Wyoming Supreme Court

Board of Trustees, Laramie County School District No. 1, Appellant (respondent Below) v. in the Matter of Sydney…

April 22, 19761976 Wyo. LEXIS 191

Summary

The Wyoming Supreme Court affirmed the District Court's reversal of the Laramie County school board's termination of continuing-contract teacher Sydney Spiegel, holding that the board's refusal to grant his motion for a more definite statement of the vague charges against him and its refusal to extend his preparation time were abuses of discretion amounting to error; that his union-publication criticisms of school administrators were protected by the First Amendment and article 1, section 20 of the Wyoming Constitution, so that nonrenewal based even partially on such protected speech was improper; and that the evidence was insufficient — unsupported by substantial evidence — to establish cause for termination. A footnote expressly states that the opinion's extensive voir dire discussion (permitting bias inquiry of administrative board members and limiting the rule of necessity) represents only Justice Rose and retired Judge Armstrong, not the majority. Guthrie, C.J., joined by Thomas, J., concurred in the result but dissented from the voir dire portion, and McClintock, J., specially concurred on the First Amendment ground alone.