School Administrators Not Entitled to Reinstatement After District Reorganization

The Supreme Court of Ohio today declined to reinstate four Monroe County school administrators whose positions were eliminated.

In a unanimous per curiam opinion, the Supreme Court found the Switzerland of Ohio Local School District Board of Education developed and followed the proper policy to suspend the contracts of four administrators in 2021. That year, the board hired a new superintendent who considered the district’s administration to be overstaffed.

The administrators argued the local policy used to suspend their contracts was unlawful because it did not include all the provisions required under state law. The Court stated that while the local policy might not have been drafted precisely, state law does not entitle them to be reinstated to their eliminated positions or receive backpay.

The decision affirmed a Seventh District Court of Appeals ruling, which found the school board policy was valid and the reasons given for the administrators’ suspensions were legitimate.

School Personnel Contest Position Elimination
In 2019, James Ruble, Linda O’Connor, and Cynthia Brill were appointed by a recently hired superintendent to administrative positions, and their contracts extended through the 2021-2022 school year. Suzanne Holland was appointed to an administrative position in 2020, which also extended through the 2021-2022 school year. At the end of the 2021 school year, the superintendent stepped down and took a principal position. A new superintendent appointed in 2021 told the school board he believed the district had too many administrators – one for every 40 to 50 students – compared to the statewide average of one for every 130 students.

In August 2021, the board approved the new superintendent’s recommendation to suspend the contracts for Ruble, O’Connor, Brill, and Holland so they would not be in effect for the 2021-2022 school year.

State law, R.C. 3319.17, provides a process for suspending the contracts of public school teachers and administrators. Another law, R.C. 3319.171, permits a board of education to develop its own policy to suspend an administrator’s contract. Switzerland of Ohio Local adopted its policy, Policy 1540, in 2012. The four administrators contested their suspensions by seeking a writ of mandamus in 2022 from the Seventh District Court of Appeals. They claimed the reasons for their suspensions were pretext, meaning the board provided a justification that wasn’t the real reason for their dismissal. They also claimed the policy did not comply with the requirements of R.C. 3319.171. One provision of the law should give them the right to “restoration” and require the board to place them in other positions for which they qualify. The administrators requested the Seventh District order them to be reinstated to their prior positions and receive backpay.

In 2024, the Seventh District ruled that the board provided legitimate reasons for their suspensions. When considering their certifications, only Ruble qualified for one of the available positions under the new superintendent’s reorganization. Ruble declined the position.

The administrators appealed the Seventh District’s decision to the Supreme Court but limited their challenge to the claim that Policy 1540 was invalid because it did not include all the requirements mandated by R.C. 3319.171. They maintained if the policy is invalid, so too are their contract suspensions.

Supreme Court Analyzed Suspension Laws
The per curiam opinion explained that to be entitled to a writ of mandamus, the administrators must prove three points, including that they have a clear legal right to the relief they request. The Court examined R.C. 3319.171 to address the administrators’ complaint that the local policy did not include required provisions.

If a local school board adopts a contract suspension policy under R.C. 3319.171, it must include three specific provisions. The administrators argued Policy 1540 lacked two requirements, a procedure for determining the order of suspensions and the right to restoration for administrators “if and when any positions become vacant or are created for which any of them are or become qualified.” The third requirement is the board must provide a reason for the suspension, which may include the financial conditions of the school district.

The Court wrote that the law does not give the suspended administrators a clear right to what they seek, reinstatement to their former positions, which no longer exist, with backpay and benefits.

The Court noted some state laws provide specific procedures that must be followed to terminate a public school teacher or administrator’s contract, and the Court had ordered the reinstatement of school employees when procedures were not correctly followed. The opinion stated that R.C. 3319.17 provides a specific process that must be followed when a school board seeks to suspend the contracts of teachers and administrators. However, the Court noted that R.C. 3319.171 offers more discretion to local boards allowing any adopted policy as long as it contains the three specific provisions in the law.

“Plus, R.C. 3319.171 does not require reinstatement as a remedy for administrative personnel whose contracts have been suspended,” the opinion stated.

The opinion stated Policy 1540 had been in effect for nearly a decade before the administrators challenged its validity. While there may be “shortcomings in the wording of Policy 1540,” it did not prevent the board from suspending the contracts, and nothing in the law requires reinstating their administrators to their former positions because of any failures of the policy, the Court concluded.

2024-0697. State ex rel. Ruble v. Switzerland of Ohio Local School Dist. Bd. of Edn., Slip Opinion No. 2025-Ohio-1510.

Please note: Opinion summaries are prepared by the Office of Public Information for the general public and news media. Opinion summaries are not prepared for every opinion, but only for noteworthy cases. Opinion summaries are not to be considered as official headnotes or syllabi of court opinions. The full text of this and other court opinions are available online.