A federal judge from the District of Idaho has, for the most part, denied a school district’s motion for summary judgment in a case where the district was sued by a plaintiff for race and gender discrimination because it repeatedly passed over the plaintiff for various coaching positions.
Specifically, plaintiff John Banks was able to “raise doubt about the (district’s) proffered reasons for not hiring him as a coach.” He did this by highlighting the fact that the school district had previously given him positive evaluations in two areas, organizational and communication skills, which were the precise reasons given that he was not hired as a coach.
Banks sued the Pocatello School District after numerous “unsuccessful efforts to obtain coaching positions” within the district. The district moved for summary judgment, spawning the instant opinion.
The court noted that for Banks to establish a prima facie case of discrimination, his first obligation, pursuant to McDonnell Douglas Corp. v. Green, 411 U.S. 792, 802, 93 S. Ct. 1817, 36 L. Ed. 2d 668 (1973), was to show that (1) he belongs to a statutorily protected class, (2) he applied for and was qualified for an available position, (3) he was rejected despite his qualifications, and (4) his rejection occurred under circumstances that give rise to an inference of unlawful discrimination. See id. at 802.
Both parties agreed that Banks satisfied the first three requirements, but were at odds over the fourth. The district maintained that it had legitimate, nondiscriminatory reasons for rejecting Banks for the head coach positions. It claimed that it did not select Banks because each hiring committee ranked him lower than the hired applicant based upon his answers to a set of standardized questions. The court concurred that “the district’s proffered reason for not hiring Banks is legitimate and nondiscriminatory. Thus, the burden shifts back to Banks to demonstrate that its reason is merely a pretext for discrimination.”
Banks did just that, successfully arguing that the lower ranking “contradicts its assessments of his skills in other contexts.
“When deposed, four district administrators, each of whom served on one or more of the selection committees, cited two principal reasons why the committees ranked Banks lower. First, Banks’s communication skills were lacking. Second, Banks lacked the organizational skills necessary for a head coach position.
“Banks raises a genuine issue of material fact regarding the validity of these otherwise-neutral reasons by pointing to favorable evaluations of his organizational and communication skills by the district in the teaching context.”
The court added that “the positive evaluations of his organizational and communication skills that Banks received as a teacher raise doubt about the deposed administrators’ proffered reasons for not hiring him as a coach. Although the district may be right that the skills required in the classroom are not identical to the skills required in the sports arena, the district has not pointed to evidence currently in the record that justifies summary judgment based on that argument. At trial, the district will have an opportunity to develop the facts supporting its argument.”
John Banks v. Pocatello School District No. 25; D. Idaho; Case No. CV-04-125-E-BLW; 2006 U.S. Dist. LEXIS 26915; 4/25/06
Attorneys of Record: (for plaintiff) Gary L Cooper, James D Ruchti, Cooper & Larsen, Pocatello, ID; John B Ingelstrom, Racine Olson Nye Budge & Bailey, Pocatello, ID. (for defendant) Brian K Julian, Anderson Julian & Hull, Boise, ID; Paul J Stark, Boise, ID.
