NAVIGATING THE DANGEROUS
SEAS OF TEACHER DISCIPLINE
ACSA’s 2014 Personnel Institute
October 9, 2014
Presented By:
Michelle L. Cannon
Sacramento | Bakersfield | Roseville | San Luis Obispo | Walnut Creek
Introduction
 Every former student can recall the “teacher who couldn’t
teach.” Yet the belief that such teacher’s tenure meant
absolute protection from dismissal was shared by students,
parents, school administrators and school boards. Myth or
reality?
 It is possible to dismiss poor teachers and teachers who engage
in misconduct.
 An absolute first step in the teacher dismissal process is proper
training of school administrators in evaluating teachers and
documenting misconduct. District administrators must also
develop a plan and work as a team with advice of legal counsel.
Knowledge about specific legal
requirements
 Statutory causes for dismissal
 Procedural pitfalls in Education Code
 Personnel files (Ed. Code § 44031) and Miller v.
Chico
 Performance evaluations & Documentation
 Commission on Professional Competence (CPC) and
Hearing Process
 Dismissal Process from A to Z
Changes in law starting
January 1, 2015:
 “Egregious Conduct”
 Alternative process
 Miscellaneous changes
Statutory Causes for Dismissal of
Permanent Teacher
 Education Code § 44932(a) lists the following causes for
dismissal:
 Immoral Conduct (Immediate unpaid suspension per Ed.




Code § 44939)
Unprofessional conduct (45-day Notice of Deficiency per
Ed. Code § 44938(a))
Dishonesty
Unsatisfactory Performance (90-day Notice of Deficiency
per Ed. Code § 44938(a))
Evident Unfitness for Service
Statutory Causes for Dismissal of
Permanent Teacher (cont’d)
 Physical/Mental condition making person unfit to




teach
Persistent Violation of or Refusal to Obey School
Laws of the State or Reasonable Regulations [of
State or Governing Board]
Conviction of a Felony or any Crime Involving Moral
Turpitude (also allows for immediate unpaid
suspension)
Knowing membership in Communist Party*
Alcoholism or other drug abuse which makes
employee unfit to teach
Statutory Causes for Suspension of
Permanent Teacher
 Education Code § 44932(b)
authorizes suspension without
pay for a specific period of
time.
 Only for Unprofessional
Conduct
 Only if 45-day Notice of
Deficiency has been sent
 Only if there is no provision in
collective bargaining
agreement
Immediate Unpaid Suspension
 Education Code § 44939 authorizes immediate unpaid
suspension upon filing of charges for dismissal.
 May be used when teacher charged with immoral
conduct, conviction of a felony or a crime involving
moral turpitude, incompetency due to mental
disability, and willful refusal to perform regular
assignments without reasonable cause.
Procedural Pitfalls – Education Code
 Education Code § 44944(a):
“No witness shall be permitted to testify at the hearing except
upon oath or affirmation. No testimony shall be given or
evidence introduced relating to matters which occurred more
than four years prior to the date of the filing of the notice.
Evidence of records regularly kept by the governing board
concerning the employee may be introduced, but no decision
relating to the dismissal or suspension of any employee shall
be made based on charges or evidence of any nature relating
to matters occurring more than four years prior to the filing of
the notice.” (Emphasis added.)
Procedural Pitfalls – Education Code
(cont’d)
 This section places a strict limitation on the time that
can elapse between any incident and the filing of the
Notice of Dismissal and Statement of Charges.
 Possible exception based upon “equitable estoppel”
(Atwater case).
 Education Code § 44944(a) also provides that hearing
must commence within 60 days from date of
employee’s demand for hearing.
 Statement of Charges must be verified.
