Kim Cook v. Gary Chartrand

Rule of Law:

State laws and policies that infringe upon non-fundamental rights or create classifications not based on a protected class are constitutional under the Fourteenth Amendment's Due Process and Equal Protection Clauses if they are rationally related to a legitimate governmental purpose.

Facts:

• In 2011, the Florida legislature enacted the Student Success Act, establishing new requirements that at least 50 percent of a public school teacher's performance evaluation must be based on student learning growth data from statewide assessments.
• The Act tasked the Florida Commissioner of Education with approving a formula (known as the FCAT value-added model or 'FCAT VAM') to measure individual student learning growth on the Florida Comprehensive Assessment Test (FCAT).
• The FCAT VAM was designed to provide evaluation scores for 'Type A' teachers (English grades 4-10, Math grades 4-8) whose students had FCAT scores from at least two years.
• For 'Type B' teachers (grades 4-10, non-FCAT subjects) and 'Type C' teachers (grades below 4 or above 10, or non-testing students), the Act instructed school districts to select an 'equally appropriate formula' for measuring student learning growth.
• Most school districts, including the three defendant school districts (Alachua, Escambia, and Hernando Counties), lacked the resources to develop alternative assessments or statistical models for Type B and C teachers.
• In the absence of an alternative formula, Type B teachers' evaluations were based on FCAT VAM scores derived from their students' FCAT scores in English and Math, even though these teachers did not teach those subjects.
• In the absence of an alternative formula, Type C teachers' evaluations were based on school-wide FCAT VAM scores derived from the FCAT scores of students whom the Type C teachers did not teach.
• Kim Cook, Bethann Brooks, Emily Jefferis, Cathy McConnell, Shauna Paedae, Janine Plavac, Catherine Boehme, and three teacher associations (Alachua County Education Association, Hernando Classroom Teachers Association, Escambia Education Association) are teachers and associations representing teachers in Florida public schools.

Procedural Posture:

• Plaintiffs (seven Florida public school teachers and three local teacher associations) filed a lawsuit against the school districts of Alachua, Escambia, and Hernando Counties, and officials from the Florida Commissioner of Education and State Board of Education, challenging the Student Success Act and its implementation under the Due Process and Equal Protection Clauses of the Fourteenth Amendment in the United States District Court for the Northern District of Florida.
• The district court determined that the plaintiffs had standing because they alleged a concrete risk of reduced future income.
• The district court granted the defendants' motion to dismiss the complaint's facial challenge to the Student Success Act, finding that the Florida legislature had a rational basis for enacting the evaluation scheme.
• The district court allowed the plaintiffs' as-applied claims to proceed.
• The district court later granted the defendants summary judgment on the as-applied claims, holding that the evaluation policies implemented under the Act were justified by a rational basis.
• Plaintiffs appealed the district court’s order to the United States Court of Appeals for the Eleventh Circuit.