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Pleener v. New York City Board of Education
Citation: 311 F. App'x 479Docket: No. 07-4898-cv
Court: Court of Appeals for the Second Circuit; February 23, 2009; Federal Appellate Court
The judgment of the district court, dated October 10, 2007, is affirmed in favor of the defendant regarding Barbara Pleener's discrimination claim under Title VII and related laws. Pleener contends that her removal as principal of Beach Channel High School was racially motivated and that she was constructively discharged by the New York City Board of Education. The court reviews the summary judgment de novo, favoring the non-moving party. For Pleener to prevail, she must provide more than minimal evidence to counter the defendant’s claims. The district court's application of the McDonnell Douglas framework was scrutinized, particularly concerning the defendant’s nondiscriminatory rationale for Pleener's removal and whether it was pretextual. Pleener's arguments regarding the Board's assessment of her leadership and the school's status were insufficient to demonstrate that the Board's stated reasons were not genuinely held or that racial bias was the actual motive. The court clarified that merely showing the employer's decision was erroneous does not prove discrimination; rather, the focus is on whether discriminatory intent influenced the employer's actions. Pleener also argued that her replacement by an African-American principal indicated discriminatory intent. However, the court emphasized that the relevant inquiry is how the employer would have treated Pleener had she belonged to a different race, rather than comparing her treatment to that of others outside her racial group. Overall, the court found no basis to support a claim of racial discrimination in Pleener's case. Once the defendant provided a legitimate, non-discriminatory reason for Pleener's removal as principal, additional evidence beyond her replacement by a person of a different race was necessary for Pleener to prove intentional racial discrimination. Although the race of a replacement can suggest discrimination, it is neither sufficient nor necessary. Pleener contended that racial bias influenced the Board's decision to remove her, citing community resistance to a Caucasian principal. However, federal law prohibits discrimination based on race to cater to biases from clients or the community, as established in prior case law. The evidence did not support claims of such bias; instead, it indicated that Pleener's loss of authority was linked to the Board's prior dismissal of a popular African-American assistant principal for insubordination. Community objections were more about Pleener's disciplinary history than her race, and she failed to convincingly link any community sentiment to racial hostility. The Board's decision was portrayed as a reaction to Pleener’s inability to manage the perceived racial insensitivity rather than a reflection of racial bias against her. Regarding her constructive discharge claim, Pleener did not provide evidence that racial bias influenced her resignation. She suggested she felt pressured to resign due to financial constraints, which does not constitute a prima facie case of discriminatory constructive discharge. The court affirmed the district court's judgment, noting that Pleener did not contest the summary judgment on her other claims, including those under 42 U.S.C. § 1983 and retaliation, rendering those arguments waived.