See e.g., Goss v. E.S.I. Cases & Accessories, Inc., No. 18-cv-2159, 2020 WL 5817163, at *3 (S.D.N.Y. Sept. 29, 2020) (finding that the employer had "reason" — that is, "cause" — to terminate the employee based on the employment agreement); Trans World Airlines, Inc. v. Beaty, 402 F. Supp. 652, 658 (S.D.N.Y. 1975) ("[A] discharge for cause is ordinarily defined as a discharge for some reason which is not arbitrary or capricious."); Stanacard, LLC, No. 12-cv-462508, 2016 WL 462508, at *23 ("In the absence of any contractual definition of 'cause,' the trier of fact can simply apply the most natural meaning of the phrase: whether [the employee] was fired for an articulable and defensible reason relating to the performance of his duties at [the employer-company]."); Spurlin v. Sch. Bd. of Sarasota Cnty., 520 So. 2d 294, 296 (Fla. Dist. Ct. App. 1988) (authorizing school board to decline recommending that a contract be extended for a "lawful, rational, non-arbitrary, non-statutory reason"); see In re Piazza, 719 F.3d 1253, 1261-62 (11th Cir. 2013) (in a bankruptcy context, applying the "ordinary meaning" of "cause", and observing: "the ordinary meaning of 'cause' is adequate or sufficient reason").
In Florida, the general notion of "good cause"—a close cousin of "cause"—is that its lack of a definition gives educational institutions a degree of leeway to determine what is a sufficient basis for termination. For example, in Spurlin v. School Board of Sarasota County, 520 So.2d 294, 296 (Fla. 2d DCA 1988), the deputy school superintendent argued that "good cause" for termination was limited to the "seven-deadly sins" set out in the statute then applicable to teachers (i.e., immorality, misconduct in office, incompetency, gross insubordination, willful neglect of duty, drunkenness, and conviction of a crime involving moral turpitude).
Thus, the court recognized that a school board's ability to reject an applicant nominated by the superintendent is broader than the statutory grounds for dismissal in Chapter 231, Florida Statutes. 520 So.2d 294, 295 (Fla. 2d DCA 1988). Section 231.36(1)(a), Fla. Stat. (1995), provides that contracts for instructional staff employees must include a provision for dismissal during the term of the contract only for just cause; including, but not limited to, misconduct in office, incompetency, gross insubordination, willful neglect of duty, or conviction of a crime involving moral turpitude.
This case raises no question regarding the prerogatives of school superintendents vis-a-vis school boards. See generally Spurlin v. School Bd. of Sarasota County, 520 So.2d 294 (Fla. 2d DCA 1988); Von Stephens v. School Bd. of Sarasota County, 338 So.2d 890 (Fla. 2d DCA 1976).Appropriate Relief
PER CURIAM. Affirmed. MacPherson v. School Bd. of Monroe County, 505 So.2d 682 (Fla. 3d DCA 1987); Spurlin v. School Bd. of Sarasota County, 520 So.2d 294 (Fla.2d DCA 1988); Siess v. Department of Health Rehabilitative Serv., 468 So.2d 478 (Fla. 2d DCA 1985); § 120.57(10), Fla. Stat. (1987).