Arkansas Code Annotated

Ark. Code Ann. § 6-17-1502 (2026)

Definitions

✓ current as of May 2026

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As used in this subchapter:
1. 1. “Probationary teacher” means a teacher who has not completed three (3) successive years of employment in the school district in which the teacher is currently employed.
  2. 1. A teacher employed in a school district in this state for three (3) years shall be deemed to have completed the probationary period.
    2. However, an employing school district may, by a majority vote of its directors, provide for one (1) additional year of probationary status; and
2. “Teacher” means any person, exclusive of the superintendent or assistant superintendent, employed in an Arkansas public school district who is required to hold a teaching license from the State Board of Education as a condition of employment.
A teacher who has completed three (3) successive years of employment in the school district in which the teacher is employed on July 4, 1983, or a teacher who has been given credit for a prior service in another school district as authorized by subdivision (a)(2) of this section, is deemed to have completed the required probationary period.

History. Acts 1983, No. 936, §§ 2, 4; A.S.A. 1947, §§ 80-1266.1, 80-1266.3; Acts 2011, No. 989, § 55.

Amendments. The 2011 amendment substituted “license from the State Board” for “certificate from the Department” in (a)(1).

Case Notes

Hearing.

Circuit court did not err in granting a teacher injunctive relief and enjoining a school district from denying the teacher a hearing or refusing to renew his contract until his rights were adjudicated in the hearing because the teacher was entitled to the provision of the Arkansas Teacher Fair Dismissal Act, § 6-17-1509, that afforded him a hearing; nothing in the Act indicates that a teacher is not employed unless he or she has a written contract, and the requirement of the Act, § 6-17-1506(a), that a teacher's contract must be renewed in writing refers to an original “contract” but does not specify that it be a written contract. Fayetteville Pub. Schs v. Dial, 2010 Ark. App. 296 (2010).

Notice.

Where substitute teacher failed to meet the definition of “teacher” under the Teacher Fair Dismissal Act, § 6-17-1502 et seq., and did not occupy a position that required a teaching license, he was not entitled to written notice of the nonrenewal of his teaching contract or a hearing on the matter. Harris v. Altheimer Unified Sch. Dist., 94 Ark. App. 152, 227 S.W.3d 437 (2006).

Probationary Teacher.

The General Assembly did not intend to allow a teacher to combine his or her years of teaching in different school districts to achieve nonprobationary status, but to require a teacher to complete three successive years of teaching in a single school district in this state. McGee v. Armorel Pub. Schs., 309 Ark. 59, 827 S.W.2d 137 (1992).

The General Assembly did not intend to require a school district to employ a teacher who had achieved nonprobationary status in another district on a nonprobationary status. McGee v. Armorel Pub. Schs., 309 Ark. 59, 827 S.W.2d 137 (1992).

Teacher.

Party who was employed by the district and required to be certified was a teacher; it does not matter if she was denominated a part-time teacher, a half-time teacher, or a replacement. Love v. Smackover Sch. Dist., 322 Ark. 1, 907 S.W.2d 136 (1995).

Where plaintiff was employed with the Department of Correction school district as a teacher and was required to have a state teaching certificate as prerequisite to employment, he was a teacher within the meaning of this section. Allred v. Ark. Dep't of Corr. Sch. Dist., 322 Ark. 772, 912 S.W.2d 4 (1995).

In a case where a teacher alleged that a school district breached its contract with the teacher by violating the Arkansas Teacher Fair Dismissal Act (TFDA), the teacher, although receiving the pay of a teacher, failed to meet the requirements set forth in this section; therefore, he was not a teacher for the purposes of the TFDA and the teacher lost the benefits provided by the TFDA and could not pursue an action under the TFDA. Sheets v. Dollarway Sch. Dist., 82 Ark. App. 539, 120 S.W.3d 119 (2003).

Grant of summary judgment in favor of the school district in the teacher's action after he was terminated was inappropriate because the unambiguous terms of the teacher's contract governed and the trial court erred in considering parol evidence in construing that contract. Further, the Teacher Fair Dismissal Act of 1983, § 6-17-1501 et seq. , defined “teacher” as any person, exclusive of the superintendent or assistant superintendent, employed in an Arkansas public school district who was required to hold a teaching certificate from the Department of Education as a condition of employment, pursuant to this section; it was undisputed that the teacher met that definition too. Barnett v. Mt. View Sch. Dist., 2010 Ark. App. 333, 374 S.W.3d 851 (2010).

In a case under the Arkansas Teacher Fair Dismissal Act, a superintendent and a school district failed to bring to a principal's attention the problems that were identified as reasons for termination and failed to document the efforts taken to assist the principal to correct the causes for potential termination. The principal was found to be a teacher because her contract required that she hold a teaching license. Jasper Sch. Dist. No. 1 v. Cooper, 2014 Ark. 390, 441 S.W.3d 11 (2014).

Cited: Roberts v. Van Buren Pub. Sch., 773 F.2d 949 (8th Cir. 1985); Hilton v. Pine Bluff Pub. Sch., 796 F.2d 230 (8th Cir. 1986); Sosebee v. County Line Sch. Dist., 320 Ark. 412, 897 S.W.2d 556 (1995).

Notes of Decisions

Cited in 16 cases (2 in the last 5 years), 1992–2024 · leading case: Sheets v. Dollarway Sch. Dist., 120 S.W.3d 119 (Ark. Ct. App. 2003).

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Sheets v. Dollarway Sch. Dist., 120 S.W.3d 119 (Ark. Ct. App. 2003). · cites it 22× “In that case, Love had worked as a certified teacher for a period of one year and was a probationary teacher as defined by Ark.Code Ann. § 6-17-1502. In July, she learned that she would not be rehired for her position in the upcoming school year.”

