The Steel Valley School District in Pennsylvania pays its teachers pursuant to a salary scale based on their education and years of experience. When the District hired Patrick Connelly, he had had nine years of teaching experience — in Maryland. But working in Maryland is practically the same as not working at all, according to Steel Valley policies: The District credited him with only one year when calculating his starting salary. Other new teachers with similar experience acquired within Pennsylvania — but outside Steel Valley — received at least partial credit for each year they had taught.
This week, the Third Circuit Court of Appeals concluded that the District’s pay policy did not violate the right to interstate travel under the Privileges and Immunities Clause.
Connelly's lawsuit against the District alleged that Steel Valley's salary scale impaired his right to interstate travel and should be subject to strict scrutiny. The appellate court disagreed, finding that the scenario warranted rational basis review.
Because Connelly didn't argue that Steel Valley's classification affected a suspect class, strict scrutiny would only apply if it burdened a fundamental right. Here, that determination hinged on whether the District's experience-based classifications penalized Connelly's fundamental right to be treated like other Pennsylvania citizens.
The Third Circuit, however, says that strict scrutiny only applies in such situations when the state creates "distinctions between newcomers and longer term residents." That wasn't the case here. Instead, the District's classification was based on the location of teaching experience, not the duration of residency.
The appellate court offered the following example to make its point:
Consider a teacher who, for his whole life, has lived in Gettysburg, Pennsylvania, but spent the first decade of his teaching career working at a public school in Frederick, Maryland. If that teacher were to leave the Frederick school and take a position with Steel Valley, he presumably would receive the same credit for his Maryland teaching experience that Connelly received. Thus, only the teacher's lack of Pennsylvania teaching experience -- not his residency -- would adversely affect his starting pay.
After deciding to apply rational basis review, the Third Circuit reasoned that Steel Valley's system was sufficiently tied to the legitimate state purpose of promoting an efficient and effective public school system. The court found that it was reasonable to assume that teachers with more experience working within Pennsylvania schools have greater familiarity with state policies and goals, as well as what methods are most successful in achieving the goals the state has established. Therefore, a school district may rationally place a premium on teachers who have more experience working within the Pennsylvania school system in order to achieve the legitimate goal of an efficient and effective public education system.
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