Caffas v. Board of School Directors

In Caffas v. Board of School Directors, 23 Pa. Commw. 578, 353 A.2d 898 (Pa. Cmwlth. 1976), a teacher appealed an order from the Pennsylvania Secretary of Education, sustaining a school board's decision to terminate a teacher's contract due to, inter alia, "cruelty." At that time, there was no regulation defining "cruelty." The Court, thus, resorted to a dictionary definition of the term, part of which included the following: "'the intentional and malicious infliction of physical suffering upon living creatures, particularly human beings.'" Caffas, 353 A.2d at 900 (quoting Black's Law Dictionary 541 (rev. 4th ed. 1968)). The current definition in the Commission's regulations is similar, except that it includes the additional modifier of "unnecessary infliction" and refers to "physical or psychological pain" instead of "physical suffering." This Court concluded that the evidence of cruelty in Caffas was overwhelming. There was substantial evidence in the record to support the finding that the teacher subjected the children under his charge to physical and verbal abuse--"striking them on the head, wrestling them to the ground, propelling them into the walls and against furniture, shaking them and subjecting them to a humiliating form of horseplay referred to locally as 'red belly'," etc. Id. Apparently, however, the Secretary of Education struggled with the teacher's defense that he never actually intended to inflict suffering on the students. Faced with this concern, the Court opined: The Secretary, apparently troubled by the defense in . . . this case, that the teacher did not intend to inflict suffering on his students, provides his own rather awkward, but not plainly erroneous, definition of cruelty. We suggest to the Secretary that a fully adequate definition is that of Black's Law Dictionary 541 (rev. 4th ed. 1968) . . . . We point out that intent is not irrelevant, but that it may be inferred from the facts and that denials of intent to inflict injury may be rejected, if belied by the actor's demonstrated conduct. Id.