Goodrich v. Newport News Sch. Bd., 743 F.2d 225 (4th Cir. 1984). · Go Syfert
Goodrich v. Newport News Sch. Bd., 743 F.2d 225 (4th Cir. 1984). Cases Citing This Book View Copy Cite
48 citation events (34 in the last 25 years) across 21 distinct courts.
Strongest positive: Emmett Hickam v. Chesterfield County School Board, et al. (vaed, 2026-06-17)
Treatment trajectory · 1984 → 2026 · click a year to view as-of
1984 2005 2026
Top citers, strongest first. 13 distinct citers. How cited ↗
examined Cited as authority (verbatim quote) Emmett Hickam v. Chesterfield County School Board, et al. (3×) also: Cited as authority (rule)
E.D. Va. · 2026 · quote attribution · 1 verbatim quote · confidence high
when the minimal due process requirements of notice and hearing have been met, a claim that an agency's policies or regulations have not been adhered to does not sustain an action for redress of procedural due process violations.
examined Cited as authority (quoted) Grant v. Albemarle County
W.D. Va. · 2021 · quote attribution · 1 verbatim quote · confidence low
when the minimal due process requirements of notice and hearing have been met, a claim that an agency's policies or regulations have not been adhered to does not sustain an action for redress of procedural due process violations.
discussed Cited as authority (quoted) Myers v. City of Charleston
S.D.W. Va · 2020 · quote attribution · 1 verbatim quote · confidence low
a claim that an agency's policies or regulations have not been adhered to does not sustain an action for redress of procedural due process violations
discussed Cited as authority (rule) MATHIS v. CASWELL COUNTY SCHOOL BOARD OF EDUCATION (2×)
M.D.N.C. · 2021 · confidence medium
Id. at 226.
discussed Cited as authority (rule) Rone Ex Rel. Roseboro v. Winston-Salem/Forsyth County Board of Education
N.C. Ct. App. · 2010 · confidence medium
In making this determination, the superior court relied upon Goodrich v. Newport News School Bd., 743 F.2d 225 (4th Cir. 1984) and In re Alexander, supra. In Goodrich, the Court held that, for termination of a public school teacher, “[m]inimal procedural due process required . . . adequate notice, a specification of the charges against [the teacher], an opportunity to confront the witnesses against [the teacher], and an opportunity to be heard in [the teacher’s] own defense.” 743 F.2d at 227 (internal quotations and citation omitted).
cited Cited as authority (rule) J.S. Ex Rel. Duck v. Isle of Wight County School Board
E.D. Va. · 2005 · confidence medium
Schs., 263 F.Supp.2d 1043, 1055 (E.D.Va.2003)(quoting Goodrich, 743 F.2d at 226-27).
discussed Cited as authority (rule) Echtenkamp v. Loudon County Public Schools (2×)
E.D. Va. · 2003 · confidence medium
Id. at 226.
discussed Cited as authority (rule) Williams v. Charlottesville School Board
W.D. Va. · 1996 · signal: cf. · confidence medium
Cf. Goodrich v. Newport News School Board, 743 F.2d 225, 226 (4th Cir.1984) (stating that "[wjhen the minimal due process requirements of notice and hearing have been met, a claim that an agency’s policies or regulations have not been adhered to does not sustain an action for redress of procedural due process”) (citations omitted).
discussed Cited as authority (rule) Eftekhara v. Illinois Department of Children & Family Services
N.D. Ill. · 1987 · confidence medium
Illinois thus provides plaintiff with a post deprivation remedy sufficient to satisfy any constitutional requirements. 4 *529 The court therefore concludes plaintiff has adequate state remedies available to her. 5 “The enforcement of state regulations is to be done through the state court system and not in an action under § 1983.” Goodrich v. Newport News School Board, 743 F.2d 225, 227 (4th Cir.1984).
discussed Cited as authority (rule) Pleasant View Elementary School PTA v. Group 1
4th Cir. · 1985 · confidence medium
I The district court, holding that the defendants had complied with the minimal elements of due process, notice and an opportunity for a hearing, dismissed plaintiffs’ procedural due process claim on the basis of Goodrich v. Newport News School Board, 743 F.2d 225, 227 (4th Cir.1984).
