HORTONVILLE DIST. v. HORTONVILLE ED. ASSN.

426 U.S. 482 (1976)

by

Heather Wilson

Facts of the Case:

The teachers at Wisconsin public school were in the process of negotiating and bargaining their contract with the school board. When this negotiation failed the teachers went on strike. Wisconsin had a law which prohibited teachers to strike. During the strike the superintendent sent out letters on two separate occasions informing the teachers that they were in violation of the law and requesting that they go back to work. Some but not all teachers returned to their job after these letters were sent. The remaining teachers were sent another letter with a date for a hearing scheduled for the beginning of April. The teachers did not want to be heard individually but rather wanted to be heard as a group. The school board fired all the teachers who remained on strike after the hearing. The letter that was sent out firing them also invited them to return back to work. The teachers claimed that this was in violation of the Fourteenth Amendment due process clause and that during the negotiations for changes to the contracts the school board “used coercive and illegal bargaining tactics.” The trial court said that the strike was in violation if the state law and rejected the teachers’ claim that they were denied due process. The courts ruled in favor of the board because the school board sent out a letter warning the teachers that they were in violation of the law. On appeal, the Wisconsin Supreme Court reversed the decision of the trial court. The decision was made based on the fact that when the decision to fire the teachers was made it was not made by an impartial decision maker. The school board appealed to the Supreme Court of the United States.

Decision of the Court:

The Supreme Court of the United States reversed the decision of the Wisconsin Supreme Court and remanded the case back to the Wisconsin Supreme Court.

Basis of Decision:

The Supreme Court ruled that the due process clause of the Fourteenth Amendment did not guarantee teachers who were on the strike that the decision to fire them would be made by any other than the school board and the Supreme Court ruled that the school board was an impartial decision maker. The Supreme Court referred to the case of Withrow v. Larkin which held that even if it was shown that the board participated in the negotiating of the contracts it was not enough to take away the powers that it was given by the state legislatures.