Oscar Brownfield v. Cherokee County School District No. 35 a/k/a Tahlequah Public Schools, Leon Ashlock, Mat Cloud, and Deann Mashburn

Summary

The United States District Court for the Eastern District of Oklahoma addresses cross-motions for summary judgment in Oscar Brownfield’s action against Tahlequah Public Schools and individual defendants. The court grants defendants’ motion on all claims except Brownfield’s Title IX retaliation claim against the school district, based on factual disputes concerning his coaching position and substitute-teacher status, and denies Brownfield’s motion. The court holds his Rule 11 sanctions motion in abeyance pending a show-cause hearing.

Holdings

1. Summary judgment was denied because genuine disputes of material fact remained regarding whether TPS influenced or controlled Brownfield's removal from the youth wrestling coaching position and whether and why TPS personnel removed him from the substitute-teacher list after his protected Title IX activity.
2. The October 2019 letter, which addressed Brownfield's requested board meeting and warned him about conduct toward school staff, was not a materially adverse action because it would not dissuade a reasonable person from engaging in protected activity.
3. TPS was entitled to summary judgment on the Title VII retaliation claim because Brownfield failed to show that TPS's legitimate, nondiscriminatory reasons for not interviewing or hiring him were pretextual.
4. TPS and the individual defendants were entitled to summary judgment on Brownfield's First Amendment claims because the undisputed facts did not show an injury that would chill a person of ordinary firmness from continuing to engage in protected activity.
5. Ashlock, Cloud, and Mashburn were entitled to qualified immunity because Brownfield failed to establish that they violated a constitutional or statutory right.

Questions Presented

1. Whether genuine disputes of material fact precluded summary judgment on Brownfield's Title IX retaliation claim based on his alleged removal from the youth wrestling coaching position and the TPS substitute-teacher list.
2. Whether the October 2019 letter, standing alone, constituted a materially adverse action for purposes of Title IX retaliation.
3. Whether TPS was entitled to summary judgment on Brownfield's Title VII retaliation claim arising from his nonselection for a 2021 teaching and coaching position.
4. Whether Brownfield established the elements of First Amendment retaliation under 42 U.S.C. § 1983 against TPS and the individual defendants.
5. Whether the individual defendants were entitled to qualified immunity.

Disposition

other