In the context of a summary judgment proceeding, Plaintiff is required at least to raise a genuine issue of fact regarding pretext. Id; Murray v. Mount Pleasant Independent School District, 754 F. Supp. 535, 538-39 (E.D.Tex. 1990), aff'd, 928 F.2d 402 (5th Cir. 1991). The Plaintiff has failed to do so.

English may have been correct before the TCNA was enacted, but as Grounds makes clear, it is no longer a correct statement of Texas law. See also Murray v. Mount Pleasant ISD, 754 F. Supp. 535 (E.D.Tex. 1990) aff'd 928 F.2d 402 (following English v. Hairston). Although George had a property interest in renewal, it does not follow that she had a property interest in a two-year renewal.

Nothing in the Act, nor in any cases we have found, indicates the legislature intended to create a property interest of constitutional dimensions. English, 888 F.2d at 1071; Murray v. Mount Pleasant Indep. School Dist., 754 F. Supp. 535, 536 (E.D.Tex. 1990), affirmed without opinion 928 F.2d 402 (5th Cir. 1991). Teachers certainly have a cause of action for breach of contract when school districts fail to obey the Act, and Grounds brought and settled such an action.