Martin v. Randolph County Board of Education
In Martin v. Randolph County Board of Education, 195 W. Va. 297, 465 S.E.2d 399 (1995), the Court analyzed West Virginia's school personnel classification scheme.
It noted the creation of the two classifications discussed previously, and analyzed the situation of the individual whose position was in issue. The Court concluded that the two classes of personnel were distinct, and stated: "Under our statutory scheme, [a school employee] . . . must be either one or the other."
In Martin v. Randolph County Board of Education, the Court indicated that at the heart of the classification process was the character of work to be performed in a job.
The clear implication of the Court's decisions is that the Legislature contemplated that school jobs be either of a professional or of a service type character, and that they cannot be both.
The logical extension of this is that the melding of professional and service duties into one job, regardless of whether it is formally designated "professional" or "service," is counter to the legislative design of the classification system.
The Court elucidated the extent of the Court's scope of review, explaining as follows:
"In reviewing an ALJ's decision that was affirmed by the circuit court, this Court accords deference to the findings of fact made below. This Court reviews decisions of the circuit under the same standard as that by which the circuit reviews the decision of the ALJ. We must uphold any of the ALJ's factual findings that are supported by substantial evidence, and we owe substantial deference to inferences drawn from these facts. . . . We review de novo the conclusions of law and application of law to the facts." (195 W. Va. at 304, 465 S.E.2d at 406.)
The Court has invariably explained that as a reviewing tribunal, we "must determine whether the ALJ's findings were reasoned, i.e., whether he or she considered the relevant factors and explained the facts and policy concerns on which he or she relied, and whether those facts have some basis in the record." (Id., 465 S.E.2d at 406.)
The Court commented upon the narrow review which is appropriate in these matters, explaining that "the scope of review under the arbitrary and capricious standard is narrow, and a court is not to substitute its judgment for that of the hearing examiner." 195 W.Va. at 304, 465 S.E.2d at 406.
Furthermore, upon review of an administrative law judge's decision which was affirmed by a lower court, "we must uphold any of the ALJ's factual findings that are supported by substantial evidence, and we owe substantial deference to inferences drawn from these facts." Id.
"Conclusions of law and application of law to the facts" are reviewed de novo. Id.