discussed Cited as authority (rule) Pleasant View Elementary School Pta and Myra Freer and Wilbur H. Friedman v. Group 1 Former Members of the Board of Education of Montgomery County, Maryland: Carole F. Wallace and Eleanor D. Zappone and Joseph R. Barse and Dr. J. Edward Andrews, Former Superintendent, Montgomery County Public Schools, and Elizabeth W. Spencer and Suzanne Peyser, Dr. Marian L. Greenblatt and Blair G. Ewing and Group 2 Current Members of the Board of Education of Montgomery County: Suzanne Peyser, Dr. Marian L. Greenblatt, Blair G. Ewing, Dr. James Cronin, Marilyn Praisner, Odessa Shannon, Dr. Robery Shoenberg, and Dr. Wilmer Cody, Current Superintendent, Montgomery County Public Schools and Group 3 Members of Montgomery County Council and Montgomery County Executive: Rose Crenca, Scott Fosler, Esther Gelman, Michael Gudis, William Hanna, Neal Potter, David Scull and Charles W. Gilchrist, Montgomery County Executive and Group 4 Former Members of Maryland State Board of Education: G. George Asaki, May T. Bolt, Mary Elizabeth Ellis, Verna T. Fletcher, Joanne T. Goldsmith, Rosetta G. Kerr, Albertine T. Lancaster, Frederick Schoenbrodt, Dr. David W. Hornbeck, State Superintendent of Schools and Lawrence A. Miller and Group 5 Current Members of Maryland State Board of Education: G. George Asaki, May T. Bolt, Mary Elizabeth Ellis, Verna T. Fletcher, Joanne T. Goldsmith, Rosetta G. Kerr, Albertine T. Lancaster, Frederick Schoenbrodt, Dr. David W. Hornbeck and Herbert Fishpaw, Pleasant View Elementary School Pta and Myra Freer and Wilbur H. Friedman v. Group 1 Former Members of the Board of Education of Montgomery County, Maryland: Carole F. Wallace and Eleanor D. Zappone and Joseph R. Barse and Dr. J. Edward Andrews, Former Superintendent, Montgomery County Public Schools, and Elizabeth W. Spencer and Suzanne Peyser, Dr. Marian L. Greenblatt and Blair G. Ewing and Group 2 Current Members of the Board of Education of Montgomery County: Suzanne Peyser, Dr. Marian L. Greenblatt, Blair G. Ewing, Dr. James Cronin, Marilyn Praisner, Odessa Shannon, Dr. Robery Shoenberg, and Dr. Wilmer Cody, Current Superintendent, Montgomery County Public Schools and Group 3 Members of Montgomery County Council and Montgomery County Executive: Rose Crenca, Scott Fosler, Esther Gelman, Michael Gudis, William Hanna, Neal Potter, David Scull and Charles W. Gilchrist, Montgomery County Executive and Group 4 Former Members of Maryland State Board of Education: G. George Asaki, May T. Bolt, Mary Elizabeth Ellis, Verna T. Fletcher, Joanne T. Goldsmith, Rosetta G. Kerr, Albertine T. Lancaster, Frederick Schoenbrodt, Dr. David W. Hornbeck, State Superintendent of Schools and Lawrence A. Miller and Group 5 Current Members of Maryland State Board of Education: G. George Asaki, May T. Bolt, Mary Elizabeth Ellis, Verna T. Fletcher, Joanne T. Goldsmith, Rosetta G. Kerr, Albertine T. Lancaster, Frederick Schoenbrodt, Dr. David W. Hornbeck and Herbert Fishpaw
4th Cir. · 1985 · confidence medium
Plaintiffs now appeal from the dismissal of each of their causes of action by the district court. 5 * The district court, holding that the defendants had complied with the minimal elements of due process, notice and an opportunity for a hearing, dismissed plaintiffs' procedural due process claim on the basis of Goodrich v. Newport News School Board, 743 F.2d 225, 227 (4th Cir.1984).
discussed Cited "see, e.g." Vanover v. Hantman
D.D.C. · 1999 · signal: see also · confidence low
See Stone v. F.D.I.C., 179 F.3d 1368, 1377 (Fed.Cir.1999) (“the Due Process Clause only provides the minimum process to which a public employee is entitled”); see also Goodrich v. Newport News School Bd., 743 F.2d 225 , 227 (4th Cir.1984) (“When the minimal due process requirements of notice and hearing have been met, a claim that an agency’s policies or regulations have not been adhered to does not sustain an action for redress of procedural due process violations”); Atencio v. Bd. of Educ. of Penasco Independent School Dist.
discussed Cited "see, e.g." Mcdarby v. Dinkins
2d Cir. · 1990 · signal: see also · confidence low
See Basciano, 605 F.2d at 609-11 ; see also Winston, 759 F.2d at 250 (citing Basciano ). 19 As was said in Goodrich v. Newport News School Bd., 743 F.2d 225 (4th Cir.1984): 20 When the minimal due process requirements of notice and hearing have been met, a claim that an agency's policies or regulations have not been adhered to does not sustain an action for redress of procedural due process violations.
Retrieving the full opinion text from the archive…
Sarah M. Goodrich
v.
Newport News School Board, a Corporate Body and Chairman Erwin M. Alexander, William E. Beamer, Elizabeth Crutchfield, Svein J. Lassen, Rev. G. Wesley Raney, III and Roy D. Stallings, Jr., Individually and in Their Official Capacities as Members of the Newport News School Board and Woodrow Holmes and James West, Individually and in Their Capacities as Members of the Newport News School Board and Oliver C. Greenwood, Individually and in His Official Capacity as Division Superintendent of the Newport News Public School System
83-1740.
Court of Appeals for the Fourth Circuit.
Sep 13, 1984.
743 F.2d 225

