Faculty Rights

Most teachers perform their jobs admirably and never face censure, but cases of teachers charged with incompetence or unethical or illegal behavior surface regularly. Teachers are protected by the constitutional and civil rights guaranteed to all citizens, but because they are entrusted with responsibility of educating impressionable students and serve as role models, they are held to higher standards in the classroom. Teachers need to protect themselves and must ensure the rights of their students, so it is recommended that they be knowledgeable of education law. There are many reasons why a teacher may be dismissed and each state has statutes for granting and withdrawing certification and school boards have established dismissal processes. Probationary teachers are generally not as fully protected as are tenured teachers who are guaranteed of the right to due process should they face charges for dismissal.

Keywords 1st Amendment; 14th Amendment; Certification of Teachers; Civil Rights; Dismissal of Teachers; Due Process; Faculty Rights; Fair Treatment; Just Cause; Teacher Certification; Tenure

Overview

A series of articles prepared by the Associated Press that appeared in newspapers across the nation in the fall of 2007 exposed the pervasiveness of sexual abuse by teachers. The sensational nature of the articles evoked the abuse scandals by priests in the Catholic Church and implied that school administrators are remiss in tracking perpetrators. The AP found that more than 2,500 teachers in the U.S. were punished for sexual misconduct over five years (Garcia, 2007; Irvine, 2007). Considering that there are around three million teachers in the United States, the percentage found guilty of abuse was small, but one would argue that one case is too many for professionals charged with the responsibility of educating and shaping young lives. Suits involving teachers surface regularly in local media around the country and the cases are frequently complicated. Charges involve many other misconduct issues. Likewise, the teacher is not always in the wrong and may be unjustly accused. The majority of teachers go about the business of educating the young and exercising their professional skills and judgments, but at the same time, the wise ones know the laws and are aware of their rights. One of those rights is to a good reputation which is why any teacher facing dismissal also has the right to due process (Jewett, 2007).

Most teacher education programs include some instruction on education law. Extensive research presented in a study by Schimmel and Militello (2007) indicates that many teachers are poorly informed about school law and would change their behavior if they knew more. They believe that teachers frequently violate students' constitutional rights without knowing any better and put themselves at risk. Their article points out that bringing charges against teachers in schools is expensive and litigation involving special education in particular has increased. The study concluded that a majority of teachers in their sample are uninformed or misinformed about a number of important issues concerning student and teacher rights. Ignorance of the law is not an excuse in a court room. Teachers are often not fully aware of rights until they learn about them when they run up against a problem. In today's litigious society, it is increasingly important that teachers raise their level of awareness.

Constitutional Rights

Teachers are assured of the rights basic to all citizens under the Amendments of the U. S. Constitution including the freedoms of speech, religion, and association. Even the constitutional right to bear arms has become an issue for some teachers. A case reported in the national news in October 2007 when a teacher in Oregon who had a restraining order against her ex-husband and filed suit against her school district which refused to allow her to carry a gun to school. At the same time in Michigan, a state representative was introducing legislation to allow teachers with firearm certification to have access to a gun at school (Ash, 2007). Although each case is unique and even unusual, fundamental rights are continually being tested and court decisions help define national norms.

Wohl (2005), offered a primer on the "The Extent and Limitations of Teachers' Rights" by highlighting issues related to the essential freedoms of speech, religion and association. He contends that teachers' rights have become more clearly defined in the last fifty years and "… legal conflicts concerning limits on those rights and freedoms have also increased, adding an entirely new procedural layer to the job" (Wohl, 2005, par. 4).

The most frequently tested of teachers' rights is that of freedom of speech, both in and out of the classroom. The frequently cited case of Pickering v. Board of Education 391 U.S. 563 (1968) set a precedent for modern challenges to teachers' freedom of speech. The case allowed that Pickering, a teacher, had the right to criticize his school board and administrators in a public forum, but subsequent challenges have defined standards that require levels of civility and professionalism by disallowing vituperative remarks or disclosure of confidences (Wohl, 2005).

Issues in the Classroom

Discussion of political issues within a classroom is generally appropriate as long as teachers do not force their personal opinions on students. The most contentious issues related to freedom of speech involve academic freedom. Teachers are bound by assigned texts and the curriculum determined by school districts and the states. Deviations from those are limited, but teachers do retain the right to … "shape their lessons and to evaluate and comment on materials and issues related to their teaching and curriculum" (Wohl, 2005, par. 8). Further, Wohl quotes Justice Thurgood Marshall who said that we must "arrive at a balance between the interests of the teacher, as a citizen, in commenting upon matters of public concern, and the interest of the state, as an employer, in promoting the efficiency of the public services it performs through its employees" (par. 5).

