Giles v. Shaw Sch. Dist.
| Decision Date | 12 March 2015 |
| Docket Number | Civil Action No. 4:14–CV–00024–SA–JMV. |
| Citation | 92 F.Supp.3d 533 |
| Parties | Sharita GILES, Plaintiff v. SHAW SCHOOL DISTRICT, et al., Defendants. |
| Court | U.S. District Court — Northern District of Mississippi |
John M. Mooney, Jr., Law Offices of John M. Mooney, Jr., PLLC, Madison, MS, for Plaintiff.
Willie Griffin, Bailey & Griffin, Greenville, MS, for Defendants.
Plaintiff Sharita Giles initiated this lawsuit against her former employer Shaw School District (“SSD”) and members of its School Board, alleging gender discrimination, deprivations of substantive and procedural due process, and violations of the Equal Protection Clause. In a related and ongoing action in the Chancery Court of Bolivar County, Mississippi, Giles has appealed SSD's decision not to renew her employment. In view of these parallel proceedings, SSD has filed a Motion to Abstain and to Stay [8]. Upon consideration of the motion, responses, rules, and authorities, the Court finds as follows:
Facts and Procedural History
Giles began her employment as Principal of McEvans School in the Shaw County, Mississippi School District in 2008. Giles alleges that, in November 2012, the District Superintendent, Dr. Cederick Ellis, recommended to the School Board that all of the District's administrators receive pay raises for the upcoming year. According to Giles, the School Board approved a raise for a male principal within the District, but declined to authorize a raise for her. Based on this decision, Giles filed a charge with the Equal Employment Opportunity Commission (“EEOC”), alleging sex-based discrimination. The following February, according to Giles, Ellis recommended that the Board renew Giles' employment as Principal of McEvans. However, the School Board again declined to adopt Ellis's recommendation and voted by a count of three to two not to renew Giles' employment. She then filed another charge with the EEOC, alleging that her non-renewal was effectuated in retaliation for her initial charge of sex discrimination.
Following the non-renewal, Giles requested and received a hearing before the School Board, pursuant to Mississippi's School Employment Procedures Law. See Miss.Code Ann. § 37–9–111. The Board voted (again three to two) to uphold its original non-renewal decision, at which time Giles filed a third charge with the EEOC, reiterating allegations of sex discrimination and retaliation. Giles also timely appealed the Board's decision to the Bolivar County Chancery Court, which has jurisdiction pursuant to Mississippi Code Section 37–9–13 to determine whether the School Board's non-renewal should be overturned. Oral arguments were heard in the Chancery Court on March 21, 2014, and a resolution is pending.
After her appeal to the Chancery Court, Giles initiated this action against SSD and the Board Members involved in the decisions not to give her a raise and not to renew her employment. She seeks compensation and equitable relief from SSD under Title VII on the basis of sex discrimination and retaliation; declaratory relief and injunctive relief against the Board Members in their official capacities to remedy alleged violations of due process and equal protection; and damages from the Board Members in their individual capacities pursuant to 42 U.S.C. § 1983. SSD has filed the pending motion, requesting the Court to abstain from exercising jurisdiction over Giles' claims for declaratory and injunctive relief under to Younger v. Harris, 401 U.S. 37, 91 S.Ct. 746, 27 L.Ed.2d 669 (1971), and to stay Giles' claims for damages.
A federal court should abstain under Younger when “assumption of jurisdiction by a federal court would interfere with pending state proceedings....” La. Debating & Literary Ass'n v. City of New Orleans, 42 F.3d 1483, 1489 (5th Cir.1995) (citation and quotation omitted). Although the Younger doctrine originally only required courts to abstain from interfering with state criminal prosecutions, it now applies to civil proceedings as well “if the State's interests in the proceeding are so important that exercise of the federal judicial power would disregard the comity between the States and the National Government.” Health Net, Inc. v. Wooley, 534 F.3d 487, 494 (5th Cir.2008) (quoting Pennzoil Co. v. Texaco Inc., 481 U.S. 1, 10–11, 107 S.Ct. 1519, 95 L.Ed.2d 1 (1987) ). In cases to which Younger applies, the Court must abstain from exercising jurisdiction over claims of declaratory or injunctive relief. La. Debating & Literary Ass'n, 42 F.3d at 1489. The Fifth Circuit has held, however, that Younger is not applicable to requests for monetary relief, although the Court may have discretion to stay the damage claims when abstention would otherwise be appropriate. Lewis v. Beddingfield, 20 F.3d 123, 125 (5th Cir.1994) ; see also Floyd v. Amite Cnty. Sch. Dist., 376 F.Supp.2d 693, 697 (S.D.Miss.2005).
