Gallien Declaratory

ELECTRONICALLY FILED - 2023 Oct 05 8:06 AM - CHARLESTON - COMMON PLEAS - CASE#2023CP1004910
IN THE STATE OF SOUTH CAROLINA IN THE COURT OF COMMON PLEAS
COUNTY OF CHARLESTON FOR THE NINTH JUDICIAL CIRCUIT
Dr. Eric N. Gallien, ) Case No.: 2023-CP-10-___________

)
Plaintiff, )
)
vs. ) SUMMONS
) (Declaratory Judgment)
Charleston County School District, )
)
)
Defendant. )
)
TO THE DEFENDANT ABOVE NAMED:

You are hereby summoned and required to answer the Verified Complaint in this action, a
copy of which is herewith served upon you, and to serve a copy of your answer to the Verified
Complaint to the subscriber at Bloodgood & Sanders, LLC, 242 Mathis Ferry Road, Suite 201,
Mt. Pleasant, South Carolina, 29464, within thirty (30) days after the service hereof, exclusive of
the day of such service. If you fail to answer the Verified Complaint within that time, the Plaintiff
will apply to the Court for the relief demanded in the Verified Complaint and a judgment by default
will be rendered against you.
BLOODGOOD & SANDERS, L.L.C.
s/Nancy Bloodgood
Nancy Bloodgood, SC Bar No.: 6459
Lucy C. Sanders, SC Bar No.: 78169
242 Mathis Ferry Road, Suite 201
Mt. Pleasant, SC 29464
Telephone: (843) 972-0313
Email: nbloodgood@bloodgoodsanders.com
lsanders@bloodgoodsanders.com
Attorneys for Dr. Gallien
Charleston, South Carolina
October 5, 2023
1
IN THE STATE OF SOUTH CAROLINA IN THE COURT OF COMMON PLEAS
COUNTY OF CHARLESTON FOR THE NINTH JUDICIAL CIRCUIT
Dr. Eric N. Gallien, ) Case No.: 2023-CP-10-___________

