California Teachers Assn. v. State of California

In California Teachers Assn. v. State of California (1999) 20 Cal.4th 327, an adjudicator at an administrative hearing upheld a public school district's decision to dismiss a teacher for misconduct. (California Teachers, supra, 20 Cal.4th at pp. 331-332.) State law provided the teacher could be charged half the cost of the hearing, including the cost of the officer. (Id. at p. 341.) The teacher did not pay the bill, and was then notified his state income tax refunds would be offset against the debt. (Id. at p. 332.) The teacher petitioned for a writ of mandate to compel the State Controller not to offset the refund against the debt. (Ibid.) On appeal, our Supreme Court held the cost-shifting statute was unconstitutional because, "The legislative purpose of imposing the cost of the adjudicator upon teachers to deter them from requesting administrative hearings on nonfrivolous grounds is not a legitimate one." (California Teachers, at p. 346.) The court also found a due process violation under Mathews v. Eldridge (1976) 424 U.S. 319, because the state's interest in "conserving resources or discouraging hearings that happen to result in an administrative or judicial decision against a teacher does not outweigh the teacher's strong interest in presenting his or her side of the case and in invoking the discretion of the adjudicator or the public's interest in preventing erroneous or arbitrary dismissals or suspensions of teachers in our public schools." (California Teachers, at p. 357.)