In the last decade, the federal courts, led by the Supreme Court, have emphasized the equal protection clause of the fourteenth amendment as a basis for an employee's right to procedural due process prior to dismissal from public employment. The Supreme Court has declared that any governmental action to deprive a person of an interest, even a privilege-type interest, is arbitrary and capricious if not applied with universal evenhandedness This holding would seem to entitle almost any teacher summarily dismissed to procedural due process.