Alaska Statutes

Alaska Stat. § 14.20.170 (2026)

Dismissal

✓ current as of July 2026
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Sec. 14.20.170. Dismissal.
 (a) A teacher, including a teacher who has acquired tenure rights, may be dismissed at any time only for the following causes:
     (1) incompetency, which is defined as the inability or the unintentional or intentional failure to perform the teacher's customary teaching duties in a satisfactory manner;

     (2) immorality, which is defined as the commission of an act that, under the laws of the state, constitutes a crime involving moral turpitude; or

     (3) substantial noncompliance with the school laws of the state, the regulations or bylaws of the department, the bylaws of the district, or the written rules of the superintendent.

 (b) A teacher may be suspended temporarily with regular compensation during a period of investigation to determine whether or not cause exists for the issuance of a notification of dismissal according to AS 14.20.180.

 (c) A teacher who is dismissed under this section is not entitled to a plan of improvement under AS 14.20.149.




Notes of Decisions
Cited in 13 cases (2 in the last 5 years), 1964–2025 · leading case: Watts v. Seward Sch. Bd., 421 P.2d 586 (Alaska 1966).
Watts v. Seward Sch. Bd., 421 P.2d 586 (Alaska 1966). · cites it 35× “1957, chapter 71, section 2 (now AS 14.20.170) first stated and defined the causes for nonretention.”
Kenai Peninsula Borough Bd. of Educ. v. Brown, 691 P.2d 1034 (Alaska 1984). · cites it 12× “The substantive challenge is based on the sufficiency of evidence to support a finding that the teacher committed an act constituting a crime involving moral turpitude.”
Nichols v. Eckert, 504 P.2d 1359 (Alaska 1973). · cites it 10× “Both letters of dismissal cited AS 14.20.170(a) as authorizing the dismissal.”
Toney v. Fairbanks North Star Borough Sch. Dist., 881 P.2d 1112 (Alaska 1994). · cites it 10× “AS 14.20.170 provides in relevant part: (a) A teacher, including a teacher who has acquired tenure rights, may be dismissed at any time only for the following causes: (2) immorality, which is defined as the commission of an act that, under the laws of this state, constitutes a…”
Kilmer v. Dillingham City Sch. Dist., 932 P.2d 757 (Alaska 1997). · cites it 6× “NOTES [1] AS 14.20.170 provides: A teacher ... may be dismissed at any time only for the following causes: (1) incompetency, which is defined as the inability or the unintentional or intentional failure to perform the teacher's customary teaching duties in a satisfactory manner;…”
Watts v. Seward Sch. Bd., 454 P.2d 732 (Alaska 1969). · cites it 8× “The superior court, acting as an intermediate appellate court, held as a matter of law that neither appellants' circulation of the Open Letter of May 18, 1959, nor their circulation of the recall petition constituted "immoral conduct" under AS 14.20.170(a) (2). The superior…”
Nenana City Sch. Dist. v. Coghill, 898 P.2d 929 (Alaska 1995). “However, AS 14.20.170 provides that (a) A teacher, including a teacher who has acquired tenure rights, may be dismissed at any time only for the following causes: [[Image here]] (3) substantial noncompliance with the school laws of the state, the regulations or bylaws of the…”
Skagway City Sch. Bd. v. Davis, 543 P.2d 218 (Alaska 1975). “AS 14.20.170(a)(3). 5 . 4 AAO 15.030(d). 6 .”
Wendte v. State, Bd. of Real Est. Appraisers, 70 P.3d 1089 (Alaska 2003). “The statute at issue in Brown, AS 14.20.170, provided in part that "[al teacher .”
Watts v. Seward Sch. Bd., 395 P.2d 372 (Alaska 1964). “(1957) [Now AS 14.20.170]. 8 . Sec Keiner v. City of Anchorage, 378 P.”
R. Brett Stirling v. North Slope Borough Sch. Dist. (Alaska 2025). · cites it 20× “To the extent we are called upon to interpret the terms of AS 14.20.170 in this context, we apply the reasonable basis standard in light of the Board’s expertise regarding the implicated job qualifications and duties, as well as the involvement of “fundamental policies within…”
Reiné Loebs v. Lower Yukon Sch. Dist. (Alaska 2024). · cites it 3× “Loebs’s contract allowed the District to terminate her employment for failure to “discharge the duties imposed either through incapacity or disability, or for cause” as defined in AS 14.20.170. 1 In April 2019 a teacher’s aide observed Loebs acting “very strange” in her…”
