Frances v. Angstadt, Plaintiff-Below v. Red Clay Consolidated School District, Defendant-Below

Summary

The Supreme Court of Delaware held that four written correspondences could not be relied upon in deciding not to renew Dr. Angstadt’s teaching contract because they were never properly placed in her personnel file before notice of nonrenewal. It further held that an unfavorable Lesson Plan Analysis properly placed in the file constituted other documented material that could be considered without an individualized improvement plan. Although the District’s procedures were flawed, they substantially complied with the governing statute, so the judgment granting summary judgment was affirmed.