Mary C. Donaldson, Plaintiff-Appellant v. Board of Education of the City of North Wildwood, Cape May County…

Summary

The Supreme Court of New Jersey reversed the dismissal of the plaintiff’s petition and held that a board of education must provide a non‑tenured teacher with a statement of reasons for non‑renewal of his contract. The Court based its decision on principles of fairness and administrative law, rejecting the Commissioner’s reliance on an outdated Illinois case and noting that the legislature had not then enacted a contrary statute. A dissent argued that the later statutory scheme precludes any judicial requirement of reasons.