Procedural Pitfalls – Education Code
(cont’d)
 Two charging documents:
 Statement of Charges under Education Code
 Accusation under Administrative Procedure
Act
 Education Code § 44936 prohibits giving of
Notice of Dismissal or Suspension between
May 15 and September 15.*
Procedural Pitfalls – Cases
 Morrison standards (Morrison v. State Board of Education
– 1969 California Supreme Court)
 Applies to teacher dismissal based upon the following
causes:
 Immoral Conduct
 Dishonesty
 Evident Unfitness for Service
 Case involved private, consensual, noncriminal
homosexual relationship which had occurred 19 months
before
 Conduct must indicate teacher is not fit to teach
Procedural Pitfalls – Cases (cont’d)
 Morrison standards:








Harm caused by conduct to students or fellow teachers
Degree of harm anticipated
Proximity or remoteness in time
Type of teaching certificate
Extenuating or aggravating circumstances
Motive
Likelihood of recurrence
Chilling effect on legal rights
Procedural Pitfalls – Cases (cont’d)
 Impact of Morrison – there must be some
nexus between teacher’s conduct and job
performance before conduct can form basis for
dismissal
 Recent update – San Diego USD v. CPC (2011)
Personnel Files
(Education Code §44031 and Miller v. Chico)
 If it is not written down, given to employee and placed in
the employee’s personnel file within a reasonable time, it
did not happen.
 Intent is to give teacher notice of any performance
problems and the opportunity to respond, i.e. to tell his or
her side of the story.
 Unless CBA or Policy prohibits it, supervisors may keep a
“working file” to store temporary records (such as
calendars or handwritten notes) relative to recent
incidents.
Personnel Files
(Education Code §44031 and Miller v. Chico)
(cont’d)
 Any information in working file that has ongoing
significance must find its way from working file
into personnel file via:
 Performance evaluation
 Formal documentation
 Must be made available for inspection
Personnel Files
(Education Code §44031 and Miller v. Chico)
(cont’d)
 Magic paragraph “Pursuant to Education Code § 44031, you have the
right to comment upon this Notice and to have your
written comments attached to a copy, which will be
placed in your personnel file maintained in the
district’s personnel office in approximately ten days.”
Sound Evaluations Are Critical Component Of
A Winning Case Based on Unsatisfactory
Performance
 Why are evaluations and documents so important?
Because documents speak louder than words!
 Full compliance with all provisions in CBA, including
evaluation forms
 Timelines
 Procedural steps
Sound Evaluations Are Critical Component Of
A Winning Case Based on Unsatisfactory
Performance (cont’d)
 Goal:
 Provide written record to support testimony
during hearing before CPC
 Importance of detail in evaluation – creating
an accurate record of what is occurring in
classroom
 Avoid union challenge
TEACHER EVALUATIONS CAN MAKE
A DIFFERENCE!!
 Properly prepared evaluations can reward and
support good teachers and help them become better
teachers
 Enhance ongoing conversations between teacher and
administrator about what works and what does not
work and why and how to improve
TEACHER EVALUATIONS CAN MAKE A
DIFFERENCE!! (cont’d)
 Minimize misunderstandings – verbal
communication can be misunderstood
 Provide record for teacher for later reference
 Stimulate teacher reflection to enhance student
learning
 Provide documentation for any discipline
TEACHER EVALUATIONS CAN MAKE A
DIFFERENCE!! (cont’d)
 But remember:
 Primary objective is always to improve
job performance
 Secondary objective is to document poor
performance
Building a Winning Case
Types of Documentation:
 Evaluations
 Letters of warning, direction, reprimand
 Formal notices of deficiency (with most recent
evaluation attached)
 45-Day Notice of Unprofessional Conduct
 90-Day Notice of Unsatisfactory Performance
 Combined notice for both
Building a Winning Case (cont’d)
 Plan for Improvement
 In a dismissal hearing documentation is key. School Districts
are inherently at a disadvantage in witness credibility battles.
The natural tendency is to resolve any doubts in favor of the
“underdog” the teacher who is fighting for their job.
 Without documentation teacher may argue performance
was satisfactory and/or had no knowledge of problems.
 Only accurate and specific documentation can counter this
argument.
Commission on Professional
Competence
 Dismissal hearing is conducted before a three-person panel
(CPC) composed of:



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Administrative law judge who serves as chairperson;
One member selected by teacher;
One member selected by district; and
Both of these members cannot be employees of the district
initiating the dismissal, must hold a currently valid
credential, and must have at least five years’ experience
within the past ten years in the discipline of the teacher.
Commission on Professional
Competence (cont’d)
 Standard of proof – preponderance of
the evidence.
 Written decision by CPC.
Other Important Reminders
 Placement of teachers on paid administrative
leave.
 Weingarten Rights – Employee’s right to
representation in investigatory
interviews/meetings that employee reasonably
believes might result in disciplinary action.
 Right is not triggered until employee requests
representation.