School prayer and the teaching of evolution remain among the most incendiary of issues that test freedom of religion. Teachers are often in the center of the debate as cases arise. One of the most highly publicized cases of recent years occurred in Pennsylvania where parents sued, demanding that students be read a statement critical of evolution and that the concept of intelligent design be presented. The challenge fizzled as a federal judge ruled that intelligent design is a religious viewpoint and that evolution is backed by scientific evidence ("Ruling on intelligent design," 2005).

Teachers may not proselytize or indoctrinate their students. Official prayer is also banned from the classroom, but courts in recent years are less reluctant to restrict private prayer in schools. A former principal, Rooney (2007), offers a philosophical perspective on teaching and managing a school. She says that individuals pray all of the time in public schools as they draw on all strengths at their personal disposal to and expresses that no particular religious system prevails.

The freedom of association is tied closely to the right of teachers to organize in a union. As long as their assembly is disassociated from their professional responsibilities, teachers' rights to organize and assemble is permitted and closely regulated by the states.

Teachers are also covered by the Equal Protection Clause of the Fourteenth Amendment, which protects all citizens from discriminatory practices. It assures that a teacher will not be discriminated against on the basis of race, sex or national origin. Subsequent federal legislation offered further defines protection including the Civil Rights Act of 1964 and its amendment to include educational institutions in 1972; Title IX of the amendment protected discrimination based on sex and Title VII and IX prohibits sexual harassment in the workplace.

Tenured vs. Probationary Teachers & Due Process

When discussing teachers' rights, a distinction must be made between those teachers who are tenured and those who are not. Newly hired teachers who are probationary serve at the pleasure of their school board. Probationary teachers have contracts that must be renewed from year to year and can usually be terminated without due process unless they can prove that that their dismissal "… violated a constitutional or statutory right (e.g., that the non-renewal occurred because of race, religion, age, or other discriminatory reasons)" (Imber, 2004, p. 303).

Teachers are granted tenure after a period of probation which is usually two to five years, depending on the state. All states have tenure statutes that define the process. Tenure is granted automatically in some states, but in others teachers must be appointed by the school board after undergoing evaluation. Teachers who are granted tenure have proven their competence and demonstrate professional responsibility. By definition, tenure confers on teachers the privilege of having their contract renewed automatically from year to year and having the right to due process should they be charged … They cannot be dismissed "for engaging in constitutionally or statutory protected behavior or because the school board believes that a better teacher could be found or even if a better teacher is found" (Imber, 2004, p. 404).

Dismissal procedures are generally well defined and due process guarantees that a tenured teacher be notified of termination, be told what the specific charges are, and have an opportunity for a hearing. The due process right of a tenured teacher facing dismissal requires that a school board must show substantial evidence that it has grounds for the action. Because of the cost of time, money and human resources, dismissals aren't entered into lightly. Grounds for dismissal defined by state statutes may include incompetence, insubordination or neglect of duty, incapacity, or immoral or criminal behavior; although each state and their courts may interpret specific actions differently.

Further Insights

Selected Cases Involving Teachers' Rights

Freedom of Speech

The case of Pickering v. Board of Education (1968) is the most often cited Supreme Court case that set precedent for a teacher's right of expression within school walls. Pickering, a social sciences teacher, had been dismissed by his school board for writing a letter to the editor of the local newspaper criticizing their management of funds. The Supreme Court decided 8-1 that the board had violated the teacher's freedom of speech. Pickering had expressed his view on a matter of public concern but it did not affect his students or cause harm. Justice Marshall wrote that we must "arrive at a balance between the interests of the teacher, as a citizen … and the interest of the state, as an employer, in promoting the efficiency of the public services it performs through its employees" (Wohl, 2005).

Pickering v. Board of Education has guided court decisions over the last forty years as they noted Marshall's limits to criticism, which are "subject to time, place and manner restrictions … [judges examine] the consequences and the context of a teacher's actions or words and factors them into an equation balancing public versus private interests" (Wohl, 2005). Accordingly, in Calef v. Budden, a South Carolina federal court found that a teacher who wore a "War is Not the Answer" button and criticized the war in Iraq decided against the teacher. Her actions were upsetting to many of the students in the school who were children of military parents and the court decided in favor of the state's interest in promoting efficient public services.

