Here, Anderson has no actual or apparent authority to hire permanent certified employees. That function is statutorily reserved for the Board. Therefore, Anderson is incapable of making a promise to McCormick and promissory estoppel does not apply. Even if Anderson had authority to bind the District, McCormick is not entitled to rely. The statute requires that teachers sign a written contract.
Public policy requires a background check before teachers are permanently employed.
Teachers should be aware of the statutory procedures. An applicant is not entitled to rely where statutory procedure is not followed. McCormick was paid substitute wages. She knew that her paperwork had to be processed and that her references reviewed. As a matter of law, she should have known that she was not permanently employed and therefore was not entitled to rely on Anderson's representations.