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Case 1:10-cv-04852 Document 9-1 Filed 08/13/10 Page 1 of 15

IN THE UNITED STATES DISTRICT COURT


FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION

Chicago Teachers Union, American Federation )


of Teachers, Local No. 1; )
Plaintiff; ) Case No. 10-cv-4852
v. )
Board of Education of the City of Chicago; a body )
politic and corporate, and Mary Richardson ) Judge David H. Coar
Lowery, Norman Bobins, Tariq Butt, Roxanne )
Ward, Peggy Davis, Alberto Carrero, Jr., and Ron )
Huberman, in their official capacities; )
Defendants. )
__________________________________________)

PLAINTIFF’S MEMORANDUM IN SUPPORT OF ITS MOTION FOR


PRELIMINARY INJUNCTION

Introduction

Plaintiff Chicago Teachers Union (“CTU”) brings this motion under Fed. R. Civ. P 65 to

enjoin the individual defendants (the “Officers”), officers of the Board of Education of the City

of Chicago (the “Board”), from firing tenured teachers under color of a resolution of June 15,

2010, in violation of their rights under the Due Process Clause of the Fourteenth Amendment and

Illinois law. The gist of the violation is simple: the Officers are firing qualified tenured teachers

without any hearing. Normally in constitutional law such a hearing would be to determine

“cause.” Here, the Board has gone out of its way to construe discharges not as “for cause”

firings, but as “honorable. But “honorable” or not, the Board is still firing them and cutting off,

without any hearing or further opportunity to be heard, all rights to be considered for retention in

preference to a non-tenured teacher or probationary employee.

But tenured teachers can be fired only “for cause” after a hearing with a panoply of due

process rights. See Cleveland Bd. of Educ. v. Loudermill, 470 U.S. 532 (1985). The Board has

chosen to retain at least some non-tenured employees over these “honorably discharged” tenured
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teachers. Numerous qualified tenured teachers have lost their jobs while non-tenured

probationary teachers continue in their stead, and many more hundreds imminently face the same

fate. This deprives tenured teachers of their property rights in violation of the Due Process

Clause of the Fourteenth Amendment.

In an act of particular hubris, the Board and Officers are ignoring and failing to apply the

retention and reassignment provisions for tenured teachers that exist in Appendix H of the

parties’ collective bargaining agreement, the “Agreement Between the Board of Education of the

City of Chicago and the Chicago Teachers Union, July 1, 2007 to June 30, 2012.” Compl. Ex.

D. Even worse, the Board is ignoring and failing to apply its own regulations governing the

retention and reassignment of such discharged tenured teachers, Board of Education Rule 4-6

“Layoff of Employees and Reductions in Force,” and Board Policy 504.2, “Reassignment and

Layoff of Regularly Certified and Appointed Tenured Teachers”. These Regulations fully

incorporate Appendix H. Furthermore state law requires that in conducting any reduction in

force the Board consider these tenured teachers’ “qualifications, certifications, experience,

performance ratings or evaluations, and [] other factors relating to [their] job performance,”

when conducting any layoffs. 105 ILCS 5/34-18(31).

If the Board refuses to apply these rules used in the past for layoffs, then it must develop

something that provides the same due process right to be considered for retention or

reassignment. On this motion, plaintiff CTU does not seek to enforce either Appendix H or Rule

504.2 directly but instead contends that the Due Process Clause requires some equivalent

procedure for every teacher regardless of circumstances. Furthermore, the school code itself, in

addition to the Due Process Clause, requires the Board to come up with such a procedure to

consider tenured teachers for retention based on their qualifications. 105 ILCS 5/34-18(31). At

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the very least, the Board cannot carry out this reduction in force consistent with the Due Process

Clause without some fair procedure for comparing the qualifications of the tenured teachers with

property rights in their employment with non-tenured teachers who are probationary and have no

such rights, and retaining or reassigning qualified tenured teachers in preference to their non-

tenured counterparts.

Statement of Facts

For purposes of this Motion, plaintiff CTU refers to and incorporates herein all the facts

set out in ¶¶ 16-62 of the Complaint, and the exhibits attached thereto. To summarize the facts

briefly:

By resolution of June 15, 2010, the Officers passed a resolution authorizing defendant

Huberman to “honorably terminate” tenured teachers (Compl. Ex. F). On June 16, 2010,

defendant Huberman began to assert this power and “honorably discharged” teachers who taught

in city-wide programs, including those elite teachers who trained other teachers. Decl. of Jackson

Potter, ¶ 8 (attached hereto as Exhibit 1).

