Vanelli v. Reynolds School Dist. No. 7

In Vanelli v. Reynolds School Dist. No. 7 (9th Cir. 1982) 667 F.2d 773, a high school teacher was dismissed midway through a one-year contract. He was dismissed without a pre-termination hearing, but did receive a full evidentiary hearing a month later. Vanelli brought a section 1983 action against the school district and board members for violation of his liberty and property interests. The Ninth Circuit found the dismissal before expiration of the contract, based on charges of offensive conduct with students, violated both Vanelli's property and liberty interests and that he should have been given a pre-termination hearing. (Vanelli v. Reynolds School Dist. No. 7, supra, 667 F.2d 773, 777-779.) It found the post-termination hearing met the standards of fairness required by the due process clause. (Id. at p. 780.) The court remanded the case for determination of compensable damages for mental and emotional distress caused by denial of the procedural due process. (Id. at p. 781.)