Barnes v. Mayor & Aldermen of Savannah
| Decision Date | 19 November 2020 |
| Docket Number | CASE NO. CV419-048 |
| Parties | ANGELA R. BARNES, Plaintiff, v. THE MAYOR AND ALDERMEN OF THE CITY OF SAVANNAH, Defendant. |
| Court | U.S. District Court — Southern District of Georgia |
Before the Court is Defendant The Mayor and Aldermen of the City of Savannah's (the "City") Motion for Summary Judgment. (Doc. 37.) For the following reasons, the City's motion is GRANTED IN PART and DISMISSED IN PART.
Plaintiff Angela R. Barnes, a black female, alleges that the City discriminated and retaliated against her when it terminated her employment with the Recorder's Court of Chatham County. (Doc. 19.) Plaintiff worked as the Clerk of Recorder's Court from March2015 until her termination in September 2016. (Doc. 37, Attach. 1 at ¶¶ 14, 116; Doc. 53, Attach. 11 at ¶ 118.) In the following sections, the Court will describe Recorder's Court and its administrative issues; Plaintiff's duties as Clerk of Recorder's Court; issues between Plaintiff and Judge Claire Cornwell-Williams; the City's investigation of Plaintiff's conduct as Clerk; the Superior Court of Chatham County's intervention in the administration of Recorder's Court; and the circumstances surrounding Plaintiff's termination.
Recorder's Court serves as the court of first appearance for felonies and misdemeanors and the traffic court for the City of Savannah and the unincorporated area of Chatham County. (Doc. 43, Attach. 4 at 3.) Recorder's Court has three judges who are elected every four years. (Doc. 37, Attach. 1 at ¶ 1; Doc. 53, Attach. 11 at ¶ 1.) During the relevant time period, Judge Tammy Stokes, a black female, served as the Chief Judge of Recorder's Court. (Doc. 37, Attach. 1 at ¶ 2; Doc. 53, Attach. 11 at ¶ 2.) Judge Claire Cornwell-Williams, a white female, and Judge Harris Odell, Jr., a black male, served as the other two Recorder's Court judges. (Doc. 37, Attach. 1 at ¶ 3; Doc. 53, Attach. 11 at ¶ 3.)
It is undisputed that Recorder's Court has a history of interpersonal and administrative issues predating Plaintiff's employment. Stephanie Cutter, City Manager, stated that she "was aware oflongstanding issues and dysfunction within the Recorder's Court" and "significant tension (a 'feud') between Chief Judge Tammy Stokes and Judge Claire Cornwell-Williams which impacted the Recorder's Court employees and the operation of the court." (Doc. 39, Attach. 1 at ¶ 4.) Cutter also stated that throughout her tenure "the City Manager's office received a disproportionately high volume of complaints out of the Recorder's Court . . . ." (Id. at ¶ 7.)
During the time most relevant to this order, the City could not require changes within the Court, but the City and Chatham County worked with Chief Judge Stokes to make improvements to Recorder's Court.2 (Doc. 38, Attach. 3 at 2.) Because of the ongoing issues, Chief Judge Stokes sent a letter to Cutter on January 26, 2015 proposing that the administrative oversight of Recorder's Court be delegated to the Clerk of Recorder's Court, including "staff supervision, staff assignments, workload distribution and other administrative duties . . . ." (Doc. 39 at 2.) Chief Judge Stokes also proposed that "the Clerk's position, as in the past, come under the direct oversight of the City Manager's Office."3(Id.) The City agreed to this arrangement.4 (Doc. 39, Attach. 1 at ¶ 9.)
Plaintiff was hired as the Clerk of Recorder's Court on March 30, 2015. (Doc. 37, Attach. 1 at ¶ 14; Doc. 53, Attach. 11 at ¶ 14.) As Clerk, Plaintiff held the second highest position in the Court's chain of command, behind only the Judges.5 Plaintiff testified that, when she started as Clerk, "there were a lot of operational challenges," including "a lack of policies and procedures . . . ." (Doc. 39, Attach. 3 at 26, 28.) In Plaintiff's opinion, the source of the conflict seemed to be that "Judge Williams . . . wanted the court run one way, but Judge Stokes . . . wanted it run a different way." (Id. at 17.)
Plaintiff testified that one of her essential job functions was communicating regularly with the judges to facilitate court operations. (Doc. 39, Attach. 3 at 38.) Plaintiff was also responsible for communicating with court staff, attorneys, law enforcement, other courts, and the public about Recorder's Court matters. (Doc. 37, Attach. 1 at ¶ 24; Doc. 53, Attach. 11 at ¶ 24.) In addition to facilitating communication, Plaintiff was "[i]n charge of supervising staff in Recorder's Court . . . ." and hiring and firing Clerk's Office personnel. (Doc. 39, Attach. 3 at 61.)