 School district has no obligation to inform
employee of the right.
Dismissal of Probationary
Teachers:
 Non-reelection on or before March 15 of second
consecutive complete school year.
 But effective at end of the year, not mid-year.
 Dismissal mid-year under Educ. Code §44948.3.
 Same causes as for permanent employees.
 45 day/90 day notice requirements apply.
Dismissal of Probationary Teachers:
(cont’d)
 Notice of dismissal by March 15th for 2nd year
probationary employees.
 Must include statement of reasons and notice of
opportunity to appeal.
 Teacher has 15 days from receipt of notice to request a
hearing.
 Hearing before an ALJ with a recommended decision to
governing board.
 No CPC panel.
 Suspension without pay for a specified period of time as
an alternative to dismissal.
Ok, We Are Ready to Move Forward
With Dismissal of A Permanent Teacher,
Now What?
 Key Decision before filing
charges – is it worth going
forward?
Ok, We Are Ready to Move Forward
With Dismissal, Now What? (cont’d)
 Even if we can prove all these facts and charges
– will the CPC panel actually vote to terminate?
 Approval and support from administration at all
levels?
 Support from key witnesses?
Ok, We Are Ready to Move Forward
With Dismissal, Now What? (cont’d)
 Do we have all relevant documents in front of us;
nothing too embarrassing or inconsistent with the
dismissal case.
 Having all documents this early helps to prepare
charges and respond to the teacher’s later requests
for documents and information.
 Causes supporting dismissal in Educ. Code § 44932.
 Must be nexus between conduct and ability to
function as a teacher.
Pre-Disciplinary Conference
 Send “Skelly” letter; setting informal meeting to notify teacher
of intent to recommend disciplinary action (including dismissal)
to the Superintendent and Board.
 It should very closely resemble the draft Statement of Charges
(see below).
 The employee gets the letter a few days ahead of the meeting
time.
 Allow employee to bring representative (Weingarten).
Pre-Disciplinary Conference
 This is employee’s chance to respond to charges before they go
to the Board.
 Purpose is to clear up factual mistakes, allow employee to
state why the proposed action is improper under the
circumstances.
 Keep it short and simple; just hear what they have to say.
Pre-Disciplinary Conference
 After meeting with Human Resources representative, that
person then decides whether to continue to recommend
discipline.
 If district decides not to continue, notice should be sent to
employee.
 Full Skelly hearing like that done with classified employees not
required here.
Statement of Charges
 List all specific facts supporting charges/causes
for dismissal; including dates and times, if
possible.
 Include specific laws, rules, regulations violated.
 Adults referred to by first and last name,
students by first name and last initial.
Statement of Charges
 List all efforts to help the teacher improve, or understand
the problem(s).
 Have Superintendent sign charges and a verification.
 Don’t charge Unprofessional Conduct or Unsatisfactory
Performance without giving the required prior written
notice of such charges and opportunity / plan to improve
(45 and 90 days, respectively) (Ed. Code, § 44938).
Statement of Charges
 File with board.
 Board decides whether to issue Notice of
Intention to Suspend and/or Dismiss in 30 days.
 (Ed. Code, § 44934.)
Board Meets to Decide Whether to
Authorize Dismissal
Serve Notice of Intention to Dismiss In 30 Days.
 Cannot be served on teacher between May 15 and
September 15 (Ed. Code, § 44936).
 May include notice of unpaid suspension pending
hearing, under certain charges (Ed. Code, § 44939).
 Personal service or certified mail.
Board Meets to Decide Whether to
Authorize Dismissal
 Must include copies of:
 Notice of Intention to Suspend and/or
Dismiss after 30 days if no hearing
requested
 Statement of Charges
Board Meets to Decide Whether to
Authorize Dismissal
 Blank Request for Hearing.
 Copies of Education Code sections 44930
through 44988.
 Copies of Government Code sections 11507.5;
11507.6 and 11507.8.
 Proof of Mailing/Service by registered or
certified mail; or personal service.
Wait for Employee’s Written Request
for Hearing.
 If not received within 30 days, Teacher is
automatically terminated (Ed. Code, § 44937).
 If received within 30 days:
Contact Office of Administrative Hearings
(“OAH”) to open a file and get possible hearing
dates.
After Request, Board Must Either Rescind its
Action or Schedule a Hearing (Ed. Code, §
44943).
