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State court of last resort · ST-VA-SC

Payne v. Fairfax County School Bd.

No. 140145Supreme Court of Virginia

140145 Payne v. Fairfax County School Bd. 10/31/2014 Code § 22.1-315(A) does not require a school board to hold a hearing before suspending a non-teaching employee without pay for fewer than five days. The pre…

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Current update

140145 Payne v. Fairfax County School Bd. 10/31/2014 Code § 22.1-315(A) does not require a school board to hold a hearing before …

At a glance
Court
Supreme Court of Virginia
First added here
October 4, 2026
Last entry
October 31, 2014
Policy at issue

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Official docket

Case timeline

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Docket entry

140145 Payne v. Fairfax County School Bd. 10/31/2014 Code § 22.1-315(A) does not require a school board to hold a hearing before suspending a non-teaching employee without pay for fewer than five days. The present employee has no standing argue the due process rights of teachers, and any due process rights she may have had as a non-teaching employee were fulfilled by the grievance process. Code § 22.1-28 vests school boards with authority to supervise the schools in their school divisions. Under Dillon's Rule, the power to discipline school employees is not only necessarily and fairly implied from this provision, such power is essential and indispensable, and Code § 22.1-79(6) presupposes t…

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