The Third Circuit Court of Appeals ruled last week in Connelly v. Steel Valley School District that the Privileges and Immunities Clause of the U.S. Constitution does not require that the same credit be given for out-of-state teaching experience as is given for in-state teaching experience for salary purposes. In this case, the Steel Valley School District in Pennsylvania hired Connelly as a sixth grade teacher in 2006. The school district pays its teachers on a salary scale based on their education and years of experience, much like the salary schedule used by Arkansas school districts. At the time he was hired, Connelly had nine years of teaching experience in the state of Maryland, but none in the state of Pennsylvania. Therefore, the school district only gave Connelly one year of credit for his past experience, which led to Connelly receiving a much lower salary than similarly situated teachers who had teaching experience in Pennsylvania. As a result, Connelly filed a lawsuit, arguing that the Steel Valley School District had violated his right to interstate travel under the Privileges and Immunities Clause and denied him equal protection under the law.
The Third Circuit rejected Connelly’s argument that the salary classification by Steel Valley violated his fundamental right to interstate travel, and as such, rejected his argument that it be reviewed under strict scrutiny. Because Steel Valley’s classification discriminated on the basis of the location of Connelly’s teaching experience, rather than on the duration of his residency in Pennsylvania, the Court ruled that the classification was subject to the less restrictive rational basis review. Under that review, the Court found that there was legitimate government interest in offering higher compensation to individuals with Pennsylvania teaching experience. First, the Court noted that teachers with experience in Pennsylvania are more familiar with state policies, procedures, and regulations, and second, because those teachers with in-state experience would have a better grasp on what methods were the most successful in achieving the state’s goals, it would lead to increased educational efficiency in the schools. Because of these reasons, the Third Circuit upheld the classification and ruled in favor of the Steel Valley School District.