PHILLIPS, Chief Judge.
Michael J. Patrone, a nontenured school teacher in the Howland, Ohio, district, was employed for eight successive years under a series of one year certificates to teach industrial arts. He is not eligible for tenure under Ohio law because he has never qualified for a regular industrial arts teaching certificate. When his contract was not renewed for the 1970-71 school year, he filed this action under 42 U.S.C. § 1983, complaining that the...
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