California Teachers Assn. v. Governing Bd. of Rialto Unified School Dist

In California Teachers Assn. v. Governing Bd. of Rialto Unified School Dist. (1997) 14 Cal.4th 627, a tenured, credentialed teacher employed by a school district unsuccessfully applied for two assistant coach positions within the district. (Rialto, supra, 14 Cal.4th at p. 631.) One of these positions was filled by a noncredentialed district employee who had worked only as a security guard for the district, and the other was filled by a person without a teaching credential. (Ibid.) The teacher, joined by two nonprofit employee associations, sought mandamus, contending that the school district had violated section 44919(b) in filling the positions. (Rialto, at p. 631.) Before the Supreme Court, the district contended that section 44919(b) required only that it advertise openings for coaching positions to teachers currently employed by the district, and allow them to apply for these positions. (Rialto, supra, 14 Cal.4th at p. 632.) By contrast, the teacher contended that as the sole applicant for the coaching positions who was then a credentialed teacher employed by the district, he was entitled to a position upon demand. (Id. at pp. 635-636.) The court in Rialto rejected both interpretations of section 44919(b). (Rialto, supra, 14 Cal.4th at pp. 632-636.) It held that the Legislature, in enacting this provision, intended to accord an advantage in the hiring process to credentialed teachers currently employed by a school district over "walk-ons," or candidates not so employed, "provided such teachers apply for the position and are otherwise qualified under applicable criteria promulgated by the school district." (Id. at pp. 630, 632.) To clarify the "advantage in the hiring process" at issue, the Rialto court engaged in a lengthy examination of the language and legislative history of section 44919(b), as well as related statutes and regulations. (Rialto, supra, 14 Cal.4th at pp. 636-652.) It determined that the pertinent statutory and regulatory scheme delegates school districts two forms of discretion over the hiring of athletic coaches. First, districts may set qualifications for coaches "as high as necessary to coincide with local preferences," subject to regulatory minima, when applicable. (Id. at pp. 639-640.) Second, once these qualifications had been set, a district "retains much leeway in determining whether an applicant for a coaching position has met these criteria." (Id. at p. 640.) The court in Rialto thus concluded that "section 44919(b) gives credentialed teachers currently employed in the district an employment preference, not a guarantee of the position they seek." (Rialto, supra, 14 Cal.4th at p. 644.) It stated: "Only to the extent a teacher-applicant currently employed in the school district . . . satisfies the qualifications promulgated by the district, does section 44919(b) prohibit the district from hiring a walk-on in preference to the teacher." (Rialto, at p. 644.) Applying these conclusions to the case before it, the court in Rialto determined that the record did not indicate whether the teacher in question met the pertinent qualifications, and it thus remanded the matter for further proceedings. (Id. at p. 653.) Although the Rialto court did not squarely address the issue before us, its discussion indicates that districts may properly attach teaching requirements to the qualifications for coaches. The court in Rialto explained that "each district may decide how to allocate scarce educational resources to athletics, which sports deserve funding, and how much," and it emphasized that districts could tailor athletic programs to meet goals regarding graduation rates and academic studies. (Rialto, supra, 14 Cal.4th at p. 640, ) Furthermore, in discussing the public policies served by section 44919(b), it stated: "The 'best coach' in a public school setting may be one who serves goals beyond merely producing a winning team. For example, the Legislature may have believed teachers already employed in the district would not place undue emphasis on a student's athletic achievements to the detriment of the student's academic studies." (Rialto, at p. 651.)