Heinlein v. Anaheim Union H. S. Dist

In Heinlein v. Anaheim Union H. S. Dist. (1950) 96 Cal.App.2d 19, the petitioner was classified by the district as an "unsatisfactory" teacher for a variety of reasons as a result of which she lost her annual increase in salary. She petitioned for a writ of mandate to compel the district to recognize her as a "satisfactory employee," alleging that the rating she had received was discriminatory, arbitrary and unreasonable. ( Id. at p. 20.) In both the trial court and on appeal, the petitioner contended that the district had violated constitutional guarantees against unfair discrimination and had not followed the established principle of uniformity in fixing salaries. This led the court to a reference to section 13802 of the Education Code and cases construing it, including Rible v. Hughes (1944). Heinlein then quotes Rible, "according to these decisions, then, a board of education may exercise its discretion in adopting salary schedules fixing the compensation to be paid to permanent teachers although (1) the schedule must be adopted prior to the beginning of the school year; (2) any allowance based upon years of training and experience must be uniform, and subject to reasonable classification; and (3) the schedule must not be arbitrary, discriminatory or unreasonable." ( Rible v. Hughes, supra, 24 Cal.2d 437, 444.)