)
Plaintiff, )
)
vs. ) VERIFIED DECLARATORY
) JUDGMENT COMPLAINT
Charleston County School District, )
)
)
Defendant. )
)
This action is brought pursuant to the South Carolina Uniform Declaratory Judgments Act.
Plaintiff Dr. Eric N. Gallien seeks a declaration of his rights and status as Superintendent of the
Charleston County School District (CCSD) under an employment contract signed by CCSD, Board
Policies adopted by CCSD (which are incorporated into Dr. Gallien’s employment contract), and
State law. Dr. Gallien would respectfully show unto this Honorable Court the following:
Parties, Jurisdiction, and Venue
1. Plaintiff is a citizen and resident of Charleston County, South Carolina. At all times
relevant to this Complaint, Dr. Gallien was employed by Defendant Charleston County School
District (“CCSD”) as Superintendent.
2. CCSD is a body politic and corporate that provides public educational services to
student residents within the defined boundaries of Charleston County.
3. The majority of events alleged herein happened or took place in the County of
Charleston, State of South Carolina and jurisdiction is proper.
2
4. Venue is proper in this jurisdiction because Defendant does business in Charleston
County and the actions giving rise to Dr. Gallien’s claims were committed within Charleston County.
5. Plaintiff was improperly placed on leave pending an investigation into a CCSD
employee’s job complaint, and Plaintiff’s request to Defendant’s Chair to call a special meeting to
consider allowing Plaintiff to return to work while the complaint is being investigated was
promptly denied by Defendant.
FACTS
Employment Contract
6. Defendant CCSD and Dr. Gallien signed an employment contract on June 21, 2023
for Dr. Gallien to serve as CCSD’s Superintendent. (Ex. 1, Employment Contract.)
7. The initial term of Dr. Gallien’s employment contract was from July 1, 2023
through June 30, 2025.
8. Dr. Gallien’s job responsibilities per the employment contract stated he “shall be
in charge of the Administration of the District.” (emphasis added).
9. Exhibit A to the employment contract authorizes Dr. Gallien to provide for the
employment of qualified persons in the District and establish job descriptions.
10. Per the employment contract, Dr. Gallien was expected to act in accordance with
South Carolina law1 and in accordance with CCSD Board policies.
CCSD Board Policies
1
S.C. Code § 59-19-90 sets forth the general powers and duties of school boards; S.C. Code §
59-1-510, et seq. sets forth the guidelines and regulations for recruitment and hiring staff in
professional areas.
3
11. CCSD Board Policy BBA “Board Powers and Duties” acknowledges the CCSD
Board as the “policymaking body of the district.”2
12. CCSD Board Policy BBA also states, “The board shall appoint a superintendent
who is charged with and shall be held responsible for the operation and management of the
district.”
13. CCSD Board Policy BCA “Board Member Code of Ethics” requires a Board
member to understand “that the basic function of a school board is policymaking, not
administration, and accept[] the responsibility of learning to discriminate intelligently between
these two functions.”
14. CCSD Board Policy BCA also states, “A board member should give “the
superintendent full operational authority for properly discharging his/her professional duties…”
and act “only upon the recommendation of the superintendent in matters of employment or
dismissal of school personnel per the Act of Consolidation.”
15. CCSD Board Policy GCF states the “[h]iring of principals and candidates at the
executive director level and above shall be the responsibility of the superintendent, who will advise
the board of such hires.”
16. CCSD Board Policy CBC “Superintendent’s Role and Responsibilities” states,
“The superintendent shall be responsible for the operational organization of the district in all
aspects” and “the board believes the responsibility for operating the school system is the
superintendent’s.”
17. CCSD Board Policy BCA “Board Member Code of Ethics” states, the board must
recognize “that authority rests only with the board in official meetings and that the individual
2
Board Policies cited in this Complaint are attached as Exhibit 2.
4
member has no legal status to bind the board outside of such meetings” and refrain “from assuming
personal responsibility for resolving operational problems or complaints; complaints will be
referred to the superintendent for investigation and resolution.”
18. CCSD Board Policy BEDA/BEDB, regarding Board Agenda and Notice, states,
“The superintendent shall prepare all agendas for board meetings. Items for the board meeting
agenda will ordinarily come from the committee of the whole. The superintendent and board
chairman shall confer about the agenda.”
19. CCSD Board Policy BDG “General Counsel” states the general counsel “shall
represent and advise the board and the district administration on legal matters involving the
business of the district.”
20. CCSD Board Policy BDG “General Counsel” also states “in the event of a dispute
between the board and superintendent, the General Counsel may not represent the interests of
either and, in such event, the superintendent shall authorize the hiring of outside counsel to
represent the board.”
Dr. Gallien’s Attempt to Perform his Job
21. Dr. Gallien began work as Defendant’s Superintendent on July 1, 2023.
22. After Dr. Gallien began working as Superintendent, he told the Board he intended
to hire two (2) administrators he had worked with in Wisconsin to be part of his administration;
Dr. Gallien was told by the Board he could not make these hires.
23. During this same time period, Dr. Gallien also attempted to move a high-level
employee into a job with less responsibilities, but Chair McKinney told Dr. Gallien he could not
to do so.
5
24. A few weeks after Dr. Gallien was hired, Chair McKinney and Board member
Grybowski met with Dr. Gallien to advise him of a May 18, 2023 Board Directive (passed before
