Law School Case Brief
McNaughton v. Charleston Charter Sch. for Math & Sci., Inc. - 411 S.C. 249, 768 S.E.2d 389 (2015)
In ruling on a motion for a directed verdict or judgment notwithstanding the verdict, a trial court must view the evidence and the inferences that reasonably can be drawn therefrom in the light most favorable to the party opposing the motions. The trial court must deny either motion when the evidence yields more than one inference or its inference is in doubt. An appellate court will reverse the trial court only when there is no evidence to support the trial court's ruling. A jury's factual finding will not be disturbed unless a review of the record discloses that there is no evidence which reasonably supports the jury's findings.
In late 2008, plaintiff Cynthia McNaughton, who was in her 50s at the time, was accepted into the South Carolina Department of Education's Program of Alternative Certification for Educators (PACE program), which enables individuals who had earned a college degree but had not completed a traditional teacher preparation program, to become certified South Carolina public school teachers. In August 2010, defendant Charleston Charter School for Math and Science’s (Charleston) principal hired McNaughton to teach 6th, 7th, and 8th grade art, along with the yearbook class. When she was hired, Charleston knew that McNaughton was participating in the PACE program, and that her completion of the program was contingent upon her fulfillment of further requirements, including the completion of an induction teaching year. McNaughton signed an employment agreement, which stated that McNaughton "agree[d] to be a full-time teacher at Charleston Charter School for Math and Science for the school year 2010-2011." The employment agreement further stated that it was "contingent on funding and enrollment" (the contingency clause). A "Wage Payment Notice" indicated that Charleston would pay McNaughton a yearly salary of $34,040. However, on December 1, 2010 in the middle of the school year, the principal informed McNaughton that Charleston was terminating her employment. The principal told McNaughton that Charleston needed to use the funds designated for McNaughton's salary to hire and pay a new math teacher because some of the students had performed poorly on a recent math achievement test. At trial, the principal testified in detail about the Charleston''s budget and funding decisions, but conceded that when McNaughton was terminated, there was funding available to pay McNaughton's salary, but that the funding was instead used to hire and pay the new math teacher. McNaughton filed a complaint against Charleston, alleging four causes of action: wrongful termination/breach of contract, breach of contract accompanied by a fraudulent act, third party beneficiary breach of contract, and grossly negligent supervision. In her complaint, McNaughton requested actual and special damages, costs, and attorney's fees pursuant to S.C. Code Ann. § 15-77-300 (2005). The trial court granted Charleston's motion on the breach of contract accompanied by a fraudulent act, third party breach of contract, and grossly negligent supervision claims. The court denied the motion as to the wrongful termination/breach of contract claim, attorney's fees, and damages. At the close of all of the evidence, Charleston again moved for a directed verdict on these issues, which the court denied. The jury returned a verdict in favor of McNaughton on her breach of contract claim, finding $20,623 in actual damages and $74,112 in special damages. After the jury verdict was announced, Charleston moved for JNOV under Rule 50(b), SCRCP, and a new trial under Rule 59(a), SCRCP, which the court denied. McNaughton filed a petition for attorney's fees. The trial court held a separate hearing on the issue of attorney's fees and awarded $37,894 in attorney's fees. In its order awarding attorney's fees, the trial court addressed and considered the factors of § 15-77-300 (2005). in detail. Charleston appealed to the court of appeals.
Was a verdict properly returned for McNaughton on her wrongful termination/breach of contract claim against Charleston?
The Supreme Court of South Carolina held that the trial court properly denied Charleston directed verdict and judgment notwithstanding the verdict motions because there was evidence to support the jury's finding that the school breached the teacher's employment agreement. The trial court did not err in charging and allowing the jury to award the teacher special damages for her breach of contract claim because the teacher presented evidence to support the jury's special damages award. The trial court did not err in awarding the teacher attorney's fees pursuant to S.C. Code Ann. § 15-77-300 (2005).
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