What is the probationary period for a substitute teacher?

"New York", United States of America

The following excerpt is from Carpenter v. Board of Educ. of Locust Valley Cent. School Dist., 522 N.E.2d 1030, 527 N.Y.S.2d 733, 71 N.Y.2d 832 (N.Y. 1988):

Education Law 2509(1)(a) provides that a teacher shall be appointed for a probationary period of three years, after which the teacher may be recommended for tenure. However, for a teacher who has rendered two years of satisfactory service as a regular substitute, the probationary period is limited to one year (Education Law 2509[1][a] ). Moreover, a period of service as a regular substitute teacher of less than two years may be applied to reduce the three-year probationary period proportionately ( Matter of Robins v. Blaney, 59 N.Y.2d 393, 398, 465 N.Y.S.2d 868, 452 N.E.2d 1196). A separate section of the Education Law also applicable here--section 3012(1)(a)--repeats the provision for a

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