Knox v. Board of School Directors of Susquenita School District

In Knox v. Board of School Directors of Susquenita School District, 585 Pa. 171, 888 A.2d 640 (2005), our Supreme Court addressed the applicability of Section 1089(c) to business administrators. Therein, our Supreme Court held as follows: We agree with appellant and amicus that the plain language of the statute encompasses all school business administrators, and not just those subject to written employment agreements. By its terms, subsection (c) neither limits its application to written employment relationships, nor purports to exclude those administrators working without the benefit of a written contract. Additionally, the introductory caveat ("Unless otherwise specified in an employment agreement") itself is not limited to written agreements, nor does that caveat advert to the "written employment agreement" addressed in subsection (b)'s recognition of the authority of the governing board to enter into such written agreements: instead, subsection (c), at least, is open-ended. This construct suggests that the protections offered in the provision were intended to be applicable so long as there is not some other agreement between the parties addressing the subject of the statute. . . . Accordingly, we hold that the protections offered by Section 1089 apply equally to business administrators with or without written employment agreements, . . .Knox, 585 Pa. at 185-86, 888 A.2d at 649.