 At the next possible board meeting, have Board
vote to either:
 Rescind the disciplinary action; or
 Proceed with a hearing on the matter.
 Once charges issued and CPC is convened, District
cannot unilaterally dismiss charges. See 2011 Boliou
decision.
Prepare Accusation
(Gov. Code, §§ 11500 et seq.)
 Hearing must start within 60 days of receiving request (unless
teacher agrees otherwise); Education Code section 44944.
 Before setting hearing dates, document at least one attempt to
consult/ agree with employee on dates.
 If you need more time, try to get the employee to agree, in
writing to dates farther away than 60 days, if possible; or
formally “open” the hearing within 60 days and postpone the
rest until later.
Prepare Accusation
(Gov. Code, §§ 11500 et seq.) (cont’d)
 Draft detailed Accusation (re-worded Statement of Charges)
with an emphasis on specific, provable misconduct/violations;
drafted like a “complaint” in a lawsuit; showing how all the
specific elements of each charge are met under the facts and
circumstances; (Gov. Code §11503.)
 Must specify any statutes and rules violated, not just charges
phrased in the language of those statutes / rules.
Obtain District’s Panel Member.
 On three member panel, district picks a member, so does
teacher; other member is an Administrative Law Judge who
runs the process; rules on evidence and objections.
 Member must be appointed by 7 days before hearing, or
appointment power is waived.
 Person cannot be related to the teacher, nor an employee of
the district.
Obtain District’s Panel Member
(cont’d)
 Must hold a valid teaching credential and have taught for at
least five years “in the discipline of the employee” out of the
last ten years.
 This definition allows the district to appoint an administrator
who was previously a teacher.
 Start your search early; and be persistent, as it often takes
longer than you anticipate, and can confer substantial benefit
at hearing.
Obtain District’s Panel Member
(cont’d)
 Difficulty is that they only get reimbursement of costs
and expenses of serving; no additional salary, and
their employer must continue to pay them full salary
(and cost of a substitute or replacement).
 This can be burdensome in a hearing lasting many
days.
Serve the Accusation Packet, which
contains:
 Statement to Respondent (setting forth basic notice
of formal charges and various procedural rights; e.g.
discovery and to be represented by counsel).
 Accusation (Formal charging document; should
closely resemble both the Predisciplinary Letter, and
the Statement of Charges).
Serve the Accusation Packet, which
contains: (cont’d)
 Notice of Defense and Request for Hearing Form
(check-off form response per Government Code
section 11506 allowing teacher to object to the form
of the Accusation and respond to it by admission or
denial; redundancy in Government Code requires
teacher to again request a hearing within 15 days or
waive right to hearing; failure to file notice of defense
also waives hearing right).
Serve the Accusation Packet, which
contains: (cont’d)
 Statement of Charges (another copy, with same
attachments).
 Proof of Mailing / Service by registered or certified
mail or by personal service.
Prepare for Hearing
 You have only 30 days from date of Accusation to send out
Discovery requests; try to send out district’s discovery requests
at the same time as the Accusation packet, to have documents
prior to any depositions.
 Early requests allow time for motion to compel further
answers /response, if teacher or attorney is uncooperative;
(only have 15 days from refusal).
 Compile hearing binders.
Prepare for Hearing (cont’d)
 Contact district’s witnesses to make sure their testimony are
still solid and consistent with what they told you before.
 Substantial amount of work in a short period of time.
 Often, teacher’s attorney will file meritless “nuisance” motions
(to limit or exclude evidence / discovery, dismiss entire action
on “constitutional” or “jurisdictional” grounds) to run up
district’s costs; discourage district from dismissing other
teachers; disrupt district’s preparation for upcoming hearing.
Send Notice of Hearing at Least 10
Days Before (Gov. Code, § 11509)
 Gives formal notice of time
and place of hearing;
reminder of various rights.
 Arrange for court reporter to
record all proceedings.
Complete Discovery by One Week
Before Hearing
 Broad discovery allowed; Education Code section
44944(a).
 Not only Government Code section 11507.6, but also
includes “all rights and duties of any party in a civil
action brought in a Superior Court”; starting with
Code of Civil Procedure section 2016.
