Unreported / Non-Citable
Background
Todd McDaniel had a long career with the Hazlehurst City School District in Mississippi, serving in various roles including head football coach, principal, and ultimately Director of Operations and Discipline at Hazlehurst High School. Beginning in 2017, conflict arose between McDaniel and the district superintendent over discipline policies, staff assignments, and budget priorities, leading the district to narrow his role. The district’s attempt to reassign McDaniel to an assistant principal position was blocked when he successfully invoked his state-law right to a hearing.
For the 2017–18 school year, the district gave McDaniel a contract titled “Contract of Employment with Mississippi Public School Districts for Assistant Superintendent, Principal, and Licensed Employee” — the same form used for positions requiring state licensure — and paid him on the administrator salary scale. When a new superintendent sought to reorganize staff for 2018–19, the district eliminated the Director of Operations position and offered McDaniel an at-will, hourly-wage position instead. A non-renewal notice was delivered days before the statutory deadline. McDaniel requested a hearing as permitted under Mississippi Code § 37-9-109; the district refused.
McDaniel filed suit in the Southern District of Mississippi in April 2019, alleging under 42 U.S.C. § 1983 that the district violated his procedural due process rights by denying him the required notice and hearing before non-renewal. After a seven-day bench trial, the district court found that McDaniel had a constitutionally cognizable property interest in continued employment and that the district violated his state statutory rights. The court awarded lost wages, back pay, emotional distress damages, and attorneys’ fees. The school district appealed.
The Court’s Holding
The Fifth Circuit affirmed. The central question was whether McDaniel’s Director of Operations position required a state-issued license as a “prerequisite of employment” under Mississippi Code § 37-9-103(1), which would trigger the notice and hearing protections of §§ 37-9-105 and 109. The court found no ambiguity in the written contract: the district itself used the standard state-prescribed form for licensed employees, and McDaniel was compensated on the administrator salary scale. Under Mississippi’s parol evidence rule, an unambiguous contract is construed solely from its text, making the contract’s own terms dispositive of the statutory question. The district court did not clearly err in finding that the position required a license.
The school district also argued that McDaniel’s 2017–18 contract was invalid because it had never been “spread across the minutes” of a school board meeting — a prerequisite under Mississippi law for public contracts. The Fifth Circuit rejected this argument as well. The board’s July 10, 2017 meeting minutes recorded McDaniel’s job title and salary basis, and an organizational chart adopted by the board reflected his position. Under Mississippi precedent, the entire contract need not appear in the minutes; it is sufficient that enough terms are recorded to determine the parties’ liabilities and obligations without resort to extrinsic evidence. The court found the minutes met that standard.
Because McDaniel held a valid contract for a licensed position and was entitled to state-law procedural protections, the district’s refusal to provide a hearing upon non-renewal violated his property interest in continued employment. The court affirmed the damages award and attorneys’ fees, noting the district had forfeited any challenge to the damages calculation by failing to raise it in its opening brief.
Key Takeaways
- Under Mississippi law, a school employee whose position requires a state-issued license as a “prerequisite of employment” has a constitutionally protected property interest in continued employment, entitling them to written notice and a hearing before non-renewal.
- When a school district uses the state-prescribed licensed-employee contract form and pays an employee on the administrator salary scale, the unambiguous terms of that contract are themselves sufficient to establish the licensure requirement — extrinsic evidence is unnecessary.
- A public board contract in Mississippi need not be reproduced in full in the meeting minutes; recording the employee’s title and salary basis, combined with an adopted organizational chart, can satisfy the “spread across the minutes” requirement.
- A school district that fails to challenge a damages award in its opening appellate brief forfeits that argument on appeal.
Why It Matters
This decision reinforces that Mississippi school districts cannot sidestep statutory non-renewal protections simply by relabeling a position or downgrading a contract. When a district’s own paperwork — the form contract it selects and the pay scale it applies — reflects that a position requires licensure, the district is bound by those procedural obligations regardless of what the job title says. School administrators and their counsel should scrutinize not just the position description but the contract form and compensation structure when assessing whether due-process protections attach.
The ruling also provides practical guidance on Mississippi’s meeting-minutes rule for public contracts. Courts will not demand exhaustive contractual detail in board minutes; a title, salary basis, and organizational chart may be enough to validate a contract and support a later renewal. For districts seeking to avoid these protections, the lesson is clear: using licensed-employee forms and salary scales while simultaneously claiming a position is unprotected is a position courts are unlikely to accept.