Board of Directors of Ames Community School District v. Cullinan
Iowa Supreme Court
745 N.W.2d 487 (2008)
A school board's termination of a coach for just cause may examine the entire course of the coach's employment.
A school board (defendant) terminated its high school coach, Dennis Cullinan (plaintiff). For years, players and parents had complained of Cullinan's profanity, threats, and intimidation. After Cullinan's first year of coaching, the administration placed him on probation due to complaints. The following year, parents and students again complained about Cullinan's conduct. The athletic director investigated and determined the complaints had merit. The following year, the administration conducted a larger inquiry because of additional complaints. The administration gathered letters from parents and students detailing instances of Cullinan's intimidation. The administration investigated and then determined that Cullinan needed to take corrective action. The assistant superintendent wrote a memo to Cullinan indicating that Cullinan should no longer meet one-on-one with student-athletes. The board then established a remediation plan. The following year, an athlete made a critical error in a game. Cullinan pulled the athlete aside for a one-on-one correction. The student-athlete complained that Cullinan intimidated him. The administration investigated and then suspended Cullinan. The superintendent then recommended termination of Cullinan's contract. The school board voted unanimously to terminate Cullinan. Cullinan appealed to an adjudicator, claiming the termination was not for just cause, because the singular one-on-one student-athlete correction did not provide sufficient grounds to justify termination. The adjudicator reversed the termination. The board appealed to the state trial court, which affirmed the adjudicator's decision. A state appellate court affirmed the trial court's verdict. The board appealed to the state supreme court, arguing that Cullinan's termination was just in light of his entire coaching career.
May a school board's termination of a coach for just cause examine the entire course of the coach's employment?