American Federation of Teachers v. Board of Education

In American Federation of Teachers v. Board of Education, 166 Cal.Rptr. 89, 107 Cal. App. 3d 829 (Ct. App. 1980), the court first noted that "as a general rule, powers conferred upon public agencies and officers which involve the exercise of judgment or discretion are in the nature of public trusts and cannot be surrendered or delegated to subordinates in the absence of statutory authorization." Am. Fed. at 92, 107 Cal. App. 3d at 834. However, the court also expressed that "public agencies may delegate the performance of ministerial tasks, . . . ." Id. The court went on to hold that acceptance of a resignation was a ministerial act and could therefore be delegated. Id. at 94-95, 107 Cal. App. 3d at 838-39. The appellate court held that the acceptance of a letter of resignation of a certificated employee was effective on the day it was accepted by the superintendent of a school district in spite of the fact that the teacher attempted to withdraw the resignation between the time of acceptance by the superintendent and the ratification of that acceptance by the governing board.