Martin v. Dayton School Dist
In Martin v. Dayton School Dist., 85 Wn. 2d 411, 536 P.2d 169 (1975), a school district had issued a teacher a notice of discharge which was legally defective. On the same day that the plaintiff appealed the notice of discharge to the superior court, the school district issued a second, legally adequate notice.
The trial court and the Washington Supreme Court upheld the teacher's discharge. In doing so, the latter court said that it recognized the general rule that the jurisdiction of an administrative agency over a particular matter ends when the decision is appealed to the court. Id.
The reason for this rule was that the court's jurisdiction must be complete and not subject to being interfered with or frustrated by concurrent actions by the administrative body.
The Washington Supreme Court affirmed the action of the trial court because when the school district issued the second notice, the appeal from the notice of discharge was limited to the court clerk's act of receiving a notice of appeal. Id. It emphasized that the trial court had taken no action and that the plaintiff was in no way prejudiced. This case represents a close call on an exceptional situation.