Dr. Gallien was hired) which required a superintendent to “make no personnel changes to the
organizational chart of the central office, without an explicit vote of the board.” (May 18, 2023
Board Directive, Ex. 3.)
25. This May 18, 2023 Directive seriously interfered with Dr. Gallien’s ability to
operate and manage the District, violated the provisions of his employment contract, and
contradicted CCSD Board Policies.
26. Dr. Gallien was unable to operate and manage the District unless he could make
personnel changes in his administration and hire and fire employees so he requested the Board
revisit the Directive.
27. At a Special Called Board Meeting on July 17, 2023, the CCSD Board passed a
motion allowing Dr. Gallien to move forward with hiring new employees.
28. However, four (4) days later on July 21, 2023, Chair McKinney sent Dr. Gallien an
email, instructing him that the May 18th Directive had not been rescinded by the Board, and that
her understanding (and the General Counsel’s understanding) was that the motion that had passed
on July 17, 2023 “to allow the new Superintendent to take appropriate action to fill interim and
vacant positions” would still require a Board vote for any personnel changes to the organizational
chart of the central office.
29. On July 31, 2023, Chair McKinney emailed Dr. Gallien twice about an employee
he had wanted to move to a different position, stating, “I perhaps was not clear about [this
employee]” and ordering Dr. Gallien to retain the employee in her July 1st position until a Board
vote.
6
30. Chair McKinney then instructed Dr. Gallien to provide the Board a new proposed
job title and new job description for this employee.
31. Dr. Gallien presented his proposed job title and job responsibilities for this
employee the Chair was so interested in to the Board but his proposed job position was rejected
by the Board.
32. Dr. Gallien was ordered to restore this employee to the job she had held under the
previous superintendent.
33. Additionally, on August 16, 2023, Chair McKinney informed Dr. Gallien she
would not support his plan to place an existing employee (Michelle Simmons) in the Chief
Academic Officer position, and she did not believe a majority of the other Board members would
either.
34. Although Chair McKinney instructed Dr. Gallien he had to obey the Board’s May
18, 2023 Directive, she contradicted herself and emailed Dr. Gallien on August 17, 2023 telling
him that after conferring with General Counsel, she was giving Dr. Gallien permission to hire an
employee in the Procurement Department without Board approval because this hire “check[ed] all
the boxes.”
35. Dr. Gallien knew his job was in jeopardy if he did not follow the Board’s
instructions as there were five (5) “Moms for Liberty backed” Board members (Bailey, Grybowski,
Kelley, McKinney and Whatley) who voted as a block and did not support him making any
independent personnel decisions.
September 11, 2023 Special Called Board Meeting
36. The Chair called a Special Board Meeting on September 11, 2023.
7
37. At the Special Called Board Meeting on September 11, 2023, in Executive Session,
Chair McKinney complained about Dr. Gallien’s use of the word “equity” on a CCSD website and
his reluctance to follow the Board’s directions regarding personnel matters to intimidate Dr.
Gallien and threaten his employment.
38. During this Executive Session meeting, the Board provided a list of “concerns” to
Dr. Gallien; most of the items on the list involved Dr. Gallien objecting to, or not following, the
five (5) Moms for Liberty backed Board members’ instructions regarding personnel matters.
39. The real purpose of the Special Meeting called by Chair McKinney was so the five
(5) Moms for Liberty backed Board members could terminate Dr. Gallien’s employment.
40. Although the five (5) Moms for Liberty backed Board members intended to
terminate Dr. Gallien at the September 11th meeting, they decided to give Dr. Gallien the
opportunity to respond to their concerns in writing, which he did.
41. Several days later, on the evening of September 21, 2023, the employee whose job
the five (5) Moms for Liberty Board members had tried to protect, sent Dr. Gallien an email,
copying the full Board, complaining that Dr. Gallien had not given her the job duties she wanted
and she felt disrespected.
42. The email stated it was “Attorney Client Privileged” but this employee is not an
attorney and Dr. Gallien is not an attorney.
43. The same evening Dr. Gallien received this email, he emailed the Board telling
them this was a personnel matter and he would handle it.
44. Suspecting some members of the Board or his staff had encouraged this employee
to make this complaint, Dr. Gallien emailed the employee and asked her to meet with him the next
day.
8
45. The employee did not attend the meeting and, one (1) day later, Dr. Gallien learned
that the General Counsel, without Dr. Gallien’s knowledge or permission, had added two (2) items
to the Board’s Executive Session agenda.
46. The General Counsel, a private lawyer, had no right to alter a public agenda Dr.
Gallien had already approved.
47. Dr. Gallien was not able to contact the General Counsel to obtain information about
the two (2) added Executive Session agenda items.
48. Dr. Gallien was eventually told by the General Counsel the purpose of the added
agenda items was to place Dr. Gallien on leave due to the disgruntled employee’s complaint against
him.
49. Based on the General Counsel’s unauthorized action of changing the agenda, and
her repeated representation of the five (5) Moms for Liberty backed Board members against him,
Dr. Gallien sent the General Counsel an email stating she had a conflict of interest, he would not
waive the conflict, and he was terminating her representation of him as Superintendent.
50. Dr. Gallien stated in his email, “Ethically, I believe when there is a dispute between
