The Appellate Group

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.

Read the full court opinion