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Matthew Brown’s tort claim notice outlines the ways in which he believes Eugene School District 4J leaders unfairly blamed him for last year’s forecasting errors. Brown is threatening to sue for retaliation and, if the district terminates him, wrongful discharge, among other claims.
Eugene School District 4J’s finance director, Matthew Brown, has declared his intent to sue the district for retaliation and other claims.
Brown’s attorney, Nathan Rietmann of Rietmann Law, sent a tort claim notice to 4J on June 22, according to documents Lookout Eugene-Springfield obtained through a public records request. A tort claim is a required first document for those pursuing legal action against a public body for personal damages.
In the fall of 2025, the district announced a $30 million budget shortfall, and new Superintendent Miriam Mickelson presented cuts to close that gap in three stages. Then in March, 4J leaders announced there was an additional $16.4 million gap due to forecasting errors, and they decided to fill that by dipping into savings and using other one-time funds.
The tort claim notice lays out Brown’s perspective: District leaders unfairly blamed him for the $16.4 million budget error and did not fully disclose the reasons for the error.
Brown’s filing blames Mickelson for prematurely committing the district to a $30 million budget cut and it blames the board and other district officials for financial mismanagement that led to the overall budget deficit.
According to the tort claim notice, Brown has been on administrative leave since the district asked him to resign and he refused. Brown intends to sue 4J for retaliation, and, if the district terminates him, wrongful discharge.
“The district has strong disagreements with claims made in the notice,” wrote 4J spokesperson Kelly McIver in response to questions from Lookout. “Topics in the tort claim notice are connected to personnel matters, and tort claim notices are often precursors to legal proceedings, so the district declines to address the claims point-by-point or inappropriately litigate the claims in the news media.”
The district, he continued, “remains committed to financial responsibility, stability and sustainability, and maintaining community trust in the use of public funds to educate and care for students.”
The forecasting error
According to Brown, 4J’s publicized $30 million budget deficit was based on incomplete projections that did not factor in increased costs for the 2026-27 year.
He cautioned Mickelson early in the 2025-26 school year that until he had actual departmental budgets and revenue projections in February or March, it was not possible to know the actual extent of the deficit. The tort claim stated that 4J’s finance department had little control or oversight over certain departmental budgets, because those departments prepared their own budgets.
“Despite Mr. Brown’s repeated cautions to this effect, the Superintendent fixed upon $30 million as the public measure of success and committed the District to that figure publicly,” the tort claim reads.
The tort claim states one of “the principal drivers” of the $16.4 million variance that became apparent in February was increased special education personnel, payroll and benefit costs. According to Brown, the finance department does not have oversight or control over the Special Education Services budget, and therefore the increases were a surprise to Brown.
Other drivers the tort claim mentions include increased insurance costs, increased costs from partners including Lane Education Service District that provides schooling for students with disabilities, and Mickelson’s late-in-the-process decision to increase the staffing adjustment budget by $1.5 million.
In the meetings following 4J’s announcement of the forecasting variance, Mickelson, Brown and Associate Finance Director Bob Blyth laid out other unforeseen reasons for the mistake.
Among the reasons laid out at an April 8 meeting: A failure to accurately forecast vacancy savings, new state requirements that mandated a larger budget for unemployment payments, the spike in the cost of pension contributions and the finance department’s use of averages to estimate employee costs.
Mickelson and Brown also talked about the district’s failure to track the cost and revenue sources for each employee.
A resignation request
At the April 22 budget meeting, Brown went into more detail, breaking down the $16.4 million variance by dollar amount in the areas where forecasting went awry.
Brown said in his tort claim he created this breakdown in forecasting errors under protest. He did not agree with Mickelson, who attributed the $16.4 million variance to the finance and human resources departments.
“In Mr. Brown’s view, the honest reason for the budget crisis was financial mismanagement resulting from District leaders disregarding their fiscal responsibilities and using their authority instead to curry personal and political favor through irresponsible spending,” the tort claim states.
According to the tort claim, Mickelson directed Brown to present “a list of items to explain the $16.4 million variance in a manner that did not point to the School Board or the unions as responsible parties.”
In spite of this guidance, Brown presented to board members in the April 22 meeting about how since 2023 they had repeatedly voted to use reserves to keep teachers and staff as costs outpaced revenue, despite his warnings.
This presentation, which board member Jenny Jonak fact-checked, contained incorrect information about how much reserve money the district actually spent in previous years, instead of how much the board budgeted to spend. Blyth presented a corrected version at the May 6 meeting.
“We look to the past not to assign blame, but to ensure that we are learning from the indicators to better shape our future,” Brown said in the April 22 meeting.
He also said that due to bargaining with the classified staff’s union that ended in January, he and Blyth did not use the district’s then-current spending in their forecasting until March (because February was the first payroll when all employees received only their contractual salaries and not backpay).
According to the tort claim notice, 4J’s human resources director asked Brown to resign “within days” of the April 22 meeting, citing “neglect of duty.” Brown said Mickelson also offered him a letter of recommendation. When Brown declined to resign, the district put him on administrative leave and began an investigation. He said he has not received an update since.
When Lookout asked 4J about Brown’s employment status and what the investigation was about, McIver said Brown is employed by 4J and is “out,” declining to elaborate due to employee privacy.
Brown’s potential claims
Through his tort claim, Brown asserts that the district wrongfully blamed him for “the District’s financial crisis” and discouraged him from talking publicly about the board and the districts’ roles in the budget deficit to “conceal mismanagement by District leadership and the School Board.”
Brown did not clarify, when asked in an email from Lookout, how the school board was specifically to blame for the $16.4 million forecasting discrepancy.
According to the tort claim, Brown could sue 4J for retaliation and, if the district fires him, wrongful discharge and constructive discharge (when an employer has created a hostile work environment that effectively forces an employee to resign).
He may also sue for First Amendment retaliation for protected speech, denial of due process and other claims based on his contract.
The tort claim also says Brown is open to resolving the matter without filing litigation. Brown did not comment on what has happened since sending the tort claim notice to 4J.