Complete Discovery by One Week
Before Hearing
 Broad powers to inquire into any information/matter
reasonably calculated to lead to admissible evidence,
through:
 Requests for Documents (and other tangible items)
 Written Questions and Answers (Interrogatories)
 Written Requests for Admissions (Statements to admit or
deny in writing)
 Live Question and Answer Sessions (Depositions)
If Necessary, Amend Accusation to
State Additional Facts or Charges
 Sometimes, discovery reveals new facts and possible
new charges.
 You can amend accusation to reflect these new facts
and charges you plan to use and prove at hearing.
 Has teacher been contacting your witnesses?
Intimidation? Other misconduct arisen since the
charges filed?
If Necessary, Amend Accusation to
State Additional Facts or Charges
 However, doing so will most likely cause the other
side to request, and obtain a postponement of the
hearing, to help prepare a defense against any new
matter raised.
 District counsel can also move to amend the
accusation to conform to proof at the hearing itself.
Settlement
 Usually, the presiding ALJ will require at least one
settlement conference (with different Judge than the
one hearing the case).
 Most cases settle for simple economic/reality
reasons; district does not want to have to pay
thousands of dollars in attorney fees and costs, and
teacher does not want to create a public, written
record of their misconduct.
Settlement (cont’d)
 Good documentation/investigation/preparation often
leads to fast settlement on favorable terms.
 Do a careful cost/benefit analysis; what is in the
district’s interests?
 Draft the settlement agreement carefully to
encompass and prevent as much future trouble as
possible.
Settlement (cont’d)
 Get teacher’s full release of claims against district
(prevents future litigation by the teacher).
 This may or may not prevent litigation by third parties
(students and parents) against district and/or teacher.
Settlement (cont’d)
 Settlement terms generally cannot be made
confidential.
 Resignation under circumstances related to one or
more allegations of misconduct must be reported to
CTC; per Title 5 regulations (§§ 80300 et seq.); within
30 days.
Attend Pre-Hearing Conference
 Purpose is to clarify and narrow issues at hearing, to
make the process more efficient, if possible.
 Parties exchange final lists of witnesses and evidence.
 Make any last minute motions; requests for rulings.
 Settlement usually also discussed.
Dismissal Hearing
 Depending on facts, lasts from 2 days to 30 days.
 Everything is recorded by court reporter (creates record for
any appeal).
 Despite “informal” nature of hearing compared to court
proceeding, it’s usually quite tense and acrimonious;
prepare for cross-examination.
Dismissal Hearing (cont’d)
 A lot is at stake for both parties; economically;
politically; emotionally.
 Decision is written, and is issued in 2 to 8 weeks (100
day max.); depending on size of case and ALJ
caseload.
Dismissal Hearing (cont’d)
 Appeal is by motion for reconsideration within 30
days, or by request for appeal to Superior Court
within 60 days.
 When any testimony or evidence concerns private
pupil records or other private information, the ALJ
may order that part of the hearing closed and
evidence sealed (made a non-public record).
Dismissal Hearing (cont’d)
 Note: districts have some breathing room on process:
they are allowed to make “non-substantive
procedural errors” in the process and still get a
dismissal decision, so long as the errors are not
“prejudicial errors.”
 Hopefully, this prevents a decision in favor of a
teacher on mere technicalities.
CPC Decision
 CPC decision must be by majority vote and is
limited to: (1) employee should be dismissed;
(2) employee should be suspended without
pay; or (3) employee should not be dismissed
or suspended.
If Teacher Wins
 Gets immediate reinstatement plus
back-pay, if any was withheld.
 District must pay full administrative
costs of hearing.
If District Wins
 If dismissal is for immoral conduct or conviction of a
felony or crime involving moral turpitude, the Board
must send the CTC and County Board a full transcript
of hearing, and request that any certificate for the
Teacher be revoked if the employee is not ordered
reinstated after appeal; Education Code section
44947.
If District Wins (cont’d)
 District must pay full administrative costs of
hearing.
 Report dismissal to CTC within 30 days.
 There is always a possibility of a lawsuit or
other challenge by teacher alleging wrongful
termination; violation of rights, etc.
AB 215: Egregious Conduct
(Effective 1/1/15)
 Adds egregious misconduct as a cause for dismissal under Education Code
section 44932.
 Egregious misconduct is a form of immoral conduct and is defined by
particular offenses:
 Education Code section 44010 (sex offenses),
 Education Code section 44011 (drug offenses), and
 Penal Code sections 11165.2 to 11165.6 (child neglect, endangerment,
abuse).