On June 23, 2010, the Board passed a second resolution which gave defendant Huberman

the power to discharge teachers who were under remediation or had negative evaluations

(Compl. Ex. H). As set out at in ¶¶ 43, 53, and 54 of the Complaint, the Board made statements

to the media that presented the entire reduction in force as one involving teachers with

unsatisfactory evaluations. In fact, the majority of tenured teachers who have been laid off are

rated “excellent”,” or at least “superior” or “satisfactory.” Decl. of Jackson Potter, ¶ 18.

On July 22, 2010 the Board announced plans to dismiss 400 teachers in the “Track E”

schools. Compl. ¶¶46-47. The majority of these teachers were tenured. Decl. of Jackson Potter,

¶¶ 9-10. Of the few who were rated “unsatisfactory, many of them were over the age of 40 and

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had significant seniority. Decl. of Jackson Potter, ¶ 16. Plaintiff CTU has been previously

advised that there will be additional dismissals, upwards of 1000, in the schools which begin

classes in September. Decl. of Jackson Potter, ¶ 24. More tenured teachers will be dismissed,

probably in the same ratio as in the Track E schools.

The Board and CTU have a contractual provision for retention and reassignment of

tenured teachers, known as Appendix H, which the Board incorporated into its own rules in

adopting Section 504.2 of the Policy Manual of the City of Chicago (Compl. Ex. D). The Board

has refused to apply these procedures and process to the affected tenured teachers, including

importantly the rights to retention and reassignment for a ten month period with full pay. Decl.

of Jackson Potter, ¶ 23. The Board has taken the position that these displacements are not the

kind of displacements covered under Appendix H and has summarily discharged the tenured

teachers without any procedure for considering their fitness for retention or reassignment in

preference to non-tenured teachers. The Board has refused to place teachers subject to these

displacements into any “reassignment pool” or to provide them any preference over non-tenured

teachers either in retention for other positions or recall. On July 15, 2010, plaintiff CTU filed

grievances under the Agreement that the Board has violated Sections 39, 42-2 and Appendix H

of the Agreement (Compl. Exs. I1-I4). CTU has requested the Board to hold up any further

discharges while the grievances are pending. The Board has made no response.

The Board typically hires approximately 2000 new hires every year to replace “natural”

changes in labor needs arising from retirements and changes in enrollment and programming.

Decl. of Jackson Potter, ¶ 21. The Board also employs thousands of teachers who lack tenure.

Decl. of Jackson Potter, ¶ 22. Throughout the layoffs, the Board has failed to provide any

opportunity to the affected teachers to explain or show that they were qualified to perform the

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work of their non-tenured counterparts who remain employed, or to show that they should be

preferred for recall over other candidates. Decl. of Jackson Potter, ¶ 23.

Argument

Plaintiff CTU brings this motion to require the Board to provide these constitutionally

required hearings and is entitled to the entry of a preliminary injunction. See Ty, Inc. v. Jones

Group, Inc., 237 F.3d 891, 895 (7th Cir. 2001)(providing standards for preliminary injunctions).

I. Plaintiff CTU is likely to succeed on the merits of Counts I and II of its


complaint, arising under 42 U.S.C. § 1983, because the Officers, acting under
color of law, took the property rights in continued employment of tenured
teachers without considering their individual qualifications for retention or
reassignment to either vacant positions or positions filled by non-tenured
teachers that they are qualified to fill, and without providing any meaningful
opportunity to be heard.

The Board’s resolution of June 15, 2010 unlawfully authorizes the outright “honorable”

discharge of tenured teachers as part of a reduction in force, so as to cut off any chance for

retention or reassignment, without any opportunity to be heard and have their qualifications

considered for positions held by non-tenured probationary employees. Such summary

discharges, however “honorable,” take away the property rights of these teachers without due

process and turns over their jobs to probationary employees.

Every single “honorable” dismissal of a tenured teacher in this case—a dismissal without

any opportunity to be considered for retention or reassignment—deprives the teacher of a

property right in violation of that teacher’s right to Due Process. Such a right to due process is

well settled in any kind of discharge of a teacher, whether honorable or dishonorable. See

Loudermill supra, 470 U.S. 532; Bd. of Regents of State Colleges v. Roth, 408 U.S. 564 (1972).

