A Michigan state appeals court has affirmed the ruling of a trial court, finding that a district’s decision not to renew the coaching contracts of a district employee did not violate the collective bargaining agreement the district has with its employees.
Specifically, the court wrote that “nothing in the CBA overcomes the clear and unambiguous language of the extra-duty (coaching) contracts that the latter were for a definite term and contained no rights of renewal.”
The appeals court offered the following background that led to the litigation. Douglas Mullen, the plaintiff, was a tenured elementary teacher that the Parchment School District employed for several years on a year-to-year basis under separate extra-duty agreements as the district’s head cross country coach and head women’s track coach. On May 18, 2005, the district’s athletic director notified plaintiff by letter dated May 18, 2005, that his coaching contracts would not be renewed and that the district “will be posting the positions for 2005-06.”
The plaintiff sued the district, contending that by not offering him the coaching positions he had held in prior years, the district “dismissed” him from those positions without just cause in violation of the CBA. The defendants countered that the “just cause” requirement applies only to the termination or transfer of a coach during an athletic season.
The defendant successfully moved for summary disposition, spawning the appeal.
In its analysis, the appeals court wrote that “the parties entered into two coaching contracts for a definite term covering the sports season of a particular school year, and a collective bargaining agreement providing just cause protection to teachers who were also hired for ‘extra-pay’ positions, such as the coaching positions at issue. As our Supreme Court has noted, ‘[w]here the employment is for a definite term–a year, five years, ten years–it is implied, if not expressed, that the employee can be discharged only for good cause and collective bargaining agreements often provide that discharge shall only be for good or just cause.’ Toussaint, supra at 611 (citation omitted). Plaintiffs’ effort to focus on the ‘just cause’ provision in the CBA to the exclusion of the definite term provided for in the coaching contracts is unavailing.
“In sum, the undisputed facts of this case disclose that plaintiff completed and was fully compensated for the two extra-duty contracts he had with defendants during the 2004-2005 school year. There is no specific provision in the CBA that creates a lifetime right to employment in an extra-duty position. Rather, to the contrary, the extra-duty contracts specifically provide that the extra-duty positions are for a specified period of time without rights to renewal. This is consistent with state law. MCL 38.91(8). Thus, plaintiff possessed no contract right to the renewal of his coaching contracts. Consequently, after the coaching contracts expired by their own terms, defendants cannot be in breach of contract by failing to rehire plaintiff as a coach. See Reisman v Regents of Wayne State Univ, 188 Mich App 526, 531; 470 NW2d 678 (1991) (holding the non-renewal of a contract of employment for a definite term is not a breach of contract). Because the trial court reached the correct result albeit for the wrong reason, this Court will affirm the trial court’s order granting summary disposition to defendants. See Ellsworth v Hotel Corp, 236 Mich App 185, 190; 600 NW2d 129 (1999).”
Douglas Mullen et al. v Parchment School District Board Of Education et al.; Ct. App. Mich.; No. 275116; 2007 Mich. App. LEXIS 1704; 7/3/07