McGee v. Armorel Pub. Schs., 827 S.W.2d 137 (Ark. 1992). · cites it 14× “This appeal requires our interpretation of part of the Teacher Fair Dismissal Act, specifically Ark. Code Ann. § 6-17-1502 (1987). Our jurisdiction is pursuant to Ark.”

Foreman Sch. Dist. No. 25 v. Steele, 61 S.W.3d 801 (Ark. 2001). · cites it 2× “In the 1994 version of the TFDA, Steele was a “probationary teacher,” which is defined in section 6-17-1502(a)(2) as: (2) “Probationary teacher” means a teacher who has not completed three (3) successive years of employment in the school district in which the teacher is…”

Williams v. Little Rock Sch. Dist., 66 S.W.3d 590 (Ark. 2002). · cites it 2× “Ark. Code Ann. § 6-17-1502 (d) (Repl. 1999).”

W. Grove Sch. Dist. v. Terry, 885 S.W.2d 300 (Ark. 1994). · cites it 2× “The School District argues as its first point on appeal that its action against Terry was merely a reassignment of duties —• not a nonrenewal ■— and that the Teacher Fair Dismissal Act was not applicable. The facts do not bear this out.”

Sosebee v. Cnty. Line Sch. Dist., 897 S.W.2d 556 (Ark. 1995). · cites it 2× “See § 6-17-1502(a)(2) and (b). On May 1, 1992, her teaching contract was renewed for the 1992-1993 school year.”

Barnett v. Mountain View Sch. Dist., 374 S.W.3d 851 (Ark. Ct. App. 2010). · cites it 2× “” Ark.Code Ann. § 6-17-1502(a)(l) (Repl.2007).”

Bryan Mattox v. Mountain Home Sch. Dist., 2024 Ark. App. 303 (Ark. Ct. App. 2024). · cites it 2× “Arkansas Code Annotated section 6-17-1510 provides in part: (b)(1) Any licensed teacher who has been employed continuously by the school district three (3) or more years or who may have achieved nonprobationary status pursuant to § 6-17-1502 may be terminated or the board of…”

Allred v. Arkansas Dep't of Corr. Sch. Dist., 912 S.W.2d 4 (Ark. 1995). “§ 6-17-1502(a)(l). See also Love v. Smackover Sch.”

Greenwood Sch. Dist. v. Leonard, 285 S.W.3d 284 (Ark. Ct. App. 2008). “(b) Any certified teacher who has been employed continuously by the school district three (3) or more years or who may have achieved nonprobationary status pursuant to § 6-17-1502 may only be terminated or the board of directors may refuse to renew the contract of the teacher…”

Timpani v. Lakeside Sch. Dist., 386 S.W.3d 588 (Ark. Ct. App. 2011). “2007) 3 provides: (b) Any licensed teacher who has been employed continuously by the school district three (3) or more years or who may have achieved nonprobationary status pursuant to § 6-17-1502 may only be terminated or the board of directors may refuse to renew the contract…”

Love v. Smackover Sch. Dist., 907 S.W.2d 136 (Ark. 1995). · cites it 2× “Ark. Code Ann. § 6-17-1502 (a)(l) (Repl. 1993).”

Show all 16 citing cases →

— Ark. Code Ann. § 6-17-1502(1) — 1 case

Sheets v. Dollarway Sch. Dist., 120 S.W.3d 119 (Ark. Ct. App. 2003). “In that case, Love had worked as a certified teacher for a period of one year and was a probationary teacher as defined by Ark.Code Ann. § 6-17-1502. In July, she learned that she would not be rehired for her position in the upcoming school year.”

— Ark. Code Ann. § 6-17-1502(a) — 2 cases

McGee v. Armorel Pub. Schs., 827 S.W.2d 137 (Ark. 1992). “This appeal requires our interpretation of part of the Teacher Fair Dismissal Act, specifically Ark. Code Ann. § 6-17-1502 (1987). Our jurisdiction is pursuant to Ark.”

Harris v. Altheimer Unified Sch. Dist., 227 S.W.3d 437 (Ark. Ct. App. 2006).

— Ark. Code Ann. § 6-17-1502(a)(1) — 1 case

— Ark. Code Ann. § 6-17-1502(a)(2) — 5 cases

Foreman Sch. Dist. No. 25 v. Steele, 61 S.W.3d 801 (Ark. 2001). “In the 1994 version of the TFDA, Steele was a “probationary teacher,” which is defined in section 6-17-1502(a)(2) as: (2) “Probationary teacher” means a teacher who has not completed three (3) successive years of employment in the school district in which the teacher is…”

Sosebee v. Cnty. Line Sch. Dist., 897 S.W.2d 556 (Ark. 1995). “See § 6-17-1502(a)(2) and (b). On May 1, 1992, her teaching contract was renewed for the 1992-1993 school year.”

Jasper Sch. Dist. No. 1 of Newton Cnty. v. Cooper, 2014 Ark. 390 (Ark. 2014).

— Ark. Code Ann. § 6-17-1502(a)(l) — 2 cases

Barnett v. Mountain View Sch. Dist., 374 S.W.3d 851 (Ark. Ct. App. 2010). “” Ark.Code Ann. § 6-17-1502(a)(l) (Repl.2007).”

Allred v. Arkansas Dep't of Corr. Sch. Dist., 912 S.W.2d 4 (Ark. 1995). “§ 6-17-1502(a)(l). See also Love v. Smackover Sch.”

— Ark. Code Ann. § 6-17-1502(b) — 1 case

— Ark. Code Ann. § 6-17-1502(d)(í) — 1 case

Hollis v. Fayetteville Sch. Dist. No. 1 of Washington Cnty., 2015 Ark. App. 544 (Ark. Ct. App. 2015).

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