Searching over 5,500,000 cases.


searching
Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.

Boyd v. Randolph County Board of Education

United States District Court, M.D. Alabama, Eastern Division

December 20, 2017

SHAWANNA BOYD, Plaintiff,
v.
RANDOLPH COUNTY BOARD OF EDUCATION, Defendant.

          ORDER

          CLAY D. LAND U.S. DISTRICT COURT JUDGE

         Plaintiff Shawanna Boyd brought this race discrimination and retaliation action against her employer, the Randolph County Board of Education (“School District”), under 42 U.S.C. § 1981 and Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e et seq. (“Title VII”). The School District moved for summary judgment on all of Boyd's claims, and the Magistrate Judge issued a Report and Recommendation recommending that the summary judgment motion be granted. R. & R., ECF No. 44. The Court reviewed this matter de novo and concludes that summary judgment should be granted on all of Boyd's claims except her retaliation claim based on the removal of her pre-kindergarten director duties. Accordingly, the Magistrate's recommendation to grant summary judgment is adopted as modified for the reasons explained below, except as to that one claim.

         STANDARD OF REVIEW

         The Court designated the Magistrate to submit proposed findings of fact and recommendations for the disposition of any pretrial motions in this case. The Magistrate recommended that Defendant Randolph County Board of Education's summary judgment motion be granted. See generally R. & R. Plaintiff Shawanna Boyd filed an objection to the Magistrate's recommendation. Pl.'s Obj. to Recommendation of the Magistrate, ECF No. 45. The Court “shall make a de novo determination of those portions of the report or specified proposed findings or recommendations to which objection is made.” 28 U.S.C. § 636(b)(1). For those findings and recommendations to which objections were not asserted, the district courts generally conduct a plain error review. Cf. United States v. Slay, 714 F.2d 1093, 1095 (11th Cir. 1983) (“The failure to object to the magistrate's findings of fact prohibits an attack on appeal of the factual findings adopted by the district court except on grounds of plain error or manifest injustice.”). The Court “may accept, reject, or modify, in whole or in part, the findings or recommendations made by the magistrate judge.” 28 U.S.C. § 636(b)(1).

         SUMMARY JUDGMENT STANDARD

         Summary judgment may be granted only “if the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.” Fed.R.Civ.P. 56(a). In determining whether a genuine dispute of material fact exists to defeat a motion for summary judgment, the evidence is viewed in the light most favorable to the party opposing summary judgment, drawing all justifiable inferences in the opposing party's favor. Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 255 (1986). A fact is material if it is relevant or necessary to the outcome of the suit. Id. at 248. A factual dispute is genuine if the evidence would allow a reasonable jury to return a verdict for the nonmoving party. Id.

         FACTUAL BACKGROUND

         Plaintiff Shawanna Boyd does not appear to object to any of the Magistrate's factual findings. Rather, her objections are based on how the Magistrate applied the law to the facts. Therefore, the Court adopts the findings of fact as set forth by the Magistrate and discusses the relevant facts below.

         DISCUSSION

         I. Boyd's Race Discrimination Claims

         Title VII and § 1981 both prohibit employment discrimination on the basis of race. See 42 U.S.C. § 2000e-2(a)(1) (prohibiting racial discrimination with respect to the terms and conditions of employment); 42 U.S.C. § 1981(a) (prohibiting racial discrimination in the making and enforcement of contracts). To survive summary judgment in a race discrimination case under either statute, the plaintiff must produce enough evidence for a reasonable juror to conclude that her employer took an adverse employment action against her that was motivated by her race. Cf. Standard v. A.B.E.L. Servs., Inc., 161 F.3d 1318, 1330 (11th Cir. 1998) (noting that Title VII and § 1981 “have the same requirements of proof and use the same analytical framework” for discrimination claims). Boyd contends that the School District denied her two promotions because of her race: the promotion to Special Education Coordinator and the promotion to Curriculum Coordinator. The Court will address each claim in turn.

         A. Promotion to Special Education Coordinator

         Boyd, who is black, claims that she was not promoted to Special Education Coordinator because of her race. The Magistrate concluded that Boyd did not point to enough evidence to create a genuine fact dispute on this claim. Boyd asserts that the Magistrate erred in two ways. First, Boyd argues that the Magistrate erred in finding that she had not presented direct evidence of discrimination. Second, Boyd contends that the Magistrate erred in concluding that she had not presented sufficient evidence to survive summary judgment under the framework established in McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973), and Texas Department of Community Affairs v. Burdine, 450 U.S. 248 (1981).