Freedom of Religion

Many of the freedom of religion cases that have come before the courts have involved prayer in schools or the issue of evolution, both of which tend to focus on the societal issue and not an individual teacher. However, the courts have repeatedly found that a teacher is free to practice religion as he or she likes as long as she does not introduce her beliefs in the classroom or impose them on her students. The Supreme Court case, Good News Club v. Milford Central School (2001), allowed that Christian groups had the right to use the facility for meetings after hours. This action was upheld by a U.S. Circuit court in Sioux Falls, South Dakota where the school district was found to violate a teacher's right to run a Christian "Good News" club at her elementary school. Administrators had told her she could hold the program at another school, but not her own, to avoid a misperception that the program was sponsored by the school ("Teachers can run," 2004). The court found that she had a right to run the program since it was after school and had nothing to do with her classroom responsibilities.

The courts supported assertion of religious rights once again when an instructional assistant in a rural Pennsylvania school was suspended for wearing a cross on the grounds that it violated the school code. The U.S. District Court of the Western District of Pittsburgh found that the school district had violated the state's own Religious Freedom Protection Act. It found that the cross was not "religious garb" and that the schools policy violated the Free Exercise Clause of the First amendment. The teaching assistant was reinstated (Lee, 2003).

Due Process

Teachers who face charges and the administrators who bring them cannot be too careful about following proscribed procedures of due process. The Supreme Court decision in the case of Cleveland Board of Education v. Loudermill (1985) raised the question of what is due process under the Constitution. The court considered two parallel cases that involved dismissal of staff members and found that the administration had failed to give each fair notice of the charges against them and an opportunity to respond. The decision has been used to confirm the due process requirements that a tenured teacher has to be given oral or written notice of dismissal and charges, an explanation of the evidence obtained by the employer, and the opportunity for a fair and meaningful hearing.

A widely publicized case (Hearn v. Board of Public Education, 191 F. 3d 1329, 11th Circuit (1999) was that of a Savannah, Georgia teacher of social studies with 27 years of experience who had been a "teacher of the year" and was three years from eligibility to retire with full benefits in 1994. During a drug search at the school, a partially burned marijuana cigarette was found in her car. A drug test was negative. After a sequence of missteps by both parties, the teacher was dismissed, but the process raised serious questions about violations of her personal rights and the value of her contract with the school district.

Laws Pertaining to Teachers' Rights

1st Amendment of the U.S. Constitution:

The First Amendment of the U.S. Constitution establishes the basic freedoms for all citizens:

Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise thereof; or abridging the freedom of speech, or of the press, or the right of the people peaceably to assemble, and to petition the Government for a redress of grievances.

14th Amendment/Equal Protection Clause & Due Process:

The Equal Protection clause of the Fourteenth Amendment of the U.S. Constitution is the fundamental law that protects citizens from discrimination on the basis of race, sex, or national origin. It, of course, also contains the due process clause.

Section 1. "… All persons born or naturalized in the United States, and subject to the jurisdiction thereof, are citizens of the United States and of the state wherein they reside. No state shall make or enforce any law which shall abridge the privileges or immunities of citizens of the Unite States; nor shall any state deprive any person of life, liberty, or property, without due process of law; nor deny to any person within its jurisdiction the equal protection of the laws."

The 5th Amendment applies to the laws and actions of the federal government; the 14th to those of the state. Generally, educational policy and procedure is set by each state.

Civil Rights Act of 1964:

The Civil Rights Act of 1964 ensures equal educational opportunity by outlawing desegregation of education. Title VII of the Act "prohibits discrimination by covered employers on the basis of race, color, religion, sex or national origin."

The Act was amended in 1972 to include educational institutions. The Pregnancy Discrimination Act of 1978 was an amendment to Section VII and prohibits discrimination against women who are pregnant or have related conditions.

Age Discrimination in Employment Act of 1967 (ADEA) & Age Discrimination Act of 1975:

The ADEA protects applications and employees who are 40 years old or older from discrimination "on the basis of age in hiring, promotion, discharge, compensation, or terms, conditions or privileges of employment." The Age Discrimination Act of 1974 applies to all ages and pertains to programs and activities receiving federal financial assistance.

