Bliss O. Bignall, Jr., Et Ux. v. North Idaho College

Bliss 0. Bignall and Annette R. Bignall (“Bignalls”) brought an action under 42 U.S.C. § 1983 claiming that North Idaho College (“College”) had denied Mrs. Bignall procedural and substantive due process when it declined to renew Mrs. Bignall’s teaching contract for the 1973-74 academic year. The district court granted judgment for the defendants and the Bignalls appeal.

Mrs. Bignall taught at the College from 1961 to 1973, as a part-time instructor until 1969, and as a full-time instructor thereafter. In November 1972, allegedly responding to a decline in student enrollment, the Board of Trustees (“Board”) of the College ordered the College’s President, Barry G. Schuler (“Schuler”) to cut the faculty by two full-time teaching positions. Mrs. Bignall was one of the two selected for non-renewal, and Schuler notified her by letter on January 10, 1973, that the College would not rehire her for the coming year. The letter stated no reasons for her termination. The Bignalls subsequently wrote to Schuler requesting an explanation and were informed that the Board had mandated that two full-time faculty be cut. When they asked for a hearing before the Board, the Board’s attorney…