harrah (Oklahoma) Independent School District in 1969, refused to comply with the school board’s continuing education policy to obtain 5 hours of college credit every 3 years. From 1972 to 1974, Martin forfeited salary increases as an alternative to acquiring the additional college credits. After Martin’s contract was renewed for the 1973–1974 school term, the Oklahoma Legislature mandated salary increases for teachers regardless of the continuing education requirements. Not able to withhold salary increases as a penalty, the school board then required the teacher to obtain the 5 hours of college credits by April 10, 1974, a 7-month period, or her contract would not be renewed, for noncompliance with the continuing education requirement. Martin did not earn the required professional development credits, and the school board chose not to renew her contract for the following term.

Oklahoma statutes at that time required renewal of a tenured contract unless the teacher was guilty of willful neglect of duty, among other grounds. Since the teacher did not comply with the continuing education requirements, the school board voted not to renew her contract based on willful neglect of duty. The respondent alleged she was denied equal protection and deprived of protected liberty and property interests without due process, all in violation of the Fourteenth Amendment of the U.S. Constitution. The school district prevailed in federal district court, but the Tenth Circuit Court reversed in favor of the teacher.

The Court’s Ruling

The Supreme Court reviewed Martin’s claims of violation of her due process and equal protection rights. The Court easily found that Martin had received procedural due process since she had exercised her right under state law and had a hearing while represented by an attorney. To have prevailed on her substantive due process claim alleging denial of liberty and property interests, the Court explained that Martin had to prove that the board action was arbitrary and that there was no rational relationship between the board’s action and its interest in providing well-trained teachers. The Court found that the board’s decision not to renew the contract, but only prospectively, was reasonable once the Oklahoma Legislature removed the penalty of salary increase denial.

Consistent with previous rulings, the Court rejected Martin’s equal protection claim. The Court found that the sanction of not renewing Martin’s contract was rationally related to the board’s objective of enforcing the continuing education requirement. The Court was satisfied that the board’s enforcement of its policy was consistent, not selective. Further, the Court recognized that school officials obviously have a legitimate interest in teacher qualifications. The Court thus concluded that school boards can easily justify continuing education requirements to ensure that teachers stay current with the latest research and techniques in education.

Martin provides considerable guidance for school boards as they develop personnel policies and regulations. In light of Martin, board policies must be reasonable, and educators must have procedural and substantive safeguards against arbitrary dismissal and nonrenewal. Martin also upholds the power of school officials to require professional educators to continue their education as a reasonable exercise of board authority to meet the objective of providing welltrained teachers for the students. As such, Martin reaffirms the status of public school educators as career professionals whose training never ends during their working lifetimes. While guidelines may vary, continuing education credits are a common, and lawful, requirement among states and school districts to assist teachers in becoming highly qualified.

Marilyn Denison

See also Due Process; Due Process Rights: Teacher Dismissal; Equal Protection Analysis; Fourteenth Amendment; Teacher Rights

Legal Citations

  • Harrah Independent School District v. Martin, 440 U.S. 194 (1979). 
  • Kelley v. Johnson, 425 U.S. 238 (1976). 
  • Oklahoma Statute, tit. 70, § 6–101.22 (2006).