         Direct evidence of discrimination is “evidence from which a reasonable trier of fact could find, more probably than not, a causal link between an adverse employment action and a protected personal characteristic.” Wright v. Southland Corp., 187 F.3d 1287, 1298 (11th Cir. 1999).[1] In other words, direct evidence is “evidence which reflects ‘a discriminatory or retaliatory attitude correlating to the discrimination or retaliation complained of by the employee.'” Wilson v. B/E Aerospace, Inc., 376 F.3d 1079, 1086 (11th Cir. 2004) (quoting Damon v. Fleming Supermarkets of Fla., Inc., 196 F.3d 1354, 1358 (11th Cir. 1999)).

         Boyd contends that the following evidence is “direct evidence” of race discrimination: (1) she was not considered for the Special Education Coordinator position until she complained; (2) the application process was restarted after the special education committee determined that the original three finalists did not have enough experience with the state's special education paperwork; and (3) the job description was modified to remove the certification of administration/supervision requirement and add the requirement that candidates to have knowledge of special education laws, process, and the computer tracking system. None of these statements reflects a racially discriminatory attitude correlating to the Special Education Coordinator decision. The Magistrate did not err in concluding that this evidence is not direct evidence of discrimination.

         Without direct evidence of discrimination, Boyd must prove her discrimination claim using the framework established in McDonnell Douglas and Burdine. E.g., Alvarez v. Royal Atl. Developers, Inc., 610 F.3d 1253, 1264 (11th Cir. 2010). Under that framework, the plaintiff must establish a prima facie case of discrimination. Id. If she does that, then the employer may articulate a legitimate nondiscriminatory reason (or reasons) for its employment decision. Id. If the employer proffers a legitimate nondiscriminatory reason for its decision, then the plaintiff must show that the proffered reason is a pretext for discrimination. Id.

         Here, the Magistrate found that Boyd did not establish a prima facie case of discrimination. In the failure-to-promote context, a plaintiff may establish a prima facie case by showing that (1) she belonged to a protected class, (2) she was qualified and applied for a position her employer was seeking to fill, (3) she was rejected, and (4) the position was filled with a person outside her protected class. Vessels v. Atlanta Indep. Sch. Sys., 408 F.3d 763, 768 (11th Cir. 2005). It is undisputed that Boyd belonged to a protected class, that she was not promoted to Special Education Coordinator, and that the position was filled with a white person named Beth Bailey. The Magistrate concluded, however, that Boyd was not qualified for the position because she did not have a Master's Degree in Special Education, which was a requirement for the position. Boyd did not submit evidence to demonstrate that a Master's Degree in Special Education was not a legitimate requirement for the Special Education Coordinator job. Therefore, Boyd was not qualified for the Special Education Coordinator job, and the School District is entitled to summary judgment on this claim.

         Even if the Court were to conclude that a Master's Degree in Special Education was not actually required (as Boyd argues it was not), her claim still fails because she did not present enough evidence to show pretext. Boyd may demonstrate that the School District's reasons for hiring Bailey were pretextual by revealing “such weaknesses, implausibilities, inconsistencies, incoherencies or contradictions in [the School District's] proffered legitimate reasons for its actions that a reasonable factfinder could find them unworthy of credence.” Springer v. Convergys Customer Mgmt. Grp. Inc., 509 F.3d 1344, 1348 (11th Cir. 2007) (quoting Cooper v. Southern Co., 390 F.3d 695, 725 (11th Cir. 2004)). “In the context of a promotion, ‘a plaintiff cannot prove pretext by simply arguing or even by showing that he was better qualified than the [person] who received the position [s]he coveted.'” Id. at 1349 (first alteration in original) (quoting Brooks v. Cty. Comm'n of Jefferson Cty., 446 F.3d 1160, 1163 (11th Cir. 2006)). And, “[a] plaintiff must show not merely that the defendant's employment decisions were mistaken but that they were in fact motivated by race.” Id. (quoting Brooks, 446 F.3d at 1163). Finally, “a plaintiff must show that the disparities between the successful applicant's and [her] own ...


Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.