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Indiana ex rel. Anderson v. Brand

United States Supreme Court

303 U.S. 95 (1938)

Relevant factsFree

Anderson (plaintiff), a township public school teacher whose contracts since 1931 expressly incorporated Indiana's Teachers' Tenure Act granting permanent, cause-only-terminable status after five years of service, was notified her contract would end after the 1933-34 school year once Indiana amended the Act in 1933 to remove township schools from its coverage, while leaving city and town teachers' tenure protections intact. Anderson sued Brand (defendant), a school official, seeking to compel continued employment; the trial court sustained a demurrer on two grounds, that officials had authority under the Act and that the 1933 repeal did not impair any vested constitutional right, and the Indiana Supreme Court affirmed on the second ground alone.

IssueFree

Whether the United States Supreme Court may review a final state court decision resting on a federal constitutional question, despite the existence of an independent state-law ground also supporting that decision.

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