In Ciripompa v. Bd. of Educ., the New Jersey Appellate Division heard a plaintiff teacher’s appeal from the Commissioner of Education’s final order that permitted a school board to deduct unemployment payments from back-pay owed. The teacher was suspended without pay during termination proceedings from his tenured position. When the proceedings ended in the teacher’s favor, he sought back pay. But that request was denied. The Appellate Division reversed, holding that N.J.S.A. 18A:6-14 specifically allows the school board to deduct from back pay any income received from “substitute employment” and that unemployment benefits are not employment of any sort. However, the school board was permitted to deduct income the teacher received as a bus driver and umpire.