Furthermore, an “honorable” discharge that does not even pretend to be for cause does not even

have a legal basis in the Illinois School Code, even apart from the Fourteenth Amendment.

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Terminations “for cause” require extensive procedures mandated by both the parties’

contract and the Illinois School Code, 105 ILCS 5/34-85 and 105 ILCS 5/24A. Any other

termination of tenured employment must occur under the proscriptions of 105 ILCS 5/34-18(31),

but an “honorable” discharge that cuts off a tenured teacher’s due process right to be considered

for other positions is an unknown procedure under section of the Illinois School Code. That

section, 5/34-18(31), contemplates that in a reduction in force the qualifications of tenured

teachers will be considered, and not cut off arbitrarily by acts like the resolution of June 15,

2010. The Board officers cannot “honorably” discharge – or discharge (as opposed to layoff) at

all, except for cause pursuant to 105 ILCS 5/34-85.

Of course if a reduction in force is absolutely required, a tenured teacher can be “laid

off,” as opposed to “discharged,” so long as their property right of tenured employment, which

includes the right to preferential retention over non-tenured teachers, is respected. Mims v. Bd.

of Ed. of the City of Chicago, 523 F.2d 711, 715 (7th Cir. 1975); Shegog v. Bd. of Ed. of the City

of Chicago, 194 F.3d 836, 837 (7th Cir. 1999). What is dishonorable about the Board’s use of

these “honorable” discharges is that it is preventing tenured teachers from presenting the case

that they should be retained over their probationary counterparts, in contradiction of the

longstanding Illinois rule giving qualified tenured teachers priority for retention over non-

tenured teachers. See Henkenson v. Board of Education, 15 Ill. App. 3d 440 (1957); Catron v.

Board of Education 126 Ill. App. 3d 693 (1984). In Catron the appellate court stated:

If the tenured teacher is legally qualified for a position of a non tenured teacher,
or of a tenured teacher with less seniority, she may be reassigned to the latter’s
position. The policy reflected in the statute is a preference for qualified tenured
teachers over qualified non tenured teachers…

The failure to give any preference for a tenured teacher is the gist of the Board’s denial of due

process – it is the modus operandi for taking away their property rights.

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Most of the fired tenured teachers do have “honorable” records, and have been evaluated

as “excellent” teachers. Contrary to some of the defendants’ public statements, very few of these

teachers have negative evaluations. For example, CTU is not aware of even a single teacher out

of all the literacy coaches, special education instructors and others in the discharge of “city wide”

teachers who has a negative evaluation. These particular teachers are the elite of Chicago

teachers, yet they have been fired while probationary employees have been retained.

But because of the importance of the tenure right, the Supreme Court has long held that a

school board may not extinguish that right without due process. As the Court has stated:

The right to due process “is conferred, not by legislative grace, but by
constitutional guarantee. While the legislature may elect not to confer a property
interest in [public] employment, it may not constitutionally authorized the
deprivation of such an interest, once conferred, without appropriate procedural
safeguards.” Arnett v. Kennedy 415 U.S 134, 167 (1974).”
--Loudermill, 470 U.S. at 541.

As Loudermill explains, the process “due” cannot be dictated by state law itself, but only

by the Fourteenth Amendment. “In short, once it is determined that the Due Process Clause

applies, the question remains what process is due. The answer to that question is not to be found

in the… [state’s own] statute.” Id. (internal quotes and citations omitted).

Here the Board Officers are not even providing the process called for by Illinois law,

much less that of the Constitution, hence the violation is clear as is plaintiffs likelihood in

proving such violation. The Board is simply discharging qualified tenured teachers without even

a smidgen of a claim that most or all of these teachers are not meeting expectations. While the

Board has claimed the right to fire teachers who have negative evaluations—and very few of the

fired teachers have them—it cannot do so by fiat. Illinois law states that any for cause

termination requires a hearing, even in a reduction in force. 105 ILCS 5/34-85; 105 ILCS 5/34-

254A; see also, Service Employees International Union Local 11 v. Bd. of Education, School

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Dist. U-46, 1981 U.S. Dist. LEXIS 14148 (N.D. Ill)(attached as Exhibit 2). The Board and its

Officers cannot suspend Illinois law and start firing teachers “for cause” with no hearing. And

even if Illinois law did not so require, the Constitution does.

