The North Dakota Supreme Court affirmed a district court's grant of summary judgment in favor of the Grand Forks Public School District in a case involving teacher contract classifications and grievance procedures. In *Christianson v. Grand Forks Public School District* (N.D. 2026), the court ruled that separate directing contracts for work performed outside regular school hours constitute extracurricular activities.
David Christianson, a teacher at Grand Forks Red River High School, held three separate positions during the 2023-24 school year: a primary teaching contract and two director contracts for Pep Band Director and Music-Instrumental Head Director. The dispute arose after Christianson was formally reprimanded following two pranks that occurred at the 2024 Red River High School graduation practice and ceremony while under his supervision.
As a result of the incidents, the school district reassigned Christianson to a different school and declined to renew his director contracts. Christianson contested these actions through the district's four-level grievance procedure, ultimately reaching a formal hearing before the School Board. The School Board denied his level-four appeal and voted to approve a written decision of their action at a subsequent meeting.
A critical procedural issue emerged when the School Board failed to issue the written decision by the August 7, 2024 deadline required by the grievance procedure. This delay became central to the legal dispute, as Christianson argued the district's procedural failure should work in his favor.
The district court granted summary judgment for the school district, determining that Christianson's director contracts were extracurricular in nature and ruling against his claims. Christianson appealed, challenging both the classification of his director contracts and the grant of summary judgment.
The North Dakota Supreme Court, in an opinion authored by Justice Crothers, established two key legal principles in its syllabus. First, the court held that "a party's failure to comply with the contractual requirements can waive the party's ability to enforce the contractual requirements." Second, it ruled that "a teacher's separate contract for work performed outside the regular school day, that provides separate pay and different responsibilities from the duties of their teaching contract, is extracurricular."
The Supreme Court's analysis focused on the nature of Christianson's directing positions. The court found that because these roles involved separate contracts with different pay structures and responsibilities distinct from his regular teaching duties, they qualified as extracurricular activities rather than core educational functions. This classification has important implications for how such positions are treated under employment law and grievance procedures.
The waiver principle applied by the court suggests that Christianson's own failure to comply with certain contractual requirements undermined his ability to demand strict compliance from the school district. While the full details of Christianson's alleged non-compliance are not detailed in the available opinion excerpt, this principle reflects the legal doctrine that parties cannot benefit from demanding performance they themselves have failed to provide.
The case highlights the complex employment relationships that exist in public education, where teachers often hold multiple positions with varying contractual terms and conditions. The distinction between regular teaching duties and extracurricular activities can significantly impact employment protections, grievance rights, and termination procedures.
For school districts, the ruling provides clarity on how courts may view separate directing and coaching contracts. The decision suggests that positions involving additional pay for work outside regular school hours will likely be classified as extracurricular, potentially providing districts with more flexibility in personnel decisions regarding these roles.
The case also demonstrates the importance of procedural compliance in employment disputes. While the school district failed to meet its deadline for issuing a written grievance decision, this procedural error did not prevent it from prevailing in court, suggesting that substantive legal issues may outweigh minor procedural lapses.
For educators holding multiple positions within school districts, the ruling emphasizes the need to understand the different legal protections that may apply to various roles. Teaching contracts and extracurricular contracts may be subject to different termination procedures and appeal rights.
The Supreme Court's affirmation of the summary judgment indicates that the legal issues were sufficiently clear that no genuine dispute of material fact existed requiring a full trial. This suggests that the extracurricular classification and waiver principles applied represent well-established areas of law.
The case was argued by Michael J. Geiermann of Bismarck for Christianson and Rachel A. Bruner of Bismarck for the school district. The original district court proceedings were heard by the Honorable Kristi P. Venhuizen in Grand Forks County.
This decision adds to North Dakota precedent on education employment law and may influence how similar disputes are resolved in the future. The ruling's emphasis on contractual compliance and clear classification of extracurricular activities provides guidance for both school districts and educators navigating complex employment relationships in public education.