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Courts Give Deference to Ohio Department of Education Teacher Misconduct Rulings

In the case of Langdon v. Ohio Dept. of Edn., 2017-Ohio-8356, an Ohio appellate court reversed a lower court’s ruling because the lower court did not “give due deference” to a decision by the Ohio Department of Education (“ODE”) to deny a teacher’s license renewal application.

The case involved a teacher who allegedly engaged in eight instances of conduct unbecoming a teacher – including using marijuana, revealing details about a student’s individualized education program, and referring to a nurse as a “big, gross, disgusting wildebeest.” Langdon at ¶ 3.  Following a hearing on the matter, ODE denied the teacher’s application for a license renewal and prohibited her from reapplying for several years.

The teacher appealed ODE’s decision to a common pleas court, which reversed ODE’s decision.

ODE then appealed the common pleas court’s decision to the appellate court.

The appellate court agreed with ODE so the appellate court both reversed the common pleas court’s decision and affirmed ODE’s decision. In doing so, the appellate court concluded that the common pleas court improperly “substituted its judgment for that of [ODE], which it was not permitted to do, and failed to give due deference to [ODE’s] resolution of the factual conflicts and credibility issues. “ Langdon at ¶ 96.

The case emphasizes a point made in a prior blog, which can be accessed by clicking here, regarding the deference that courts give to ODE rulings in teacher misconduct proceedings.

To read this case, please click here.

Authors: Matthew John Markling and Patrick Vrobel

Note: This blog entry does not constitute – nor does it contain – legal advice. Legal jurisprudence is like the always changing Midwestern weather. As a result, this single blog entry cannot substitute for consultation with a McGown & Markling attorney. If legal advice is needed with respect to a specific factual situation, please feel free to contact a McGown & Markling attorney.

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