A TEACHER MAY NOT ACCUMULATE CREDIT TOWARD TENURE IN ONE SCHOOL DISTRICT FOR WORK AS A SUBSTITUTE TEACHER IN ANOTHER DISTRICT (SECOND DEPT).
The Second Department, in a full-fledged opinion by Justice Ford, determined a teacher may not accumulate credit towards tenure from working as a substitute teacher in a different district:
The narrow issue presented on this appeal, apparently one of first impression for an appellate court in this State, is whether a teacher may accumulate credit towards tenure, also known as “Jarema credit,” pursuant to Education Law § 3012, for time spent teaching as a regular substitute teacher in a district other than the district in which the teacher is seeking tenure. … [W]e conclude that a teacher is only entitled to “Jarema credit” for regular substitute service if said service was completed in the district in which the teacher is seeking tenure. Matter of DeNigris v Smithtown Cent. Sch. Dist., 2023 NY Slip Op 03783, Second Dept 7-12-23
Practice Point: A teacher may not accumulate credit toward tenure in one school district for time working as a substitute teacher in another district.
