A federal judge from the Western District of Arkansas has granted a school district’s motion for summary judgment in a case in which it was sued for employment discrimination.
The underlying incident involved plaintiff/employee Angelia Williams, who got into a verbal confrontation with a high school basketball coach in the Harmony Grove School District on June 15, 2023, and was subsequently suspended without pay.
The plaintiff sued, alleging that she was discriminated against based on her gender and retaliated against in violation of Title VII of the Civil Rights Act of 1964 (Title VII) and the Arkansas Civil Rights Act of 1993 (ACRA), Ark. Code Ann. § 16-123-101, et seq.
By way of background, the court noted the plaintiff was employed under two contracts with the school district. Under the first contract, Williams was employed as a reading interventionist aide in the special education department. Under the second contract, she was employed as a bus driver. On July 1, 2023, Williams was due to renew her contract as a special education aide.
On the day of the aforementioned incident, the plaintiff’s son, who was a student in the district, was attending a basketball camp sponsored by the district. Williams had volunteered to work at the gymnasium’s entry gate monitoring visitor passes and accepting money for the basketball camp. One of the people helping run the basketball camp was the high school boys’ basketball coach Eddie Potts (Coach Potts). That day, Williams confronted Coach Potts because she believed her minor son was being bullied by other students at the basketball camp and that Coach Potts was allowing it to happen.
During the confrontation, which occurred in front of 50 people, the plaintiff reminded Coach Potts of the state and federal regulations about bullying and suggested that he was aware of bullying incidents but chose not to do anything about them. Williams then stated that her son had been attending counseling because of the bullying. She further became belligerent in her language.
Later that night, Williams texted Coach Potts that “I am very sorry that I spoke to you in the manner I did. I know that was not the venue for me to speak with you, and certainly not an ugly manner.” Coach Potts then called the plaintiff. In the call, Williams told the coach that she still wanted to report the bullying students. She did so, contacting District Superintendent Albert L. Snow (Superintendent Snow). However, the district believed the plaintiff’s behavior was “unbecoming, unprofessional, disorderly based on her tone of voice, choice of words, disrespectful statements, and efforts to incite altercations between other adults.”
On June 20, 2023, Superintendent Snow sent Williams a Notice of Recommended Termination of Employment Contract because of her conduct on June 15, 2023. Superintendent Snow believed that the plaintiff’s conduct hampered her ability to effectively perform her job duties and warranted her termination. The plaintiff appealed the district school board.
On July 20, 2023, the board met and determined that Williams violated District Policy 8.45 Classified Personnel Code of Conduct. However, it declined to accept Superintendent Snow’s recommendation that she be terminated, and instead reduced the penalty to a one-semester suspension for the start of the 2023-2024 school year.
On February 7, 2024, Williams sued, alleging that the school district: (1) discriminated against her based on her gender in violation of Title VII and the ACRA; and (2) retaliated against her in violation of Title VII and the ACRA. On December 10, 2024, the district filed the instant motion for summary judgment.
In its discussion, the court considered whether the defendant is entitled to summary judgment as to the plaintiff’s gender discrimination claim; and (2) whether the defendant is entitled to summary judgment as to the plaintiff’s retaliation claim.
Regarding the gender discrimination claim, the court considered the burden-shifting framework established in McDonnell Douglas Corp. v. Green in order to establish a prima facie case of gender discrimination
To do so, she must demonstrate that: “(1) [she] is a member of a protected class; (2) [she] was qualified to perform her job; (3) [she] suffered an adverse employment action; and (4) [she] was treated differently from similarly situated males.” Hesse v. Avis Rent A Car Sys., Inc., 394 F.3d 624, 631 (8th Cir. 2005).
“The court will start with the fourth element of gender discrimination—whether the plaintiff is similarly situated to Coach Potts or the other male coaches,” it wrote. “If the plaintiff is unable to establish that she was similarly situated to the male coaches as she alleges, she will be unable to make a prima facie case for gender discrimination, and her claim will fail.”
The court dissected each contention from the plaintiff, finding that she “fails to provide evidence that she is similarly situated with the comparators in all relevant respects.” Further, she “does not share job duties with the comparators, she does not share a supervisor with the comparators, and she fails to show that they engaged in the same conduct without mitigating or distinguishing circumstances.”
Thus, even “viewing the facts presented by the plaintiff in the light most favorable to her as the non-moving party, a reasonable fact finder could not conclude that the plaintiff and the comparators were similarly situated. Thus, the plaintiff has failed to allege facts sufficient to support the fourth element of her prima facie discrimination claim, and her claim fails as a matter of law.”
In sum, “her claim for gender discrimination under Title VII and the ACRA must fail as a matter of law.”
As for the retaliation claim, The court considered whether Williams “was retaliated against when Defendant allegedly ignored her reports that her son was being bullied and replaced her job position when she was suspended, resulting in her constructive termination.”
The court found that Williams “failed to establish a claim for retaliation. The court first notes that the parties seem to presume that the plaintiff’s testimony during her appeal hearing regarding allegedly disparate treatment was protected activity under Title VII. Assuming, without determining, that the testimony was protected conduct, the plaintiff nonetheless fails to show that any adverse employment action taken against her was causally connected to that testimony or that she was constructively discharged. There is no evidence that the plaintiff’s first asserted means of retaliation, the defendant ignoring that students were bullying her son, had any bearing on her employment conditions and cannot be viewed as an adverse employment action.
“Next, there is no evidence that the defendant’s elimination of the plaintiff’s position as a special education aide was causally connected to her hearing testimony. The plaintiff’s testimony at the hearing occurred after the termination recommendation, demonstrating that an adverse employment action was sought prior to her testimony. Further, the plaintiff relies entirely on assumption when drawing a connection between her being replaced in her former special education position and her complaints of disparate treatment during the appeal hearing. That the change in position occurred after her testimony is insufficient on its own to create an inference of causality.”
The plaintiff also “failed to give the defendant reasonable time to resolve the alleged intolerable working condition—the loss of her position as a special education aide and prevention of employment in special education—before she resigned. It is undisputed that the plaintiff did not report to Superintendent Snow or the district school board and notify them of the intolerable working condition. The plaintiff attempts to argue that it would not have helped to speak with Superintendent Snow. However, ‘part of an employee’s obligation to be reasonable . . . is an obligation not to assume the worst and not jump to conclusions too fast.’ Hesse v. Avis Rent A Car Sys., Inc., 394 F.3d 624, 631 (8th Cir. 2005)
“Further, she provides no explanation for failure to notify the district school board. Thus, the court finds that the plaintiff failed to give the defendant a reasonable opportunity to resolve the problem which prevents her from alleging constructive discharge.”
Even if the plaintiff “could establish her prima facie case, she has failed to present any evidence that the defendant’s explanation for replacing her was pretextual. The defendant presents a legitimate reason for replacing her: that someone needed to work in that special education position during the plaintiff’s suspension and that it would be unreasonable and counterproductive to fire that individual after one semester. The plaintiff has provided no argument or evidence to dispute that explanation. Accordingly, the plaintiff has failed to establish a prima facie case of retaliation.”
Angelia Williams v. Harmony Grove School District; W.D. Ark.; Case No. 1:24-cv-01009; 2/27/25