743 F.2d 225

20 Ed. Law Rep. 48

Sarah M. GOODRICH, Appellant,
v.
NEWPORT NEWS SCHOOL BOARD, a corporate body and Chairman
Erwin M. Alexander, William E. Beamer, Elizabeth
Crutchfield, Svein J. Lassen, Rev. G. Wesley Raney, III and
Roy D. Stallings, Jr., individually and in their official
capacities as members of the Newport News School Board and
Woodrow Holmes and James West, individually and in their
capacities as members of the Newport News School Board and
Oliver C. Greenwood, individually and in his official
capacity as division superintendent of the Newport News
public school system, Appellees.

No. 83-1740.

United States Court of Appeals,
Fourth Circuit.

Argued Aug. 7, 1984.
Decided Sept. 13, 1984.

Beverly A. Burton, Richmond, Va. (Sa'ad El-Amin, Sa'ad El-Amin & Associates, Richmond, Va., on brief), for appellant.

F. Nash Bilisoly, Norfolk, Va. (Joseph A. Gawrys, Vandeventer, Black, Meredith & Martin, Norfolk, Va., Leonard A. Wallin, City Atty., Newport News, Va., on brief), for appellees.

Before RUSSELL, HALL and CHAPMAN, Circuit Judges.

K.K. HALL, Circuit Judge:

[*~225]1

Sarah M. Goodrich appeals from an order of the district court granting summary judgment for defendants in her action brought pursuant to 42 U.S.C. Secs. 1981 and 1983. We affirm.

I.

2

Goodrich was a tenured school teacher employed under continuing contract status by the Newport News, Virginia, School Board ("School Board") for the 1980-81 school year. During that time she was evaluated by her principal, Alfreda L. Alexander, as was required by the School Board's evaluation policy. Alexander held two interim conferences with Goodrich. Following the second conference Alexander advised Goodrich, on February 13, 1981, that she was recommending Goodrich's dismissal from her teaching position for performance below acceptable standards. On the same day, Goodrich was notified in writing that she was being suspended from her teaching position as a result of Alexander's recommendation of dismissal. Goodrich later received a letter from Oliver C. Greenwood, the division superintendent of the Newport News Public School System, informing her that her evaluation forms and other related documents had been reviewed, and that the school system authorities reviewing them concurred in Alexander's recommendation.

