Oneal v. Colton Consolidated School Dist. No. 306
1976 Wash. App. LEXIS 1735, 16 Wash. App. 488, 557 P.2d 11 (1976)
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Rule of Law:
When performance of a personal services contract becomes impossible due to a party's physical incapacity arising through no fault of their own, the contract is discharged by operation of law, relieving both parties of their duties to perform. Consequently, the non-performing party cannot be held in breach, and the other party's corresponding obligations are also extinguished.
Facts:
- In April 1974, Stanley Oneal and the Colton Consolidated School District No. 306 entered into a contract for Oneal to teach during the 1974-75 school year, starting August 29, 1974.
- Oneal suffered from progressively deteriorating eyesight as a result of diabetes.
- During the summer of 1974, prior to the start of the school year, Oneal's eyesight deteriorated to the point that he believed he would be physically unable to perform his teaching duties.
- On July 24, 1974, Oneal submitted a written resignation to the District, making it conditional upon receiving payment for his 27.5 days of accumulated sick leave.
- The District did not immediately act upon his conditional resignation offer.
- Oneal did not report for work when the school year commenced on August 29, 1974, because of his physical incapacity.
- A medical report confirmed Oneal was 'disabled' from his teaching duties due to his eyesight, making him eligible for disability benefits.
Procedural Posture:
- Oneal submitted a conditional resignation to the Colton Consolidated School District, which the District did not accept.
- After Oneal failed to report for work, the District discharged him with notice of probable cause on October 3, 1974.
- Oneal (plaintiff) appealed his discharge and sought damages in the Superior Court (trial court).
- The Superior Court upheld the District's actions, finding that Oneal had breached the contract.
- Oneal (appellant) appealed the Superior Court's judgment to the Court of Appeals of Washington (this court), with the District as the appellee.
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Issue:
Is a teacher's employment contract, which becomes impossible to perform due to the teacher's severe physical incapacity before the performance period begins, discharged by operation of law under the doctrine of impossibility, thereby preventing a breach and invalidating a subsequent discharge for cause?
Opinions:
Majority - McInturff, C.J.
Yes, the contract is discharged by operation of law. When a party's performance of a personal services contract is rendered impossible by physical incapacity, the contractual duty is discharged by law. The court found that Oneal's deteriorating eyesight made it impossible for him to fulfill his teaching duties. The doctrine of impossibility applies not only to strict impossibility but also to impracticality arising from extreme and unreasonable difficulty. Because Oneal's duty to perform was legally discharged before the school year began, there was no contract left for him to breach. Therefore, the District's subsequent discharge of Oneal for failure to appear for work was without sufficient cause and must be expunged from his record. However, because the entire contract was discharged, the District's corresponding duty to pay sick leave was also extinguished, as the employment relationship ceased to exist before performance was due.
Analysis:
This case clarifies the application of the impossibility of performance doctrine to personal services and employment contracts. It establishes that a supervening physical incapacity which makes performance impossible is a valid legal excuse that discharges the entire contract, rather than a breach by the employee. This holding protects employees from being penalized for unavoidable health issues, but it also confirms that the discharge of the contract is total, extinguishing the employer's obligations (such as paying out benefits) that were contingent on the employment relationship continuing into the performance period.
