Bd. of Educ. of Pasadena Unified Sch. Dist. v. Haas

California Court of Appeal Jun 29, 1978 No. Civ. 51991Published

Before: Hanson

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Holding. The court held that a trial court does not abuse its discretion by admitting psychiatric expert testimony based in part on a teacher's personnel file, as such information may be reasonably relied upon by experts under Evidence Code section 801, subdivision (b).

Issues

Whether a personnel file constitutes matter upon which a psychiatrist may reasonably rely in forming an opinion regarding a teacher's mental competence under Evidence Code section 801, subdivision (b).
Whether Education Code section 44942 precludes psychiatrists from considering information other than a list of job duties when evaluating a teacher's mental health.

Disposition. affirmed

Quotations verified verbatim against the opinion

“Experts in fields such as psychiatry should not be left to form their opinions in a vacuum. This is precisely the policy of Evidence Code section 801, subdivision (b).”

“We find no abuse of the trial court’s exercise of its sound discretion in admitting the psychiatric opinion which was based, in part, on material in the personnel file.”

[280]

Opinion

HANSON, J.

Defendant Rae P. Haas appeals from a judgment of the superior court confirming her placement on mandatory sick leave of absence pursuant to section 44942 of the Education Code.

Facts

Defendant-appellant Haas is a permanent certificated employee of the Pasadena Unified School District (hereinafter referred to as District). Pursuant to section 44942, subdivision (a), the Board of Education for the District (hereinafter referred to as Board) suspended Ms. Haas from employment effective January 28, 1976, upon its determination that she was suffering from mental illness of such a degree as to render her incompetent to perform her duties. The request of Ms. Haas to be examined by a panel of three psychiatrists according to the elaborate procedures provided for by that section was granted. The examination took place on March 12, 1976.

Prior to the examination, the District supplied each psychiatrist on the panel with Ms. Haas’ complete personnel file, including letters written by Ms. Haas, memoranda by the administration regarding her, letters concerning her from the office staff to the administrative staff, a statement signed by a number of Ms. Haas’ students, a letter from one of the parents, rebuttals of several employees whom Ms. Haas had accused of mistreating her, and evaluations of Ms. Haas’ teaching performance. The psychiatrists reviewed and considered this information, interviewed Ms. Haas personally for approximately one hour, and on March 21, 1976, submitted a report concluding that Ms. Haas was “sufficiently impaired by mental illness, manifested by paranoid ideation, inappropriate affect and behavior, poor judgment and impaired insight, to render her incompetent to perform her duties.” Following its receipt of this report, the Board placed Ms. Haas on mandatory sick leave on April 21, 1976, pursuant to section 44942, subdivision (f) (former § 13411, subd. (f)).

Following the Board’s action, Ms. Haas requested a hearing by the court. The Board approved Ms. Haas’ request and filed its complaint on July 30, 1976, asking the superior court to inquire into the charges and make the determinations prescribed by section 44942, subdivision (g). Accordingly, on February 1 and 2, 1977, the trial court heard the

Bd. of Educ. of Pasadena Unified Sch. Dist. v. Haas

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HANSON, J.

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