UPDATE II: Slayman files breach of contract, defamation suit against Chester County School District, others

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By Brian Garner

Former Chester County Superintendent Dr. Agnes Slayman filed a lawsuit Friday against the Chester County School District, school board chair Denise Lawson, former school board member Dr. Richard Hughes, former Chester County Associate Superintendent for Curriculum and Instruction Dr. Charles King, former Chester County Interim Superintendent Dr. Keith Callicutt and educational consultant Betty Bagley. The lawsuit, filed in Chester County, alleges “common law claims of breach of contract, breach of contract accompanied by a fraudulent act, defamation and civil conspiracy” and asks for actual, compensatory, punitive damages and court costs.

According to the lawsuit, which contains 85 different allegations, Slayman, who was superintendent from 2012 through 2015, states her yearly evaluation was postponed from an August 2015 board meeting until the meeting in September and before the evaluation could take place, board chair Denise Lawson told her “something bad is going on” and directed her to take vacation or personal leave until the end of August.

The lawsuit alleges there was no school board meeting before Slayman was asked to take leave and “the action was unilaterally taken by…Lawson,” and after Lawson had placed Slayman on leave, she called other board members and told them “she had placed Dr. Slayman on leave and that she could not discuss it with them.”

The lawsuit states that Dr. Slayman was unaware at the time that Lawson was “one of the people trying to oust her from the superintendent position.”

Following this action, the lawsuit alleges a school board meeting was called to discuss accusations against Dr. Slayman, and states during that meeting “there was a clear disconnect with a few school board members focused on ousting Dr. Slayman from her job and the remaining board members were caught by surprise and were left out of the loop of the targeted efforts to ruin Dr. Slayman’s career that was taking place before and after the special school board meeting.”

After the meeting, the suit alleges, Lawson and Dr. Richard Hughes along with school board attorneys met with school district employees disgruntled with Dr. Slayman.

In meetings prior to the school board meeting, the suit says, Dr. Slayman was “publicly accused with reports including false information, which they knew were unfounded, charging (her) with violation of civil rights, threatening EEOC action and suggesting that (she) was guilty of bullying and threatening conduct.” The suit alleges Lawson and Hughes “had met and conspired with others prior to the meeting.”

The result of that special called school board meeting was the hiring of Betty Bagley, an educational consultant, who investigated the claims about Slayman made by district employees and others.

Bagley met with employees and Slayman and reported her findings at a board meeting in September in a document that became known as “the Bagley Report.” The lawsuit further alleges the hand-written report was “not supposed to be written up since it was supposedly ‘work product’ within the attorney’s office that would not be disseminated. It was also stated that the Bagley Report would not be transcribed and should not be released to anyone and that it would remain confidential,” and said the report was “erroneous and full of false statements concerning (Slayman), both as to her violating rules and policies, bullying and threatening employees, and otherwise being incompetent to hold the position of superintendent.”

The lawsuit also alleges the allegations in the Bagley Report and statements made by Bagley were “knowingly false and made with the intent to defame and destroy (Slayman) and her reputation.”

The lawsuit also claims the Bagley Report “was selective and did not interview witnesses who would have disputed the false and inaccurate statements given by others and was designed and perpetrated with an agenda to make a predetermined finding that (Slayman) should be removed as superintendent” and further alleges several school board members rejected the contents of the Bagley Report and the allegations say the information in that report are “based on unsworn hearsay.”

At the Sept. 3 board meeting, the school board instructed that Slayman was to return to work, because a majority supported her and rejected the information presented in the Bagley Report.

She returned to work and the lawsuit alleges that Slayman was instructed by Lawson not to attend a Sept. 8 board meeting. The meeting was called and immediately adjourned by Lawson, who later told Slayman that she received grievances from five district staff members and according to the suit, Lawson instructed Slayman to remain on leave until a school board meeting could be held and the grievances were heard.

The suit alleges, “Lawson never intended for Dr. Slayman to return to her role as the district’s superintendent.”

Former District Associate Superintendent Dr. Charles King is named as a co-defendant because at this point, the suit alleges, either King or Hughes “released false information to others that the plaintiff was not on vacation but was away because of a pending grievance and was facing an open hearing before the school board, which would hopefully occur before a ‘packed house.’”

The suit continues based on the continued efforts to oust (Slayman), she felt she had no choice but to resign and met with the school board on Sept. 24 to hand them her resignation.

The district and Dr. Slayman then worked out a contractual agreement resolving the dispute between her and the district, which Lawson later signed.

At this point, Dr. Keith Callicutt was named the interim superintendent.

The lawsuit also alleges the board and Dr. Slayman agreed to keep the details of the Bagley Report confidential, however “at the school board meeting on Sept. 24, 2015, at the specific direction of Hughes and others, the Bagley Report was released to the media and all of the allegations which were agreed upon to remain confidential were exposed to public scrutiny and resulted in extreme and severe damage to (Slayman).”

