Employment Contract – Procedural Due Process

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7^th Circuit Court of Appeals

Case Name: Quintella Bounds v. Country Club Hills School District 160

Case No.: 22-2032

Officials: Rovner, St. Eve, and Kirsch, Circuit Judges.

Focus: Employment Contract – Procedural Due Process

Dr. Bounds, formerly employed as an administrator for the Country Club Hills School District in suburban Chicago, has sued the School District contending that the School District deprived her of due process by posting her position as vacant after she did not timely sign a written employment contract for the forthcoming school year. The district court entered summary judgment in favor of the School District on this claim and relinquished jurisdiction over a companion state-law claim. Bounds v. Country Club Hills Sch. Dist. 160, 2022 WL 1487332 (N.D. Ill. May 11, 2022).

Although the district court denied a motion to dismiss this claim, the court eventually granted summary judgment in favor of the defendants, reasoning that because Bounds had never signed the written employment contract presented to her and had not otherwise entered into an oral agreement with the School District for her continued employment, she lacked the property interest that was necessary to support a procedural due process claim.

Affirmed.

Decided 04/10/23

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