Reported / Citable
Background
Melissa Washington taught for Alta Loma School District for three consecutive years while the district classified her as temporary. The district said she was filling the portion of a position left open by two permanent teachers who voluntarily reduced their workloads through a job-sharing arrangement.
After the district summarily declined to reelect her, Washington sought a writ requiring reinstatement and back pay. The trial court accepted the district’s position that the reduced schedules counted as leave under Education Code section 44920.
The Court’s Holding
The Court of Appeal reversed. It held that “leave” in section 44920 means a leave of absence, not part-time work under a voluntary job-sharing arrangement. The position Washington occupied therefore was not one the law defined as temporary.
Washington acquired permanent status and could not be dismissed using the abbreviated process for temporary teachers. The court ordered reinstatement with an August 2, 2019 seniority date and further proceedings on lost compensation. Laches did not bar relief because the district’s repeated assurances that it would later change her status helped cause the delay.
Key Takeaways
- A district may label a teacher temporary only when the underlying position fits a statutory temporary category.
- A permanent teacher’s reduced workload under job sharing is not a leave of absence under section 44920.
- Misclassified teachers may obtain reinstatement, corrected seniority, and lost compensation.
- Employer assurances can defeat a laches defense when they induced delay.
Why It Matters
The published ruling limits a staffing practice that could otherwise allow public school districts to avoid probationary and permanent-status protections. Districts and educators should examine the legal basis for each temporary designation at hiring and renewal, not assume that a contract label controls.