Tarquino v. Franklin-McKinley School Dist

In Tarquino v. Franklin-McKinley School Dist. (1979) 88 Cal. App. 3d 832, the court noted that credential qualification was an implied condition of every teaching contract, but held that where a school district had twice obtained an "eminence credential" for a probationary teacher, it could not terminate her employment for not obtaining it herself the third year. The court reasoned that the parties' conduct indicated where they intended the responsibility for obtaining the credential to lie.