Knighton v. Laurens County School Dist. No. 56, 82-1801

Decision Date14 November 1983
Docket NumberNo. 82-1801,82-1801
Parties33 Fair Empl.Prac.Cas. 299, 32 Empl. Prac. Dec. P 33,910, 14 Ed. Law Rep. 928 Lewis J. KNIGHTON, Appellant, v. The LAURENS COUNTY SCHOOL DISTRICT NO. 56 and Charles L. Cummins, Jr., Appellees.
CourtU.S. Court of Appeals — Fourth Circuit

Theo W. Mitchell, Greenville, S.C. (Fletcher N. Smith, Jr., Greenville, S.C., on brief), for appellant.

James L. Edwards, Clinton, S.C. (Edwards & Howe, Clinton, S.C., on brief), for appellees.

Before WINTER, Chief Judge, HALL, Circuit Judge, and KNAPP, * Senior District Judge.

HARRISON L. WINTER, Chief Judge:

The sole issue on appeal is whether the district court erroneously failed to require defendants to rebut by "clear and convincing" evidence Lewis J. Knighton's prima facie case that he was a victim of race discrimination violating 42 U.S.C. Secs. 1981 and 1983. The district court allowed defendants to rebut by merely articulating a legitimate non-discriminatory justification for Knighton's dismissal as an elementary school principal, applying the usual Burdine 1 sequence of proof, with the ultimate burden of persuasion on the plaintiff. We agree with Knighton that the wrong burden may have been applied. However, because the district court failed to make a crucial finding which would determine the correct burden of proof that defendants must meet, we remand the case for further proceedings.

I.

Lewis J. Knighton, who holds a Master of Science degree in education from South Carolina State A & M College, had thirty-one years of full-time teaching or administrative experience as of the 1978-79 school year. For twenty-seven of those years he had worked in the Laurens County School District No. 56 (District 56), including eighteen years as principal of an all-black elementary school in the previously racially segregated school system. Immediately following unification of the school district, Knighton was reassigned for three years to an assistant principalship. By the time of the termination complained of, Knighton had been principal of another District 56 school, the M.S. Bailey Elementary School, for five years.

District 56 had remained segregated until sometime during the school year 1970-71. At the end of that year, Dr. Charles L. Cummins, Jr. took over as Superintendent of Schools for the district. He continued in that role, as Knighton's superior, through all times relevant to this suit. On February 5, 1979, Cummins directed a memorandum to Knighton outlining five areas Cummins considered deficient in Knighton's performance. 2 By May 3, 1979, Cummins had decided that Knighton's performance was not improved, and by letter of that date Cummins notified Knighton that he would not recommend his reemployment for the following school year. The county school board accepted Cummins' recommendation so that Knighton's principalship contract was not renewed for 1979-80. Following an appeal hearing before the Board, however, he was permitted to sign a one year non-renewable contract as an assistant to the district's truant officer, apparently an accommodation designed to allow Knighton to complete sufficient years of service so as to qualify for retirement benefits.

Knighton subsequently brought this suit, alleging that he had been singled out for special supervision and adverse treatment because he is black. He further alleged that, under Cummins' direction, the school district since desegregation had treated other black administrative personnel and teachers less favorably than whites, and that a disproportionate number of blacks had as a consequence been terminated.

At trial before a magistrate, Knighton introduced evidence in support of these allegations attempting to show that a pattern of discrimination against black school personnel had developed. Knighton recalled a total of six "excellent" black teachers discharged by Cummins between 1972 and 1977. He testified that Cummins and other district officials attempted to pressure him into "intimidating" one of these teachers into resigning, and that when she finally did, she was replaced by a white teacher. Knighton further explained that while white principals typically were permitted to use "short form" teacher evaluation reports for white subordinates, reports that were simple to prepare and that by their use indicated that the teacher in question was basically performing well, black principals were instructed to use a "long form" that was needlessly detailed, time-consuming to prepare, and implied that the evaluated black teacher had performance problems requiring careful monitoring. As another illustration of discriminatory treatment, Knighton testified that although a black teacher had been denied a relatively routine release from her contract to provide her enough time to find a job in another school district, white teachers were typically granted such releases.

Although the issue was plainly raised, neither the magistrate nor the district court made any finding for or against Knighton as to whether there was in fact a pattern of discriminatory treatment of black personnel following unification of the school system. Instead, they confined their analysis of the evidence to the burden-shifting sequence set out in Burdine, 450 U.S. at 248, 101 S.Ct. at 1091, with the ultimate burden of persuasion on plaintiff. Accordingly, the magistrate first concluded that Knighton had established a prima facie case of...

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7 cases
  • Lujan v. Franklin County Bd. of Educ., 84-5397
    • United States
    • U.S. Court of Appeals — Sixth Circuit
    • 17 Junio 1985
    ...of a prima facie case. Lujan cites numerous cases to support this proposition. See, e.g., Knighton v. Laurens County School District No. 56, 721 F.2d 976, 978 (4th Cir.1983); Harris v. Birmingham Board of Education, 712 F.2d 1377, 1383 (11th Cir.1983); Evans v. Harnett County Board of Educa......
  • Love v. Alamance County Bd. of Educ., C-79-456-G.
    • United States
    • U.S. District Court — Middle District of North Carolina
    • 29 Febrero 1984
    ...of the Fourth Circuit in Evans v. Harnett County Board of Education, 684 F.2d 304 (4th Cir.1982) and Knighton v. Laurens County School District No. 56, 721 F.2d 976 (4th Cir.1983) the burden of persuasion must shift to the defendant to prove that its actions were not motivated by sexual or ......
  • Ardrey v. United Parcel Service
    • United States
    • U.S. Court of Appeals — Fourth Circuit
    • 18 Agosto 1986
    ...720 F.2d 326 (4th Cir.1983), cert. denied, 466 U.S. 951, 104 S.Ct. 2154, 80 L.Ed.2d 539 (1984), and Knighton v. The Laurens School District, 721 F.2d 976 (4th Cir.1983). The district court subsequently modified its order and compelled UPS to provide the names of those in the Charlotte offic......
  • Love v. Alamance County Bd. of Educ.
    • United States
    • U.S. Court of Appeals — Fourth Circuit
    • 27 Marzo 1985
    ...If, in fact, the Board recently had operated a discriminatory system, this would be a valid argument. See Knighton v. Laurens County School District No. 56, 721 F.2d 976 (4th Cir.1983); Evans v. Harnett County Board of Education, 684 F.2d 304 (4th Cir.1982). The record, however, does not su......
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