A teacher filed a grievance with her school district, alleging that the district improperly reduced her salary. The teacher received a stipend for teaching three dual-credit courses. That stipend was reduced for the following school year. The teacher received only oral notice of the stipend amount that she would receive. The board of trustees denied the grievance and the teacher appealed to the commissioner of education.

The teacher argued that the district improperly reduced her stipend because it did so after the date by which she could resign from her teaching contract without the district's approval. Teachers may resign from their contracts for the upcoming school year at any time prior to the 45th day before the first day of instruction. A school district may reduce a teacher's pay before that time, the theory being that if a teacher disagrees with the reduction in pay, the teacher can simply resign. However, the commissioner has traditionally held that a school district cannot reduce pay when the teacher can no longer unilaterally resign from the contract. The district responded that since the stipend was only oral, it was not part of the teacher’s contract.

The commissioner held that all teaching duties are covered under the contract. If the teacher’s total compensation for the school year was going to be lower than it had been the previous year, then the district was required to give notice of this fact during the time when the teacher was permitted to unilaterally resign. However, in this case, there was no argument presented that the teacher’s entire compensation was lowered; only that a portion of it was. The prohibition against reducing compensation applies only to total compensation, not each element. Therefore, the commissioner held that the grievance should be denied.