the Board and me regarding my responsibilities, you should not, and cannot, effectively represent
either of us.”
September 25, 2023 Regular Board Meeting
51. The next day, at the September 25th Regular Board meeting, the four (4) “Regular”
Board members (the members not backed by the Moms for Liberty: Calhoun, Dunmeyer-
Roberson, Tempel and Waters) objected to the General Counsel adding items to the Executive
Session agenda without the Superintendent’s knowledge.
9
52. These four (4) Board members complained that not providing information to them
or to the public about the items added to the Executive Session agenda was the wrong way to
govern, unethical, disingenuous, not transparent, and a violation of the State’s Freedom of
Information Act (FOIA).
53. The Board agenda was nevertheless adopted by a 5-4 vote from the five (5) Moms
for Liberty backed Board members.
54. Moms for Liberty backed Board member Bailey then immediately moved to go into
Executive Session.
Executive Session
55. After approximately an hour and a half into the Executive Session, the Board
invited several attorneys representing Dr. Gallien’s interests into Executive Session at Dr.
Gallien’s request.
56. The attorneys were allowed to observe and take notes of the Board members’
statements and actions during the Executive Session.
57. When the attorneys entered the Executive Session, the General Counsel was
providing the Board advice regarding placing Dr. Gallien on leave with pay and obtaining private
outside counsel to investigate the employee’s complaint.
58. The CCSD Board was polled in Executive Session regarding their opinions.
59. Chair McKinney asked if there was a motion in Executive Session to place Dr.
Gallien on leave with pay and the General Counsel suggested the name of an outside attorney to
investigate the employee complaint.
10
60. The General Counsel told the Board the matter was “serious” because Chair
McKinney had ordered Dr. Gallien not to contact the employee and Dr. Gallien had not followed
the Chair’s instructions to him.
61. Regular Board member Calhoun asked if the Board was going to start putting every
principal about whom a teacher complained and every supervisor about whom an employee
complained on paid leave.
62. At one point during this 2 ½ hour Executive Session, CCSD Security knocked on
the door and said the audience was getting agitated. Security recommended the Board go back
into open session and then adjourn.
63. Moms for Liberty Board member Whatley asked why couldn’t the Board just
continue the meeting in Executive Session as it had done a couple of times before.
64. Dr. Gallien told the Board that placing him on paid leave would harm his name and
his reputation; he said he believed there was collusion going on by some Board members to protect
the employee who had made the complaint against him.
65. Moms for Liberty Board member Kelly exited the Executive Session stating, “We
have to protect [this employee],” referencing the employee who made the complaint.
66. When the CCSD Board finally came out of Executive Session, it was clear to
everyone, including Dr. Gallien and the lawyers who had been witnesses to the Executive Session
that there were five (5) Moms for Liberty Board members ready to place Dr. Gallien on paid leave.
Open Session
67. The General Counsel did not return to the Board meeting so the CCSD Board had
no legal counsel or parliamentarian when the meeting reconvened.
11
68. The audience became hostile towards the Board, especially after the Moms for
Liberty backed Board members refused to approve Dr. Gallien’s recommendation of making
Michelle Simmons the Chief Academic Officer by a 5-4 vote.
Illegal Meeting
69. The five (5) Moms for Liberty backed Board members then suddenly got up and
walked out of the open session meeting (Bailey, Grybowski, Kelley, McKinney, and Whatley.)
70. The video screen behind where the CCSD Board sat first indicated the meeting was
adjourned and then was changed to indicate the Board meeting was in “recess” but the four (4)
Regular Board members (Calhoun, Dunmeyer-Roberson, Tempel and Waters) remained in their
seats during this “recess.”
71. The five (5) Moms for Liberty backed members (a quorum of the CCSD Board)
then proceeded to have an illegal meeting during the regularly scheduled (and supposedly
recessed) Board meeting at a location away from the regularly scheduled meeting and they illegally
voted to appoint an employee (Anita Huggins) as Interim Superintendent to replace Dr. Gallien
(before there had even been a vote in open session to place Dr. Gallien on leave).
72. The Moms for Liberty backed Board members’ “recess” meeting violated the FOIA
as it was not properly noticed, a quorum was present, the public was not allowed to attend, and a
vote was taken at this illegal “meeting within a meeting.”
73. The Moms for Liberty backed Board members’ appointment of an Interim
Superintendent is null and void and any actions taken by her are invalid.
Reconvening in Open Session
74. Although there had been no vote by the Board to recess, when the Moms for Liberty
backed Board members returned to the public meeting, they voted 5-4 to “reconvene.”
12
75. During this second part of the regularly scheduled meeting, the Moms for Liberty
backed Board members voted to replace all of the members of the Health Advisory Committee,
even though there were only a limited number of vacancies. CCSD staff explained that some of
the persons being approved by the Board did not meet the statutory qualifications to be members
of a Health Advisory Committee.
76. Regular Board members Calhoun, Dunmeyer-Roberson, Tempel, and Calhoun
apologized to Dr. Gallien and then the Moms for Liberty backed Board members voted 5-4 to
place Dr. Gallien on paid administrative leave.
77. The Moms for Liberty backed Board members then announced they had voted (in
secret at the illegal meeting within a meeting) to appoint an Interim Superintendent, and the
meeting ended.
FOR A FIRST CAUSE OF ACTION