Although Plaintiff testified that she worked with each Recorder's Court judge, Plaintiff believed that Chief Judge Stokes had supervisory authority over her. (Id. at 38.) Plaintiff attended meetings with all of the judges, but met with Chief Judge Stokes at least three times a week. (Doc. 37, Attach. 1 at ¶ 26; Doc. 53, Attach. 11 at ¶ 26; Doc. 39, Attach. 3 at 74, 96, 143.) During Plaintiff's tenure as Clerk, Shadavia Scott-Brown, a black female, served as Deputy Clerk of Recorder's Court. (Doc. 37, Attach. 1 at ¶ 83; Doc. 53, Attach. 11 at ¶ 83.)
Plaintiff and Judge Cornwell-Williams's relationship was contentious from the beginning of Plaintiff's employment. For example, in April 2015, not even a month into Plaintiff's employment, Plaintiff refused to meet with Judge Cornwell-Williams unless another judge or her Deputy Clerk attended the meeting. (Doc. 41 at 3, 5.) After Plaintiff refused to meet with her, JudgeCornwell-Williams sent an e-mail to Plaintiff, Cutter, and Sean Brandon, the City's Management Services Bureau Chief, stating that "it seems impossible for [Plaintiff] to do [her] job and for [them] to have a professional relationship when [Plaintiff] refuses to meet with [Judge Cornwell-Williams] without [] one of the other Judges present or [her] Chief Deputy Clerk." (Id. at 2.)
Another issue arose in June 2015 when Judge Cornwell-Williams asked Plaintiff to draft an order and Plaintiff refused. (Doc. 37, Attach. 1 at ¶ 39; Doc. 53, Attach. 11 at ¶ 39; Doc. 41, Attach. 1 at 3-5.) Judge Cornwell-Williams, in response, stated "the fact that you once again refuse to do a reasonable request from the Judge is just not acceptable." (Doc. 41, Attach. 1 at 2.) Cutter was copied into the e-mail exchange. (Id.)
In July 2015, Plaintiff and Judge Cornwell-Williams again had a frustrated e-mail exchange about scheduling and paying pro-tem judges.6 (Doc. 37, Attach. 1 at ¶ 43; Doc. 57, Attach. 11 at ¶ 43.) Judge Cornwell-Williams disagreed with Plaintiff's records documenting the use of pro-tem judges and requested that Plaintiff change the records to reflect that Judge Cornwell-Williams did not use a pro-tem judge on a certain day. (Doc. 41, Attach. 2 at 4.) In response, Plaintiff told Judge Cornwell-Williams that "[t]he Pro-Tem records will remain unchanged," that Plaintiff "will not respond to any further emails on this matter," and that JudgeCornwell-Williams "may discuss this issue with the Chief Judge." (Id.)
Later that month, Judge Cornwell-Williams e-mailed Plaintiff and requested that Plaintiff "provide [Judge Cornwell-Williams] with a copy of every contempt warrant withdrawal that [she] [has] authorized in the last year." (Doc. 41, Attach. 7 at 2.) Judge Cornwell-Williams asked Plaintiff to have the information on her desk by 3:00 P.M. and thanked Plaintiff for her cooperation. (Id.) In response, Plaintiff stated:
Based on the history of e-mails I have received from you, it seems that you are accustomed to treating the Clerk of Court with utter disrespect. . . . You may request information from me but you do not give me deadlines. Your request for copies of contempt warrants you have authorized for the last year is unduly burdensome and in any event will not be available.
(Id.) At one point in the exchange, Plaintiff also stated, (Id. at 6.)
In August 2015, Judge Cornwell-Williams sent an e-mail to Cutter, Brandon, and Beth Robinson, the City Human Resource Director, about an incident between Judge Cornwell-Williams and a Clerk's Office employee. (Doc. 41, Attach. 6 at 3-4.) Cutter forwarded the e-mail to Plaintiff, and, in response, Plaintiff explained her knowledge of the incident and noted that another employee had complained about "harassing treatment" from JudgeCornwell-Williams.7 (Id. at 3.) Cutter, in response, stated in part: (Id. at 2.)
The following day, Plaintiff sent another e-mail to Cutter that stated, in part:
I am becoming increasingly frustrated by Judge Williams [sic] actions which I believe rise to the level of judicial misconduct. In my opinion her daily actions are severely disrupting the Court and subjecting staff to inappropriate behavior. . . . I am willing to [initiate disciplinary action] provided that I will not be terminated or reprimanded for taking that course of action.
(Id.) In response, Cutter reiterated that "[i]t is not appropriate for you to address issues with Judge Williams" because "that is the role of the Chief Judge" and that Plaintiff should "forward in writing any issues related to [inappropriate] behavior by a [j]udge to the Chief Judge for resolution." (Id.)
In October 2015, Plaintiff e-mailed Cutter about Judge Cornwell-Williams's "conversations [with Plaintiff] about inappropriate matters . . . ." (Doc. 41, Attach. 11 at 2.) In the e-mail, Plaintiff described several statements allegedly made by Judge...
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