Americans with Disabilities Act of 1990 (ADA):

The ADA, or Americans with Disability Act, protects those with permanent or temporary disabilities from discrimination of all types.

Dismissal of Teachers

Dismissing a teacher, particularly an experienced tenured one, can exact moral, financial and emotional costs. No two cases are the same and the situations can be complex. False or unfounded accusations are not uncommon and teachers may be caught unfairly in compromising situations. Jehlen (2003) presented case studies of five teachers who overcame false accusations.

Jehlen (2003) advises teachers to document everything, to not do anything that can be misinterpreted including avoiding touching students, or making any off-the-cuff remarks about students. He also suggests that teachers work to keep lines of communication open with administrators so problems can be addressed as soon as they arise. Those who survived false accusations said that they never lost support of colleagues and family and even from students. Fair treatment requires administrators to report any suspected case of child abuse, so parents are taken very seriously when they bring a complaint. The result may involve suspensions of the teacher without pay until the matter is resolved.

There are two aspects to due process:

• Substantive: Substantive refers "to the reason or cause for the deprivation of the liberty or property right; and

• Procedural. Procedural due process refers to the procedures that must be followed before depriving someone of a liberty or property right. The three major components of procedural due process are notice, hearing, and appeal" (Jewett, 2007, p. 6).

Due process is generally reserved for tenured teachers. For probationary teachers, a school board's authority is generally unrestricted. Tenured teachers cannot be dismissed without just cause, but there is no such requirement for dealing with probationary teachers. School boards that brings charges to dismiss a teacher must prove that the teacher did not meet a standard, but the teacher does not have to prove that she did measure up to it. In the dismissal process of a probationary teacher, the responsibility is reversed. The burden of proof is on the teacher who must show that the board acted either capriciously, did not live up to the contract, or violated the teacher's rights (Jewett, 2007).

Several years ago the National Education Association completed a study on the rights of nontenured teachers. They asked if probationary teachers were entitled to due process in the states. They found that 19 states afforded probationary teachers the right to be told the reasons for nonrenewal; 20 states required teachers to be evaluated and to have a plan of improvement; and in 14, school districts are required to comply with the requirements of the evaluation and improvement plan. In 21 states, collective bargaining representatives have the authority to negotiate "just cause" protections. There is more protection for probationary teachers than is generally thought, but the study also found that three states do not have state tenure laws - Georgia, Mississippi, and Texas - not even for veteran teachers (Simpson, 2001).

Viewpoints

There are those who argue that teachers' rights are under siege and are much diminished with the enactment of the No Child Left Behind Act of 2001 (NCLB) and the new emphasis on standards and testing. Taylor (2002) argues that students have been the beneficiaries of greater freedom as the rights of teachers and administrators have been eroded.

Tenure is a target of those who believe that we have given over too many rights to teachers as well as students. They see many incompetent teachers who are frozen in place and who are impossible to remove from their positions. New standards have resulted in more aggressive processes and lower tolerance for underperforming tenured teachers. One of the most egregious examples of the need to do this was exposed in the New York City school district by the New York Times in 2004 reported on the so called "rubber rooms" where more than 200 teachers spent their days, some at full pay, as they awaited their fate while their lawyers prepared their cases. Proposals were made to reduce the time it took to remove a teacher to six months and speed up the indefinite process that existed then (Herszenhorn, 2004).

In 2006, only four teachers from five large urban school districts had been formally terminated for poor performance - four teachers out of 70,000 ("You're (hardly ever) fired?" 2006). At the same time, Chicago Teachers Union president, Marilyn Stewart (2006), wrote that it is the "union's job to protect due process, not 'bad' teachers." She makes the points that school principals and administrators often fail to adequately document the charges that they bring against a teacher. Interestingly, she also defends the role of the union and if the employer and employee would follow the "law and the contract" "everyone - including the tax-paying public will be properly served" (Stewart, 2006, par. 9).

Terms & Concepts

Certification of teachers: All states have statutes that set requirements for licensing or certifying teachers. Most states require a college degree, specified courses, and practice teaching. Passing standard examinations is now required by a majority of the states and other requirements may include background checks and drug tests. Many states require continuing education in order to retain certification. Certification may be revoked if a teacher's conduct is found to violate state statutes or other laws.

