On March 4, 2008, the court of appeal affirmed summary judgment in favor of the Los Angeles Unified School District in Massey v. Los Angeles Unified School District (B 193196). A teacher sued the school district, claiming the school and a principal breached a settlement agreement by disclosing her below standard evaluation to prospective schools to which she applied for Assistant Principal positions, and asserting she also was defamed. On appeal, she challenged the summary adjudication on her breach of contract claim. The court of appeal found that summary judgment in favor of the school and principal was proper, concluding there was no evidence creating any triable issue of fact suggesting a breach of contract caused her any damages.

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