School Law Bulletin [serial] 27, 2 (Spring 1996)

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Ladner, 513 A.2d 257,264 (Me. 1986).
75. Id.
76. Richmond Newspapers, In,... I ipscomb, 362 S.E.2d 32 ( Va. 1987).
Furthermore, the courts that did not classify a teacher as a public official have stressed that the justifications for the higher standard of proof provided by the Supreme Court in decisions after New York Times do not apply to teachers. First, becoming the sub- ject of public debate is not inherent in teaching as it is in public office — teachers did not voluntarily seek this role
... when they entered the profession. 77 Second, contrary to the public officials envisioned by the Supreme Court, teachers usually do not have ready access to the media to rebut allegations simply because they are teachers. 78 Teachers may be public officials in North Carolina.
It is not clear whether courts would declare teachers to meet the first part of the definition of having substantial responsibility over education. On the one hand, North Carolina courts have looked to the existence of statu- tory provisions to determine whether an official is a public official, and the duties of teachers are prescribed by law in G.S.


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