Valot v Southeast Local School District Board of Education
Digest no. 19.07
Cite as: Valot v Southeast Local School Dist Board of Ed, 107 F3d 1220 (6th Cir 1997).
Appeal pending: No
Claimant: Sally Ann Valot
Employer: Southeast Local School District (Ohio) Board of Education
Docket no.: N/A
Date of decision: March 6, 1997
UNITED STATES COURT OF APPEALS, SIXTH CIRCUIT HOLDING: School board did not violate drivers’ substantive due process or equal protection rights by refusing to rehire them.
FACTS: Plaintiffs were substitute bus drivers with nine month contracts with a school district in Ohio. They applied for and were paid unemployment compensation. As the employer did not have a practice of providing “reasonable assurance” to such employees, they were not ineligible for benefits by means of the Ohio school denial period provision. In the fall, the employer refused to rehire drivers who had collected benefits. Plaintiff drivers argued their constitutional rights were violated in that seeking and obtaining unemployment benefits is protected by the constitutional right of access and the right to petition for redress of a grievance.
DECISION: Affirmed dismissal of all federal claims.
RATIONALE: Employer’s interest in promoting efficiency of public service and protecting public funds is legitimate and outweighs claimants’ interest in seeking unemployment compensation. Employer’s action was related to legitimate state interest. No substantive due process rights violated. Nor was there a violation of equal protection. Employer’s decision not to rehire claimants was rationally related to a legitimate state interest.
Digest Author: Board of Review (original digest here)
Digest Updated: 7/99