The Officers have conducted no hearings. The discharged teachers have been given no

opportunity to be heard why they should be retained. Even the few teachers with negative

evaluations never had a chance to explain why the evaluation, which is necessarily very

subjective, was undeserved. With eyes and ears shut, the Board Officers have summarily fired

them. Furthermore, as to the other teachers – the majority - there is not even a hint of poor

performance, but they have been fired too, with no chance to explain why they should be

preferred over non tenured teachers. Such summary discharges, whether “honorable” or “for

cause,” simply cannot be undertaken as a means for a reduction in force. See Mims, 523 F.2d at

715; SEIU Loc. No. 11, 1981 US Dist LEXIS 14148 (ND Ill 1981). As the district court stated

in the SEIU Local 11 case: “(T)he district cannot use considerations of economy as an excuse to

get rid of undesirable employees, thereby circumventing the ‘proper cause’ hearing…” SEIU

Local No. 11 at *11. Likewise, the June 15, 2010 resolution authorizing the outright discharge of

teachers is in violation of the requirements for permanent discharges.

Aside from the use of disguised “for cause” terminations, all tenured teachers are

entitled to an opportunity to show that they can perform work that might otherwise go to non

tenured probationary employees. Id. at *15. That is also the type of proceeding the Illinois

School Code specifically authorizes the Board to undertake in 105 ILCS 5/34-18(31)—that is, to

determine which teachers should be laid off based on their “qualifications, certifications,

experience…and …job performance” in comparison with other teachers. The above cited

provision does not authorize the Board to fire anyone. It does not contemplate terminations for

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cause. Even a single teacher with a negative evaluation may be more qualified than a

probationary employee hired at a bargain basement price right off the street, and may have more

“qualifications, certifications, experience” than any probationary employee.

And it is here that one of the primary functions of the Due Process Clause is most

important: the tenured teachers must be allowed meaningful opportunity to be heard to correct

any factual error. See Mathews v. Eldridge, 424 U.S. 319 (1976); Goldberg v. Kelly¸397 U.S.

254, 266 (1970)(“’the possibility of error or irritable misjudgment [is] too great, to allow

termination of aid without giving the recipient a chance…to be fully informed of the case against

him so that he may contest its basis and produce evidence in rebuttal.’” (citing the District

Court); see also, Smith v. Illinois Sec’y. of State, 2002 U.S. Dist. LEXIS 1318 (N.D. Ill.)(due

process claim to contest error related to identity theft), attached as Exhibit 3. These teachers

must have the opportunity to correct any mistake that could have led to erroneous evaluations, or

mistaken beliefs about their “qualifications, certifications, [and] experience.”

The reason that the June 23, 2010 resolution targeting such teachers for discharge is

unlawful is that the Board has no statutory power to fire them either, apart from its power under

105 ILCS 5/34-18(31). Nor can one prejudge their qualifications, with or without such a

negative evaluation in the record. A single bad evaluation may come from a principal’s pique

with an outspoken employee, who is not in any way a bad teacher. There is not an iota of

authority under 105 ILCS 5/34-18(31) or 105 ILCS 5/34-85 and 105 ILCS 5/24A for the Officers

to make such summary discharges, so as to avoid looking at their credentials for retention.

Even in the absence of 105 ILCS 5/34-18(31), such a consideration is constitutionally

mandated when considering retention of a tenured over a non-tenured teacher. Again, the case of

SEIU Local No. 11 is instructive. In that case, the district court held that even non teacher

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employees laid off by a school board were entitled to show they could perform the work of

temporary employees who lacked the same contractual rights. The court relied on the Seventh

Circuit’s crucial language in Mims, supra, stating:

Similarly, in Mims v. Board of Education of Chicago, 523 F.2d 711 (7th Cir
1975)… [a] hearing was required not to examined the propriety of the layoff but
to determine the fitness of those particular employees for temporary positions.

--SEIU Local No. 11 at *13-14.

In Mims, a suit against the Chicago Board of Education, the Seventh Circuit announced

the rule that applies directly to this case, stating:

‘We recognize that a layoff is less drastic than a discharge and may not require all
the procedural safeguards necessary before termination through discharge… But
we think that plaintiffs had a property interest in their continued active
employment…. Plaintiffs at least were entitled to an opportunity to attempt to
demonstrate that they were capable of performing the work assigned to the six
temporary employees… the issue of whether plaintiffs could perform the work,
unlike that of the need to cut back due to loss of federal funding, was one of
which plaintiffs might have been able to contribute information and valid
persuasion, possibly resulting in a temporary continuation of employment… The
defendant board … failed to provide plaintiffs with the opportunity for such a
review that due process required.”

