Brewster v. Board of Education of the Lynwood Unified School District

We must decide whether school officials who downgraded and ultimately dismissed a teacher may be held personally liable for allegedly violating First and Fourteenth Amendment rights.

I

Arthur Brewster applied for an elementary school teaching position with the Lyn-wood, California, Unified School District (“the District”) in July 1994. In September, the District hired Brewster as a first-year probationary teacher at the Will Rogers Elementary School (“the school”). Less than four months later, however, Brewster received formal notice that his contract with the school would not be renewed. Brewster’s § 1983 claims arise out of two separate and unrelated series of events. The first culminated in the reduction of his salary, and the second resulted in the District’s decision not to renew his contract following his first year.

A

On his employment application, Brewster listed his prior experience as follows: nine years as a superintendent, one year as a principal, one year as an associate professor at the graduate school level, and six years as a teacher-principal. California law provides that public school teachers “shall be classified on the salary schedule on the basis of…