Vasquez

The Happy Valley Union School District (District) terminated plaintiff’s employment as a substitute teacher in the 2005-2006 school year when she refused to accept being reclassified as a temporary teacher. She had taught for the District the previous two years as a substitute and temporary teacher, and she wanted a more permanent classification. She petitioned for a writ of mandate compelling the District to reinstate her and provide due process, claiming she was entitled to permanent employment based on statutory grounds. The trial court denied the petition. We affirm the trial court’s judgment, but we do so on a different basis.

STATUTORY BACKGROUND

Before reciting the facts, we review California’s civil service system for public school teachers with particular attention to its classifications for teachers and the school districts’ authority to dismiss them.

The Education Code classifies California teachers into four different categories: permanent (tenured), probationary, substitute, and temporary. “In the case of permanent and probationary employees, the employer’s power to terminate employment is restricted by statute. Substitute and temporary employees, on the…