3

An informal conference with Greenwood, in which Goodrich and her attorney participated, was held on March 24, 1981, to discuss Alexander's dismissal recommendation. After the conference, Greenwood sent Goodrich a letter advising her that he was recommending she be dismissed from her position as a classroom teacher.

4

Goodrich then requested a hearing before a three-member fact-finding panel to consider the matter. The panel concluded that Goodrich had not received the requisite number of interim conferences under the School Board's written evaluation procedures and, in a 2-1 decision, recommended that she be reinstated in the teaching position under a probationary contract. The School Board, however, after reviewing the fact-finding panel's recommendation, voted to dismiss Goodrich from her teaching position effective August 13, 1981.

5

Goodrich subsequently filed this civil rights action under 42 U.S.C. Secs. 1981 and 1983, alleging that she was terminated in violation of her procedural due process rights, and also asserting a pendent state law claim of breach of contract. The basis of her due process claim was that she was given only two interim conferences rather than the three required by the School Board's evaluation procedure. The district court granted summary judgment for the defendants with respect to Goodrich's due process claim, and dismissed Goodrich's pendent state claim for lack of subject matter jurisdiction. Goodrich appeals.

II.

6

On appeal, Goodrich contends that the district court erred in its determination that the fourteenth amendment does not require a local school board to adhere to its own guidelines as long as minimum due process is accorded. We disagree.

7

In Grimes v. Nottoway County School Board, 462 F.2d 650 (4th Cir.), cert. denied, 409 U.S. 1008, 93 S.Ct. 439, 34 L.Ed.2d 300 (1972), we addressed the minimum procedural due process requirements in cases involving the termination of a public school teacher. "[M]inimal procedural due process required ... adequate notice, a specification of the charges against her, an opportunity to confront the witnesses against her and an opportunity to be heard in her own defense." Id. at 653 (citation omitted). The evidence shows that Goodrich was afforded minimal procedural due process.

[*225]8

When the minimal due process requirements of notice and hearing have been met, a claim that an agency's policies or regulations have not been adhered to does not sustain an action for redress of procedural due process violations. Atencio v. Board of Education of Penasco Independent School District, 658 F.2d 774 (10th Cir.1981); Bates v. Sponberg, 547 F.2d 325 (6th Cir.1976).

9

In Atencio, supra, a case strikingly similar to the present appeal, plaintiff was discharged from his position as superintendent of a school district without being given the two conferences mandated by state law and Board of Education regulations. Atencio had been given notice and granted a full hearing. He did not claim that the notice and hearing were constitutionally defective, but only that he was entitled to the two conferences required by state law and the Board's policy. The Tenth Circuit stated that it was possible that Atencio's rights under the state statute and the Board regulation regarding conferences had been violated, but the Court concluded:

10

[T]here is no federal constitutional right to the conference procedures. The questions whether the allegations contained in the notice of discharge involve unsatisfactory work performance requiring conferences prior to discharge and, if so, whether Atencio in fact was accorded the requisite conferences involve considerations of fact and of state, not federal, law. There is no constitutional violation unless Atencio was denied a fair forum for protecting his state rights.

11

Id. at 779-80.

12

In this case, Goodrich was afforded her procedural due process rights to notice and a hearing. Procedural due process does not require that Goodrich be given three evaluations before being notified of her termination. She received adequate notice, a specification of the charges against her, and a hearing at which she was able to present her defense. That is all she is entitled to under the federal Constitution. Grimes v. Nottoway County School Board, supra. The enforcement of state regulations, such as those existing in this case, is to be done through the state court system and not in an action under 42 U.S.C. Secs. 1981 and 1983, where no federal constitutional guarantees have been violated.

13

Finding no error in the proceedings below, we affirm the judgment of the district court.

[*~226]14

AFFIRMED.