A federal district court in New York recently analyzed numerous claims brought by a superintendent against a school district, its Board of Education, and each of its Board members. The crux of the superintendent’s claims were that her employment was terminated because she exercised her right to take maternity leave.
One of the superintendents causes of action was of employment discrimination under Title VII. In order to establish a prima facie case for a Title VII claim, a plaintiff must demonstrate the following: (1) she is a member of a protected class; (2) she was qualified for the position she held; (3) she suffered an adverse employment action; and (4) the adverse action took place under circumstances giving rise to an inference of discrimination.
The superintendent was able to establish a prima facie case. Accordingly, the burden shifted to the Board to demonstrate some legitimate, nondiscriminatory reason for the adverse action. The school district said that the termination was due to various performance issues of the superintendent, which were supported by various performance evaluations of the superintendent by the Board.
The burden shifted back and the superintendent was required to produce sufficient evidence to support a rational finding that the legitimate, nondiscriminatory reasons offered by the school district were false, and that more likely than not, pregnancy discrimination was the real reason for the employment action. The superintendent pointed to a Board member’s statement that there were no problems with her performance — an alleged change in attitude by some Board members that the superintendent observed after she announced her pregnancy — as well as comments made by several Board members regarding her pregnancy. In particular, certain Board members allegedly made comments and inquiries about the superintendent’s dedication to her job, the difficulties associated with being a working mother, and her childcare arrangements.
On a motion for summary judgment brought by the school district, many of the superintendent’s other claims were dismissed. However, the superintendent’s Title VII claim survived, in part, because of the stray comments made by Board members related to her pregnancy. Accordingly, the school district was forced to continue its defense and proceed to trial, where the jury ultimately delivered a defense verdict, dismissing the superintendent’s remaining claims.
Employers are advised to train all employees, especially decision-makers, on appropriate topics and boundaries of conversation with employees. In this instance, even though the comments made by the Board members may have been well-intentioned or sourced from concern for the superintendent, the comments were thereafter used as ammunition to support the superintendent’s claim that the termination of her employment was due to gender discrimination. This case involves a K-12 district but the analysis is equally applicable at the college or university level.
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