Mims, 523 F2d at 71.

That statement of the Seventh Circuit is directly applicable to the situation at hand. The

only difference is that in this action, the tenured teachers are seeking consideration not for

“temporary” but permanent employment. They seek placement in teaching positions which non-

tenured teachers have or in positions which will continue to open up throughout the coming year.

As set out in Mims and SEIU Local 11, even if the Illinois School Code did not require it, the

Board officers have violated the constitutional rights of tenured teachers to provide such a

procedure to be considered for retention and reassignment.

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But the Illinois School Code does require it. Under 105 ILCS 5/34-18(31), the Officers

are expected to do exactly what the Seventh Circuit in Mims and the district court in SEIU Local

11 held that they are constitutionally obligated to do. While the Board is expressly given the

power to conduct layoffs in subparagraph (31), the exercise of that power necessarily requires

individual determinations as to which teacher has more “qualifications, certifications,

experience” than another. Specifically, 105 ILCS 5/34-18(31) authorizes the Board:

To promulgate rules establishing procedures governing the layoff or reduction in


force of employees and the recall of such employees including but not limited to
criteria for such layoffs, reductions in force or recall rights of such employees and
the weight to be given to any particular criterion. Such criteria shall take into
account factors including, but not be limited to, qualification, certifications,
experience, performance rating or evaluation and other factors relating to any
employee’s job performance.
(emphasis supplied)

In other words, 105 ILCS 5/34-18(3) authorizes the Board and its Officers to do what

they would be constitutionally obligated to do anyway. And as the Seventh Circuit stated in

Mims, the tenured must have an opportunity to be heard and be considered for retention, since

the affected teacher of course has a great deal of information to contribute to a decision on

retention or reassignment – and a right to protect his or her property interest in tenure.

Actually, if the Board and its Officers were willing to use it, the Board does have a

constitutionally adequate procedure – namely, the retention and reassignment provisions for

tenured teachers in Appendix H of the parties’ collective bargaining agreement. The same

reassignment procedure is set out in Section 504.2 of the Board’s Policy Manual. Instead, in bad

faith, the Officers have taken the position that those retention and reassignment procedures used

in the past do not apply to most of the tenured teachers now being dismissed. Plaintiff CTU

emphatically disagrees with this position and is vigorously grieving the issue.

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Even if the Board were to prevail in arguing that the particular procedure in Appendix H

or in Section 504.2 of the Policy Manual does not apply to this particular type of layoff, the

Board is still required under the Fourteenth Amendment to have a procedure that is at least as

protective of the tenure rights of teachers. It is irrelevant whether the Board can come up with

an interpretation of Appendix H or Section 504.2 of the Policy Manual to get out of those

specific procedures – it still has an obligation under the Due Process Clause to allow laid off

tenured teachers to show they are qualified to fill positions being filled or to be filled by non

tenured teachers.

II. Plaintiff’s tenured teacher members face irreparable harm in the absence of
the preliminary injunction.

The tenured teachers who have been or will be discharged without cause under the

resolution of June 15 2010, have suffered or will suffer irreparable injury. First, there is

irreparable injury simply from the violation of their Due Process rights, as set forth in Mims, to

be considered for retention over non-tenured teachers. To quote the Seventh Circuit on this type

of injury: “Submission to a fatally biased decision-making process is in itself a constitutional

injury sufficient to warrant injunctive relief.” United Church of the Medical Center v. Medical

Center Commission, 689 F.2d 693, 701 (7th Cir. 1982).

For tenured teachers to be discharged by fiat of the Board, with no hearing—while the

Officers imply to the media that only “bad” teachers will be dismissed—is the kind of travesty

that constitutes irreparable injury by itself. Furthermore, the repetition of the injury is

significant: “The existence of a continuing constitutional violation constitutes proof of

irreparable harm, and its remedy certainly would serve the public interest (emphasis supplied)”

Preston v. Thompson 589 F.2d 300, 303, fn. 3 (7th Cir. 1978). See also Wright and Miller,

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Federal Practice and Procedure, Civil, Section 2948, at p. 440 (“When… a constitutional right is

involved, most courts hold that no further showing of irreparable injury is necessary”).

