Blackmon v. Stewart County School District

Citations: 24 F. Supp. 3d 1273; 2014 U.S. Dist. LEXIS 75826; 123 Fair Empl. Prac. Cas. (BNA) 346; 2014 WL 2515228Docket: Case No. 4:13-CV-179 (CDL)

Court: District Court, M.D. Georgia; June 4, 2014; Federal District Court

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Scott Blackmon, a physical education teacher for the Stewart County School District, was terminated during a 2010 budget crisis following a recommendation by Superintendent Floyd Fort to eliminate one of the two physical education positions. Fort suggested Blackmon's position be cut because he lacked coaching or extracurricular duties, while the other teacher was involved in coaching football and baseball. Blackmon, who is white, alleges that his termination was racially motivated. The Court is currently considering the defendants' motion for summary judgment, which may be granted if no genuine dispute exists regarding material facts.

The factual background indicates Blackmon began his employment in 2005 and served as head football coach and later athletic director. However, dissatisfaction with his performance led to his removal from the athletic director position in 2009, with John Hamilton, who is black, taking over. Hamilton subsequently dismissed Blackmon as head football coach, citing poor team performance. Additionally, Blackmon faced issues regarding his teaching certification after failing a required computer competency test twice in 2009. The evidence presented must be viewed favorably for Blackmon when assessing the summary judgment motion.

Blackmon completed the required computer course at Columbus State University, but his online certification status indicated an expiration. After verifying with the Georgia Professional Standards Commission that his teaching certificate had been renewed, Blackmon was deemed eligible to continue teaching. In 2009, state funding cuts prompted the School District to eliminate 6.5 positions for the 2009-2010 school year, with further cuts anticipated for 2010-2011. Fort, responsible for the reduction-in-force, aimed to minimize harm to the instructional program and proposed eliminating five positions, including one physical education teacher role. The School District had two physical education teachers: Terry, who received positive evaluations and held coaching roles, and Blackmon, who had received several 'needs improvement' ratings and had no coaching duties. Fort chose to retain Terry to maintain continuity in the athletic programs, believing Blackmon's reassignment would not be beneficial due to his previous coaching record. The School Board unanimously approved the reduction plan on May 11, 2010, resulting in Blackmon's contract non-renewal. Although three teaching positions were available, including one in social studies, Blackmon did not apply due to lacking current certification in that subject, despite his belief he could have recertified. There was no evidence that Fort was aware of Blackmon's certification in any area other than health and physical education. Blackmon alleged that Viola Fedd, the middle school principal, harbored racially motivated bias against him, but he did not provide evidence linking Fedd to Fort's decision-making regarding his employment.

Blackmon alleges that his termination by Fort and the School District was racially motivated, violating Title VII of the Civil Rights Act of 1964. Lacking direct evidence of discrimination, he must utilize the McDonnell Douglas framework for proving discrimination through circumstantial evidence. To establish a prima facie case, Blackmon must show he belongs to a protected class, was terminated in a reduction in force, was qualified for his position, and that there are reasonable grounds to conclude discrimination occurred. Although the case is atypical, Blackmon satisfies the prima facie case criteria since he was a qualified member of a protected class whose position was eliminated. 

The School District claims its decision was based on budget cuts, retaining the teacher who also served as head coach for football and baseball. To demonstrate pretext, Blackmon must show the School District's reasons contain inconsistencies that could lead a reasonable factfinder to doubt their credibility. He acknowledges the justification for retaining the coaching teacher but contests his removal from the athletic director and head coach positions, arguing they were unjustified. However, Blackmon did not provide evidence of racial motivation for these removals, and the School District indicated that his removal was aimed at improving the athletic department's image and was due to poor team performance. Consequently, Blackmon's claims lack substantiation against the School District's articulated reasons.

The School District's decision to remove Blackmon from his football coaching role was deemed reasonable due to his lack of coaching responsibilities compared to Terry, the head coach of two teams. Blackmon failed to challenge the School District's legitimate, nondiscriminatory rationale for his termination. He attempted to prove intentional discrimination through three arguments: 

1. He claimed that Fort was targeting him due to an incident involving his teaching certificate, which Fort believed had expired. However, Fort did not take adverse action against Blackmon based on this incident, and it did not demonstrate discriminatory intent.
   
2. Blackmon suggested that Viola Fedd, the middle school principal, harbored racial bias against him. Nonetheless, statements from non-decisionmakers or unrelated remarks do not constitute direct evidence of discrimination, and Fedd was not involved in the decision-making process for Blackmon's employment issues.
   
3. Blackmon argued he should have been offered a social studies teaching position, but he did not apply for it and lacked the necessary certification. There was no evidence that Fort was aware of any potential for Blackmon to become eligible for that position.

The Court concluded that Blackmon did not present sufficient evidence to create factual disputes regarding his discrimination claims, leading to the granting of summary judgment for the defendants. Blackmon's failure to refute the defendants' facts as required further weakened his position. Additionally, he conceded that he had no age discrimination claim. Even if Blackmon contested Fort's credibility regarding the reasons for his removal as athletic director, no evidence supported that unlawful discrimination motivated the decision.