(Declaratory Judgment)
78. Dr. Gallien repeats and realleges each and every allegation of the preceding
paragraphs as if restated verbatim.
79. There is a legal dispute between the CCSD Superintendent and a majority of the
CCSD Board regarding the legal rights of the Superintendent to operate and manage the District
under his employment contract, Board Policies, and a May 18, 2023 Board Directive.
80. The Declaratory Judgments Act is intended to provide a speedy and inexpensive
method of adjudicating legal disputes and settling legal rights and relationships. Thompson v. State,
415 S.C. 560 (2016).
81. A real and substantial justiciable controversy exists regarding the authority of the
CCSD Board and the CCSD Superintendent and is appropriate for judicial determination as
evidenced by the CCSD Board’s placement of Dr. Gallien on paid leave due to his failure to take
13
the employment action the Moms for Liberty backed Board members wanted him to take regarding
an individual employee.
82. If and when Dr. Gallien is taken off paid leave and returned to work, a justiciable
controversy will continue to exist as there is a five (5) member majority (the Moms for Liberty
backed Board members) who at any time can terminate Dr. Gallien or place him on leave again
when he tries to make personnel decisions and/or exercise his authority as Superintendent to operate
and manage the District.
83. A justiciable controversy exists between the parties.
84. Dr. Gallien’s employment contract authorizes him to be in charge of the
administration of the District under the direction of the Board” and “Provide for the employment
of qualified persons [and] establish job descriptions.” (Ex. A, pp. 1, 8.)
85. Dr. Gallien’s employment contract also states Dr. Gallien “shall perform the duties
and responsibilities set forth on Exhibit A and as delegated to him from time to time by the Board
of Trustees (the “Board”), pursuant to its policies and directives and in accordance with South
Carolina law.” (Ex. A., p. 1.)
86. Defendant CCSD has breached Dr. Gallien’s employment contract by refusing to
allow him to provide for the employment of qualified persons and act in accordance with the
Board’s policies and State law.
87. CCSD Board Policies unequivocally state the superintendent is responsible for the
operation and management of the district; responsible for the operational organization of the
district in all aspects; and the responsibility for operating the school system is with the
superintendent. (Ex. 2, Board Policies.)
14
88. Defendant CCSD has ignored its Policies and attempted repeatedly to usurp the
authority of Dr. Gallien in order to control personnel and function as the de facto superintendent
of the District.
89. CCSD Board’s May 18, 2023 Directive requiring Dr. Gallien to obtain Board
approval before making any personnel decisions contradicts Dr. Gallien’s employment contract and
CCSD Board Policies.
90. Pursuant to S.C. Code § 15-53-40, a contract may be construed by a court either
before or after there has been a breach.
91. A majority of Defendant CCSD’s Board (the five (5) Moms for Liberty backed
Board members) has repeatedly violated the State’s FOIA in order to avoid public scrutiny, make
secret decisions, and harm Dr. Gallien.
92. A majority of Defendant CCSD’s Board (the five (5) Moms for Liberty backed
Board members) intended to, and have, diminished Dr. Gallien’s authority as Superintendent.
93. Dr. Gallien seeks a declaration of his rights as superintendent under his employment
contract, Board policies, and state law.
WHEREFORE, Dr. Gallien, in his capacity as Superintendent of the CCSD, seeks the
following declaratory equitable and legal relief:
1. A judicial declaration that CCSD Board’s May 18, 2023 Directive requiring Dr. Gallien
to obtain Board approval before making any personnel decisions in the central office
contradicts Dr. Gallien’s employment contract, violates CCSD Board Policies and State
law, and is null and void.
15
2. A judicial declaration that as Superintendent, Dr. Gallien has full authority under his
contract to be in charge of the administration of the District and all personnel actions
including providing for the employment of qualified persons at all levels, as well as
discharging employees he believes are detrimental to his administration;
3. A judicial declaration that pursuant to CCSD Board policies referenced in Dr. Gallien’s
employment contract, Defendant CCSD is only permitted to set policy, and that the
operation and management of the District including, but not limited to, any and all
personnel decisions, is the responsibility of the Superintendent, not the responsibility
of the Board;
4. A judicial declaration requiring Defendant CCSD to comply with the requirements of
the State’s FOIA by timely providing the specific purpose of any and all future
Executive Sessions and providing adequate background material for Board members
and the public to review and understand before an Executive Session is convened; by
requiring the Board to immediately cease the practice of polling Board members in
Executive Session and permitting motions being made and voted on in Executive
Session; by prohibiting the Board from voting or meeting in Executive Session to avoid
public scrutiny; and by prohibiting the Board from participating in illegally noticed and
held meetings; and
5. A judicial declaration that the actions of a majority of Defendant CCSD’s Board (the
five (5) Moms for Liberty backed Board members) at the CCSD Board meeting on
September 25, 2023 regarding placing Dr. Gallien on paid leave, refusing to permit Dr.
Gallien to place Michelle Simmons in the job position he chose for her, and placing
Anita Huggins in the position of Interim Superintendent are all null and void and
16
without effect as they are the result of the illegal deprivation of the superintendent’s
authority by a majority of the CCSD Board.
Dr. Gallien also respectfully requests reasonable attorneys’ fees and costs associated with
this action, as well as such other legal and equitable damages as this Court may order.
Respectfully submitted,
BLOODGOOD & SANDERS, LLC
s/Nancy Bloodgood
Nancy Bloodgood, S.C. Bar No.: 6459
Lucy C. Sanders, S.C. Bar No.: 78169
242 Mathis Ferry Road, Suite 201
Mt. Pleasant, SC 29464
Telephone: (843) 972-0313
Email: nbloodgood@bloodgoodsanders.com
lsanders@bloodgoodsanders.com
Attorneys for Dr. Gallien
Charleston, South Carolina
Date: October 5, 2023
17

