Lisa M. Johnson, Plaintiff-Appellant v. School District No. 1 in the County of Denver and State of Colorado And…

Summary

The court held that the statutory mutual-consent and unpaid-leave provisions apply to all displaced nonprobationary teachers, not only teachers displaced for enrollment- or program-based reasons. It also held that a nonprobationary teacher placed on unpaid leave has no vested property interest in salary and benefits because the governing statute eliminated the former tenure, entitlement, and durational protections. Justice Gabriel, joined by Justices Hood and Hart, concurred in the property-interest holding but would have limited displacement under the statute to the enumerated circumstances.