What is the test for determining whether a school board's decision to terminate all of its services is reasonable?

California, United States of America


The following excerpt is from Campbell Elementary Teachers Assn., Inc. v. Abbott, 143 Cal.Rptr. 281, 76 Cal.App.3d 796 (Cal. App. 1978):

"In determining whether the decision of a school board is reasonable as distinguished from fraudulent, arbitrary, or capricious, its action is measured by the standard set by reason and reasonable people, bearing in mind that such a standard may permit a difference of opinion on the same subject." (Arthur v. Oceanside-Carlsbad Junior College Dist. (1963) 216 Cal.App.2d 656, 663, 31 Cal.Rptr. 177, 182.) The record reveals that the board resolution of March 13, 1975, was not an arbitrary decision arrived at through the exercise of mere caprice, but rather was a decision supported by a fair and substantial reason. It is true that the governing board hoped that when its final budget was adopted it would not be necessary to terminate all of the enumerated services. Although the governing board wanted to keep as many certificated employees as possible, the school district was facing many financial uncertainties, and the board acted in an attempt to allow the district maximum flexibility in determining staffing for the ensuing school year in light of both available resources and needs. After the unsuccessful tax revenue election on March 4 and before the meeting of March 13 at which the second resolution was adopted, the governing board met and consulted with the business manager of the district regarding the district's financial position. The deputy superintendent reported to the board concerning "the consequences that would come to pass in terms of the District's educational

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