Gallien Declaratory

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ELECTRONICALLY FILED - 2023 Oct 05 8:06 AM - CHARLESTON - COMMON PLEAS - CASE#2023CP1004910

IN THE STATE OF SOUTH CAROLINA IN THE COURT OF COMMON PLEAS

COUNTY OF CHARLESTON FOR THE NINTH JUDICIAL CIRCUIT

Dr. Eric N. Gallien, ) Case No.: 2023-CP-10-___________

TO THE DEFENDANT ABOVE NAMED:

will be rendered against you.

BLOODGOOD & SANDERS, L.L.C.

COUNTY OF CHARLESTON FOR THE NINTH JUDICIAL CIRCUIT

Dr. Eric N. Gallien, ) Case No.: 2023-CP-10-___________

Parties, Jurisdiction, and Venue

District (“CCSD”) as Superintendent.

student residents within the defined boundaries of Charleston County.

Charleston, State of South Carolina and jurisdiction is proper.

5. Plaintiff was improperly placed on leave pending an investigation into a CCSD

promptly denied by Defendant.

for Dr. Gallien to serve as CCSD’s Superintendent. (Ex. 1, Employment Contract.)

through June 30, 2025.

in charge of the Administration of the District.” (emphasis added).

employment of qualified persons in the District and establish job descriptions.

South Carolina law1 and in accordance with CCSD Board policies.

CCSD Board Policies

Board as the “policymaking body of the district.”2

administration, and accept[] the responsibility of learning to discriminate intelligently between

these two functions.”

dismissal of school personnel per the Act of Consolidation.”

the board of such hires.”

personal responsibility for resolving operational problems or complaints; complaints will be

referred to the superintendent for investigation and resolution.”

chairman shall confer about the agenda.”

business of the district.”

represent the board.”

Dr. Gallien’s Attempt to Perform his Job

21. Dr. Gallien began work as Defendant’s Superintendent on July 1, 2023.

Board Directive, Ex. 3.)

contradicted CCSD Board Policies.

revisit the Directive.

chart of the central office.

job title and new job description for this employee.

independent personnel decisions.

September 11, 2023 Special Called Board Meeting

Gallien and threaten his employment.

opportunity to respond to their concerns in writing, which he did.

and she felt disrespected.

attorney and Dr. Gallien is not an attorney.

them this was a personnel matter and he would handle it.

to the Board’s Executive Session agenda.

Gallien had already approved.

the two (2) added Executive Session agenda items.

September 25, 2023 Regular Board Meeting

Session agenda without the Superintendent’s knowledge.

Information Act (FOIA).

for Liberty backed Board members.

statements and actions during the Executive Session.

outside counsel to investigate the employee’s complaint.

investigate the employee complaint.

the Chair’s instructions to him.

complained on paid leave.

into open session and then adjourn.

the employee who had made the complaint against him.

no legal counsel or parliamentarian when the meeting reconvened.

Michelle Simmons the Chief Academic Officer by a 5-4 vote.

seats during this “recess.”

vote was taken at this illegal “meeting within a meeting.”

Reconvening in Open Session