Merrier A. Jackson Tartt v. Unified School District No. 475

Summary

The United States District Court for the District of Kansas grants Unified School District No. 475’s motion for summary judgment on remand in Merrier A. Jackson Tartt’s Title VII racial discrimination claim. The court concludes that, even considering the portions of an affidavit identified by the Tenth Circuit and additional evidence, Tartt failed to show that the stated reasons for nonrenewal of her contract were pretextual.

Holdings

1. Plaintiff failed to present evidence from which a reasonable factfinder could conclude that Defendant's legitimate, nondiscriminatory reasons for not renewing her contract were pretextual. Defendant was therefore entitled to summary judgment on the Title VII discrimination claim.
2. Plaintiff's failure to receive an evaluation while serving as an interim principal did not establish pretext because the identified white administrators were not similarly situated, and Plaintiff received an evaluation after becoming a regular principal.
3. The alleged racist comments did not create a genuine issue of material fact because Plaintiff failed to show that the speakers participated in the nonrenewal decision or that the comments were connected to that decision.

Questions Presented

1. Whether, after considering the previously disregarded portions of Toomey's affidavit and the remanded allegations concerning racism by Board members, Plaintiff presented sufficient evidence of pretext to avoid summary judgment on her Title VII racial-discrimination claim.
2. Whether differences in the timing and number of evaluations between Plaintiff and other administrators, inconsistencies in Board members' testimony, and alleged racist comments established a nexus between racial bias and the Board's decision not to renew Plaintiff's contract.

Disposition

other