Second, the sheer number of affected teachers creates a situation difficult to remedy or

repair if no preliminary injunction is issued. The legal remedy will be inadequate. In even a few

months it will be hard to determine what positions the discharged tenured teachers should or

would have been placed in if they had been given their due process rights and considered for

retention over non tenured teachers now. For example, a music teacher who qualifies for a

position as a music teacher at School “A” may not have the chance to fill that position again—

another tenured teacher may be in the spot by then, and the relief might not be practicable. In a

case involving up to 1,500 teachers there are just too many moving parts to assume any legal

remedy can be adequate even a few months from now.

Third, damages are inadequate if reinstatement is impractical—as it may well be.

Reinstatement may come in the middle of a school year, and it may disrupt the continuity of the

academic year. Indeed, such belated reinstatement may create problems for the reinstated

teacher. If the academic performance of the students is adversely affected by an abrupt change

of teachers, then the tenured teacher who is reinstated may suffer a negative evaluation or have

his own professional reputation suffer.

Finally, as indicated, the manner of the discharge has put all the tenured teachers—but

especially those with good evaluations—in a false light, if not outright defamed them. The

officers have falsely purported or led the media to believe that only teachers with

“unsatisfactory” evaluations are being discharged. In Virgie Lee Valley et al. v. Rapides Paris

School Board, 118 F.3d 1047 (5th Cir 1997), a school superintendant sought to be reinstated

when she had been denied due process by the school board. The Fifth Circuit, relying on the

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Seventh Circuit’s decision in United Church of the Medical Center stated at page 1056: “[w]e

find the threat of injury to [the superintendant’s] reputation and her ability to procure comparable

employment, not to mention the egregious and constitutionally infirm hearing she was subject to,

sufficient to satisfy irreparable injury.”

III. The balance of hardships favors entering the preliminary injunction.

The Officers will suffer no legally cognizable injury if they are required to use a

procedure that retains qualified tenured teachers over non-tenured teachers when making layoffs.

Indeed, that is the very purpose of tenure in the Illinois School Code. As a matter of law, the

Officers cannot suffer any harm or hardship from retaining more qualified or equally qualified

tenured teachers except possibly a financial harm from the lower salaries non-tenured teachers

command. But under the Illinois School Code, in particular 105 ILCS 5/34-18(31), cost or salary

is not a legitimate consideration as to which teacher should be retained. Indeed, considerations

of cost favor entry of injunctive relief. If the tenured teachers are denied reinstatement, they

have claims to damages against the officers, while non-tenured teachers would have none.

Finally, if the Officers wish to fire teachers with negative evaluations (and most of the

discharged tenure teachers have good evaluations), the Officers have an appropriate process for

doing so, 105 ILCS 5/24A. There is no legally cognizable “hardship” for the officers if they

have to follow simple due process to reach the same result.

IV. The public interest will be served by issuing the injunction and ensuring that
qualified, tenured teachers are not displaced by their untenured,
inexperienced counterparts.

The public and certainly the students are better off if the tenure provisions of the Illinois

School Code are respected. Nothing could do more to deter young people from entering the

teaching profession than a martial-law type action to make tenure protection null and void. If the

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tenure system set up by the Illinois School Code is to be scrapped, such a decision should be

taken by the legislature and not these un-elected officials. Finally, students are better served by

having the right teachers in place now without the uncertainty as to who will teach them

remaining for months to come.

Conclusion

For the above reasons, CTU respectfully requests this Court grant its motion for a

preliminary injunction.

Dated: August 13, 2010 Respectfully submitted,

s/ Michael P. Persoon

Michael P. Persoon (mpersoon@dsgchicago.com)


Thomas H. Geoghegan (admin@dsgchicago.com)
Jorge Sanchez (attysanchez@gmail.com)
Despres, Schwartz & Geoghegan, Ltd.
77 W. Washington St., Ste. 711
Chicago, Illinois 60602
Ph: (312) 372-2511
Fax: (312) 372-7391

Robin B. Potter (robin@potterlaw.org)


Robin Potter & Associates P.C.
111 East Wacker Drive
Suite 2600
Chicago, Illinois 60601
Ph: (312) 861-1800
Fax: (312) 861-3009

Robert E. Bloch (efile@dbb-law.com)


Omar Josef Shehabi (oshehabi@dbb-law.com)
Dowd, Bloch & Bennett
8 S. Michigan Avenue
Suite 1900
Chicago, Illinois 60603
Ph: (312) 372-1361
Fax: (312) 372-6599

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