Due Process: Due process guarantees that an employee who faces censure or dismissal hears the charges, has an opportunity to respond to the accusers and is permitted to be represented throughout the process. Within the context of education, it implies that tenured teachers cannot be dismissed without following proscribed procedures for dismissal. The process is backed by legal precedent and more basically, the Fourteenth Amendment of the U.S. Constitution.

Fair Treatment: Fair treatment is the concept that the accused must be treated fairly by those in a position of authority and has a right to due process as well as an opportunity to be heard.

Just Cause: Just cause is defined as a reason that an ordinary person would consider fair and reasonable justification for an act, especially in relation to employment actions. An employer must have "just cause" to dismiss a tenured teacher or deny an employee certain benefits.

Probationary Teachers: A teacher who has two to five years of experience, depending on the state, of continuous service in the same school district is considered probationary. Probationary teachers are evaluated more frequently than tenured or "permanent" teachers and may have to meet additional requirements. Probationary teachers serve at the pleasure of their school boards and may be dismissed or not have their contract renew with little notice.

Tenure: Tenure is the guarantee of due process for a teacher. Teachers earn the right to hold a teaching appointment indefinitely or "permanently" as long as certain conditions are met. In most states, this occurs at the end of their probationary years of teaching, but school districts have some discretion for setting their own procedures for evaluating and deciding upon renewal of contracts and tenure. Processes for dismissing a tenured teacher may be protracted and must provide due process in order not to violate the rights of the teacher.

Bibliography

Ash, K. (2007). Teacher gun rights fire up both sides in Ore., Michigan. Education Week, 27 , 20. Retrieved November 21, 2007, from EBSCO online database, Academic Search Premier. http://search.ebscohost.com/login.aspx?direct=true&db=aph&AN=26989537&site=ehost-live

Coeyman, M. (2000). It's not always easy to say you're fired! Christian Science Monitor, 92 , 13. Retrieved November 22, 2007, from EBSCO online database, Academic Search Premier. http://search.ebscohost.com/login.aspx?direct=true&db=aph&AN=2807867&site=ehost-live

Darden, E. (2007, October). Conduct unbecoming. American School Board Journal, 194 , 42-43. Retrieved November 22, 2007, from EBSCO online database, Academic Search Premier. http://search.ebscohost.com/login.aspx?direct=true&db=aph&AN=26481177&site=ehost-live

Darden, E.C. (2012). Firing a teacher is getting easier. Phi Delta Kappan, 94, 68-69. Retrieved December 15, 2013, from EBSCO Online Database Education Research Complete. http://search.ebscohost.com/login.aspx?direct=true&db=ehh&AN=84304039&site=ehost-live

Essex, N.L. (2000). Fair hiring and firing. American School Board Journal, 187 , 32-34.

Garcia, O. (2007, November 11). Teacher sex abuse cases reveal patterns. The Washington Post [electronic version]. Retrieved November 22, 2007 from website. http://www.washingtonpost.com/wp-dyn/content/article/2007/11/11/AR2007111100184.html

Herszenhorn, D. (2004). Failing teachers face a faster ax. New York Times, 153 (Issue 52729), p. A1 - B4.

Imber, M. (2004). Education law. Mahwah, NJ: Lawrence Erlbaum.

Irvine, M. & Tanner, R. (2007, October 21). Sexual misconduct plagues American schools. (Associated Press). Retrieved November 22, 2007 from CNN website. http://www.cnn.com/2007/US/10/21/teacher.sex.abuse.ap

Jehlen, A. & Milloy, M. (2003). Surviving a low blow. (Cover story). NEA Today, 22 , 24-33. Retrieved November 22, 2007, from EBSCO online database, Academic Search Premier. http://search.ebscohost.com/login.aspx?direct=true&db=aph&AN=11213709&site=ehost-live

Jewett, T. (2007). Due process rights. New Teacher Advocate, 14 :6-7.. Retrieved September 15, 2007, from EBSCO online database, Education Research Complete. http://search.ebscohost.com/login.aspx?direct=true&db=ehh&AN=25269281&site=ehost-live

Lee, R. W. (2003). Defending the cross. The New American, 19 , 34.

