Anderson v. Dagget School District
Anderson v. Dagget School District, 2023 UT App 76 (Tenney, J.)
Statutory Interpretation
Clark Anderson taught in the Daggett School District for 24 years. After a series of minor infractions, the District terminated his employment. Anderson challenged his termination, but a designated Hearing Officer upheld the termination. The Utah Court of Appeals reversed the termination and remanded for a new determination, holding:
- A statute specifying that the court of appeals had jurisdiction over the case could apply retroactively.
- Public school teachers are public employees, so the Hearing Officer should have applied the “consistency and proportionality” standard to Anderson’s case, not the “shocks the conscience” standard he applied.
- Practice tip: New language in the 2021 statutory amendments—explaining that the court of appeals’ review shall be for “abuse of discretion”—may affect parties going forward.