The lawsuit then alleges that Callicutt, in his capacity as interim superintendent filed a letter in October with the S.C. Department of Education about Dr. Slayman, “in violation of the agreement and knowing the falsity of the Bagley Report and the failure of the board to take action thereon…thereby, endangering Dr. Slayman’s certification and in violation of the contract between Dr. Slayman and the district.”

The lawsuit states that the contractual agreement between Slayman and the district specifies that the school board and administrators will not publicly disparage Dr. Slayman, but in violation of this agreement, “Callicutt, Hughes, Lawson and others have publicly disparaged (her), and continue to do so until the present time.”

Former district Associate Superintendent Dr. Charles King is named in the suit when it alleges “on Dec. 15, 2016, a special meeting was called by Callicut where he stated he wanted to conduct a superintendent search. Seemingly on a fishing expedition for the board’s feelings about Dr. Slayman, Callicutt asked the board, if Agnes Slayman applied, would they consider her application.”

The suit alleges that “Callicutt and Lawson, along with others, were secretly plotting to bring in Dr. Charles King as the interim superintendent of the district…”

The suit also claims Dr. Slayman was informed in June 2017 that she did not get a superintendent position she had applied for in another school district (where she was on the short list) because of “negative remarks and interference…from the school district through its representatives and employees.”

In the four cases of action in the lawsuit, the breach of contract complaint is made against the school district. The lawsuit alleges, “the district has violated the contract it entered into with Dr. Slayman.”

The breach of contract accompanied by a fraudulent act claim is also made against the school district and states “the district had a fraudulent intent relating to the breach of the contract with Dr. Slayman. The district knew that Dr. Slayman had resigned with no findings against her, Dr. Slayman was resigning in good standing, that the board and administrators were contractually required not to disparage Dr. Slayman, that the contract and the terms therein were to remain confidential and that Dr. Slayman’s was a mutually agreed separation with no wrongdoing being found to either Dr. Slayman or the district.”

The suit claims, “the district knew all of these things at the time the contract was executed on Sept. 30, 2015. Yet, a mere two weeks later on Oct. 14, 2015, agents of the district accuse Dr. Slayman of wrongdoing and intentionally seek to harm (her) educator certificate.”

The defamation claim is also made against the school district. The suit alleges “the district defamed Dr. Slayman in word and by act in false statements impugning Dr. Slayman’s personal character and professional capabilities” and states “these false and pretextual grounds were maliciously published by the district’s agents and employees acting within the course and scope of their employment to others, including at least one or more school districts in South Carolina’ and have led to

the false insinuation that Dr. Slayman is unfit for her profession and committed potentially unethical or wrongful acts during her employment as the district’s superintendent.”

Finally the civil conspiracy claim is laid against Lawson, Hughes, King, Callicutt and Bagley and alleges “the (defendants) and others met, schemed, planned and conspired to not only remove Dr. Slayman from her position of superintendent of Chester County School District, but when Dr. Slayman settled her contract and resigned her position, the (defendants) continued to meet, scheme, plan and conspire with others, after the execution of the settlement contract, to seek to damage Dr. Slayman’s reputation and to have her certificates with the SCDE suspended or revoked’ and alleges that Callicutt

“with the full knowledge of the other individual defendants, but without the knowledge of many of the board members of Chester County School District, filed charges of unfitness with the South Carolina Department of Education using only the Bagley Report, which had already been discredited by the school board to the knowledge of Defendant Callicutt and all the other individual defendants.”

These charges lay dormant for two years, the lawsuit alleges, until the complaint at the S.C. Department of Education was revived “because of instigation, meetings and pressure by the (defendants).”

The lawsuit goes on to state, “Dr. Slayman now faces false and conjectural charges which threaten her certificates and license as an educator before the State Board of Education because of the desire of the (defendants) to harm (her) and with the intent to cause (her) special damages.”

Dr. Slayman’s attorney Lewis Cromer declined to comment on the lawsuit.

Neither the Chester County School District or co-defendant Betty Bagley, who is currently superintendent of the McCormick County School District, had released any comments on the lawsuit by press time.

Dr. Keith Callicutt, who is currently the executive director of the Pee Dee Education Center was contacted and said he had no comment.

Dr. Charles King, currently principal of Midway Elementary School in Kershaw County, was contacted and said he declined to comment.

The Chester County School District has not commented on the lawsuit at this time.

Current school board chair Denise Lawson said in an email “I have not seen a copy of the complaint that I understand has been filed by Dr. Slayman and thus have not had an opportunity to review it. It would be inappropriate for me to make any comment until such time as I have received the complaint and discussed it with an attorney.”

Lawson is also named as a co-defendant in a lawsuit brought by current Superintendent Dr. Angela Bain. Both Bain and Slayman are represented by attorney Lewis Cromer.

The case is awaiting ADR (alternative dispute resolution).


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