Patterson, J. (2000). When you have to fire a teacher. Curriculum Administrator, 36 , 42. Retrieved November 22, 2007, from EBSCO online database, Academic Search Premier. http://search.ebscohost.com/login.aspx?direct=true&db=aph&AN=3806222&site=ehost-live

Rooney, J. (2007). Asking for strength. Educational Leadership, 64 , 82-83. Retrieved November 21, 2007, from EBSCO online database, Academic Search Premier. http://search.ebscohost.com/login.aspx?direct=true&db=aph&AN=23996921&site=ehost-live

Ruling on 'intelligent design' is one for the history books. (2005, December 22). USA Today.

Samuels, C. (2006). Bill would protect searches by teachers. Education Week, 26 , 29-29. Retrieved November 19, 2007, from EBSCO online database, Academic Search Premier. http://search.ebscohost.com/login.aspx?direct=true&db=aph&AN=22531258&site=ehost-live

Schimmel, D., & Militello, M. (2007). Legal literacy for teachers: a neglected responsibility. Harvard Educational Review, 77 , 257-284. Retrieved November 19, 2007, from EBSCO online database, Academic Search Premier. http://search.ebscohost.com/login.aspx?direct=true&db=aph&AN=27078077&site=ehost-live

Simpson, M. (2001). NEA examines the rights of nontenured teachers. NEA Today, 19 , 19. Retrieved November 19, 2007, from EBSCO online database, Academic Search Premier. http://search.ebscohost.com/login.aspx?direct=true&db=aph&AN=4388968&site=ehost-live

Stewart, M. (2006). Union's job is to protect due process, not 'bad' teachers. Crain's Chicago Business, 29, , 14. Retrieved November 23, 2007, from EBSCO online database, Regional Business News. http://search.ebscohost.com/login.aspx?direct=true&db=bwh&AN=23602089&site=ehost-live

Taylor, S. (2002). How more rights have made us less free. National Journal, 34 , 3670.

Teachers can run religious clubs after school, court says. (2004). Church & State, 57 , 22. Retrieved November 19, 2007, from EBSCO online database, Academic Search Premier. http://search.ebscohost.com/login.aspx?direct=true&db=aph&AN=14774715&site=ehost-live

Teacher acts as district's 'voice' in displaying religious materials. (2011). School Law News (LRP Publications), 39, 6-7. Retrieved December 15, 2013, from EBSCO Online Database Education Research Complete. http://search.ebscohost.com/login.aspx?direct=true&db=ehh&AN=70137358&site=ehost-live

U.S. Department of Labor. (n.d.). Equal employment opportunity: Age discrimination. Accessed November 19, 2007 from http://www.dol.gov/dol/topic/discrimination/agedisc.htm

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Wohl, A. (2005). The extent and limitations of teachers' rights. Human Rights: Journal of the Section of Individual Rights & Responsibilities, 32 , 22-24. Retrieved September 15, 2007, from the EBSCO online database, Academic Search Premier. http://search.ebscohost.com/login.aspx?direct=true&db=aph&AN=19875578&site=ehost-live

Suggested Reading

Coleman, J., Schroth, S., Molinaro, L., & Green, M. (2005). Tenure: an important due process right or a hindrance to change in the schools? Journal of Personnel Evaluation in Education, 18 , 219-231.

Fort Hays State University, Kansas. Due process for teachers: what are the rights under due process for teachers? Retrieved September 15, 2007 from website. http://www.fhsu.edu/te/law/due.html

Garner, D. R. M. (2002). The knowledge of legal issues needed by teachers and student teachers. Paper presented at the Annual Meeting of the Mid-South Educational Research Association (Bowling Green, KY, November 15-17, 2000). (ERIC ED 451 139). Retrieved from website November 22, 2007. http://www.eric.ed.gov/ERICDocs/data/ericdocs2sql/content_storage_01/0000019b/80/16/e5/9d.pdf

Gerstein, R. M. & Gerstein, L. (2007). Education law; an essential guide for attorneys, teachers, administrators, parents, and students. 2nd ed. Tucson, Arizona: Lawyer and judges Publishing Co. Inc.

Schimmel, D., Fischer, L. & Stellman, L. (2008). School law: what every educator should know: a user-friendly guide. Boston: Allyn and Bacon.

Teachers Evaluating Teachers: Peer Review & the New Unionism - Studies in Social Philosophy & Policy. (1998). 5. Due process and duty of fair representation under peer pressure, p. 47-53. Retrieved November 19, 2007, from EBSCO online database, Education Research Complete database. http://search.ebscohost.com/login.aspx?direct=true&db=ehh&AN=11347786&site=ehost-live