— Alaska Stat. § 14.20.170(2) — 1 case
Watts v. Seward Sch. Bd., 421 P.2d 586 (Alaska 1966). “1957, chapter 71, section 2 (now AS 14.20.170) first stated and defined the causes for nonretention.”
— Alaska Stat. § 14.20.170(a) — 8 cases
Watts v. Seward Sch. Bd., 421 P.2d 586 (Alaska 1966). “1957, chapter 71, section 2 (now AS 14.20.170) first stated and defined the causes for nonretention.”
Watts v. Seward Sch. Bd., 454 P.2d 732 (Alaska 1969). “The superior court, acting as an intermediate appellate court, held as a matter of law that neither appellants' circulation of the Open Letter of May 18, 1959, nor their circulation of the recall petition constituted "immoral conduct" under AS 14.20.170(a) (2). The superior…”
Nichols v. Eckert, 504 P.2d 1359 (Alaska 1973). “Both letters of dismissal cited AS 14.20.170(a) as authorizing the dismissal.”
Kilmer v. Dillingham City Sch. Dist., 932 P.2d 757 (Alaska 1997). “NOTES [1] AS 14.20.170 provides: A teacher ... may be dismissed at any time only for the following causes: (1) incompetency, which is defined as the inability or the unintentional or intentional failure to perform the teacher's customary teaching duties in a satisfactory manner;…”
Toney v. Fairbanks North Star Borough Sch. Dist., 881 P.2d 1112 (Alaska 1994). “AS 14.20.170 provides in relevant part: (a) A teacher, including a teacher who has acquired tenure rights, may be dismissed at any time only for the following causes: (2) immorality, which is defined as the commission of an act that, under the laws of this state, constitutes a…”
— Alaska Stat. § 14.20.170(a)(1) — 2 cases
Nichols v. Eckert, 504 P.2d 1359 (Alaska 1973). “Both letters of dismissal cited AS 14.20.170(a) as authorizing the dismissal.”
R. Brett Stirling v. North Slope Borough Sch. Dist. (Alaska 2025). “To the extent we are called upon to interpret the terms of AS 14.20.170 in this context, we apply the reasonable basis standard in light of the Board’s expertise regarding the implicated job qualifications and duties, as well as the involvement of “fundamental policies within…”
— Alaska Stat. § 14.20.170(a)(2) — 3 cases
Kenai Peninsula Borough Bd. of Educ. v. Brown, 691 P.2d 1034 (Alaska 1984). “The substantive challenge is based on the sufficiency of evidence to support a finding that the teacher committed an act constituting a crime involving moral turpitude.”
Toney v. Fairbanks North Star Borough Sch. Dist., 881 P.2d 1112 (Alaska 1994). “AS 14.20.170 provides in relevant part: (a) A teacher, including a teacher who has acquired tenure rights, may be dismissed at any time only for the following causes: (2) immorality, which is defined as the commission of an act that, under the laws of this state, constitutes a…”
R. Brett Stirling v. North Slope Borough Sch. Dist. (Alaska 2025). “To the extent we are called upon to interpret the terms of AS 14.20.170 in this context, we apply the reasonable basis standard in light of the Board’s expertise regarding the implicated job qualifications and duties, as well as the involvement of “fundamental policies within…”
— Alaska Stat. § 14.20.170(a)(3) — 2 cases
Skagway City Sch. Bd. v. Davis, 543 P.2d 218 (Alaska 1975). “AS 14.20.170(a)(3). 5 . 4 AAO 15.030(d). 6 .”
R. Brett Stirling v. North Slope Borough Sch. Dist. (Alaska 2025). “To the extent we are called upon to interpret the terms of AS 14.20.170 in this context, we apply the reasonable basis standard in light of the Board’s expertise regarding the implicated job qualifications and duties, as well as the involvement of “fundamental policies within…”
— Alaska Stat. § 14.20.170(aX3) — 1 case
Renfroe v. Green, 626 P.2d 1068 (Alaska 1980).
— Alaska Stat. § 14.20.170(b) — 2 cases
Nichols v. Eckert, 504 P.2d 1359 (Alaska 1973). “Both letters of dismissal cited AS 14.20.170(a) as authorizing the dismissal.”
Renfroe v. Green, 626 P.2d 1068 (Alaska 1980).
— Alaska Stat. § 14.20.170(c) — 1 case
Kilmer v. Dillingham City Sch. Dist., 932 P.2d 757 (Alaska 1997). “NOTES [1] AS 14.20.170 provides: A teacher ... may be dismissed at any time only for the following causes: (1) incompetency, which is defined as the inability or the unintentional or intentional failure to perform the teacher's customary teaching duties in a satisfactory manner;…”
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