In its most recent published opinion arising under the Younger doctrine, the Fifth Circuit stated that abstention is generally required if three conditions are met: (1) the related state action must qualify as an “ongoing judicial proceeding”; (2) the state must have an important regulatory interest in the subject matter of the federal claim, and (3) the plaintiff must be afforded “an adequate opportunity in the state proceedings to raise constitutional challenges.” Bice v. La. Public Defender Bd., 677 F.3d 712, 716 (5th Cir.2012) (quoting Middlesex Cnty. Ethics Committee v. Garden State Bar Ass'n, 457 U.S. 423, 432, 102 S.Ct. 2515, 73 L.Ed.2d 116 (1982) ).
The United States Supreme Court, however, has since had occasion to clarify the applicability of these three “Middlesex conditions.” Sprint Commc'ns, Inc. v. Jacobs, ––– U.S. ––––, 134 S.Ct. 584, 593, 187 L.Ed.2d 505 (2013). The Supreme Court in Sprint explained that “[t]he three Middlesex conditions ... were not dispositive; they were, instead, additional factors appropriately considered by the federal court before invoking Younger .” Id. at 593 (emphasis in original). The Court shifted the focus by instructing lower courts to only employ Younger abstention when state proceedings present one of three “exceptional circumstances.” Id. These circumstances are (1) “ongoing criminal prosecutions[,]” (2) “civil enforcement proceedings[,]” and (3) “civil proceedings involving certain orders ... uniquely in furtherance of the state courts' ability to perform their judicial functions.” Id. (alteration in original). Thus, in light of the Supreme Court's holding in Sprint, the Court must consider whether Giles' non-renewal appeal fits into one of these three enumerated categories. Because this question is easily resolved as to the first and third categories, the Court will address them briefly before proceeding to discussion of the second category.
The first category that requires abstention is reserved for cases in which there is a related pending state criminal proceeding like in Younger itself. Id. Giles has been subject to no criminal prosecution or threat of prosecution. Rather, the Chancery Court proceeding is civil in nature. Thus, the first category from Sprint is clearly inapplicable.
The third category is limited to cases where the federal plaintiff's challenge implicates the judicial function, such as the issuing of orders or the rendering of judgments. See id. ; see also Juidice v. Vail, 430 U.S. 327, 336–38 & n. 12, 97 S.Ct. 1211, 51 L.Ed.2d 376 (1977) (); Pennzoil, 481 U.S. at 13–14, 107 S.Ct. 1519 (). In this case, Giles has challenged the School Board's conduct, not a judicial order, judgment, or anything else related to the state court's judicial function. The Court therefore finds the third category to be inapplicable.
Thus, for abstention to be appropriate, this case must fall within the second exceptional circumstance from the three enumerated in Sprint. Within this category, Younger abstention is generally appropriate if there is a state civil enforcement proceeding that is “ ‘akin to a criminal prosecution’ in ‘important respects.’ ” Sprint, 134 S.Ct. at 592 (quoting Huffman v. Pursue, Ltd., 420 U.S. 592, 598, 95 S.Ct. 1200, 43 L.Ed.2d 482 (1975) ). The Supreme Court has provided three hallmarks that characterize such enforcement proceedings. Id. First, “a state actor is routinely a party to the state proceeding and often initiates the action.” Id. (citations omitted). Second, “[i]nvestigations are commonly involved, often culminating in the filing of a formal complaint or charges.” Id. Third, such a proceeding is “characteristically initiated to sanction the federal plaintiff.” Id.
Applying these hallmarks to the present case, a state actor, SSD, is named as the defendant in the Bolivar County Chancery Court, but it was Giles who initiated the action by seeking a hearing with the School Board pursuant to Mississippi Code Section 37–9–111, and by appealing the Board's decision to Chancery Court under Section 37–9–113. Additionally, Giles has not been the target of an investigation, nor have there been any charges levied against her. And third, the purpose of the Chancery proceeding is not to punish or sanction Giles. Rather, Giles is the party seeking recourse. Therefore, of the traits that identify whether a civil enforcement proceeding is “akin to a criminal prosecution,” the Court finds none to be present here. See Sprint, 134 S.Ct. at 592, 187 L.Ed.2d 505.
Indeed, the absence of these traits creates a stark contrast between Giles' non-renewal appeal and the state proceedings involved in cases in which the Supreme Court has held that civil enforcement proceedings warranted abstention. See Middlesex, 457 U.S. at...
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