AB 215: Egregious Conduct
(Effective 1/1/15)
 Adds Education Code section 44934.1 for processing egregious
conduct cases:
 Requires service on the employee of written notice of the
district’s intent to dismiss, along with a statement of
charges, and allows for immediate unpaid suspension
pending dismissal under newly added Education Code
section 44939.1.
 Notice of dismissal may be served at any time during the
year. (Educ. Code § 44936(a).)
AB 215: Egregious Misconduct
New Dismissal Process
 Adds Education Code section 44944.1 as exclusive means for dismissal
based solely on charges of egregious misconduct. (Educ. Code §
44944.1(b).)
 Hearing conducted by single ALJ instead of 3-member CPC panel. (Educ.
Code § 44944.1(c).)
 Hearing must begin within 60 days of employee’s demand for hearing and
OAH must prioritize these cases over other dismissal cases. (Educ. Code §
44944.1(d)(1)(A).)
AB 215: Egregious Misconduct
New Dismissal Process
 Evidence may be admitted regarding egregious
misconduct that occurred more than 4 years
prior to the initiation of the proceedings.
(Educ. Code § 44944.1(d)(3).)
AB 215: Egregious Misconduct
New Dismissal Process
 If ALJ determines employee should be dismissed or suspended,
the district and State share expenses of hearing (including ALJ)
and district and employee pay own attorney fees.
 IF ALJ determines employee should not be dismissed or
suspended, district pays costs of hearing and reasonable
attorney’s fees for employee.
AB 215: Changes to Existing Law
 Eliminates the May 15- Sept 15 “blackout period” for serving
dismissal charges for all causes of action other than
unsatisfactory performance.
 Charges based on unsatisfactory performance may only be
served during the instructional year of the schoolsite where
the teacher is physically employed.
 Hearing must be commenced within 6 months and completed
within 7 months.
AB 215: Changes to Existing Law
 CPC can be waived by mutual agreement so
that heard by single ALJ.
 Discovery now limited to depositions, initial
disclosures & Pre-hearing disclosures.
AB 215: Changes to Existing Law
(unpaid suspension not based on egregious misconduct)
 Allows employees who have been immediately suspended without pay to
file a motion with OAH for reversal of the suspension within 30 days and a
hearing must be held within 30 days of filing motion. (Educ. Code §
44939(c).)
 ALJ must issue an order within 15 days of the hearing and if the suspension
is not upheld, the district must provide the employee with lost wages,
benefits, and compensation within 14 days of service of the order.
AB 215: Changes to Existing Law
 Adds Education Code section 44939.5 which prohibits districts
from entering settlement agreements to remove credible
complaints of, substantiated investigations into, or discipline
for egregious misconduct from personnel files.
 Districts must disclose they made a report to the CTC about
egregious misconduct when other school employers inquire
about a potential applicant. (Educ. Code § 44939.5.)
Amended Title V, section 80303
Regulation
 Effective July 1, 2014.
 Section 80303 requires superintendents to report change of certificated
employment status as a result of misconduct to the CTC.
 Prior language often resulted in over-reporting to include “misconduct”
such as unsatisfactory performance or even layoffs.
 Prior law also failed to provide guidance to superintendents as to
documentation which must be submitted.
Amended Title V, section 80303
Regulation
 Provides CTC must be notified whenever, as a result of misconduct or while
an allegation of misconduct is pending, an employee is: dismissed or nonreelected; resigns, is suspended or placed on unpaid admin leave (as a final
adverse employment action); retires or is “otherwise terminated.”
 Otherwise terminated “shall not include or be interpreted to include a
change of status that is solely for unsatisfactory performance … or a layoff
or reduction in force[.]”
Amended Title V, section 80303
Regulation
 Requires “all known information about each alleged act of misconduct”
organized as follows:
 Name of credential holder; current address of credential holder; name
of reporting district; name of last school or district assignment;
explanation of the allegation of misconduct or pending allegation of
misconduct; current contact information for all persons who may have
information relating to the alleged misconduct; and any and all
documentation related to the case.
Amended Title V, section 80303
Regulation
 Failure to make a report constitutes
unprofessional conduct.
 CTC must now investigate a superintendent
who fails to file required report.
Thank You!
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