In Grigsby v. King (1927) 202 Cal. 299, the California Supreme Court held that a school district was required by the Teachers' Tenure Act to classify a teacher as a permanent employee because she completed two years of successful work. The court noted that the school board's power to classify a teacher was "modified and limited by the provisions of Political Code section 1609 subdivisions (c), (d), and (e). It is therein provided that the board shall classify as substitutes only 'persons employed for less than a school year to take the places of absent regular teachers'; that the board shall classify as probationary teachers only 'those persons employed for the school year and who have not been classified as permanent.' And subdivision (e), under attack here . . ., compels the board--all boards in all districts--to classify as permanent all successful, two-year teachers, and to make its decision as to whether or not the teacher is a successful one at the end of a two-year period. It limits the power of the board to act otherwise." ( Id. at p. 305.) The teaching of Grigsby is clear--school boards lacked the power in 1927 to classify teachers outside of the strict classification boundaries dictated by the Political Code.