Actual Notice of Non-Reelection Under Certain Circumstances Meets Statutory Notice Requirement for Probationary Certificated Employee

A California Court of Appeal recently found that a probationary certificated employee’s receipt of actual notice of nonreelection was sufficient and personal service was not required. In Del M. Grace v. Beaumont Unified School District , the probationary employee received adequate notice of her nonreelection when she attended a school board meeting where the board announced its decision to lay off 12 employees, identified by employee number, one of the numbers belonged to Grace. In addition, the court found that Grace waived her right to be personally served with written notice by responding to a District’s email to her prior to March 15 in which Grace requested that notice be provided to her via certified mail.