Vinova v. Henry Cnty. Bd. of Educ.
| Decision Date | 15 September 2016 |
| Docket Number | Civil No. 15-37-GFVT |
| Parties | AMANDA VINOVA, Plaintiff, v. HENRY COUNTY BOARD OF EDUCATION, Defendant. |
| Court | U.S. District Court — Eastern District of Kentucky |
Plaintiff Amanda Vinova taught at New Castle Elementary School in Henry County, Kentucky, during the 2010-2014 school years. During the spring of 2013, Vinova married her same-sex partner, Lauren Hale, who also taught at New Castle Elementary. The next year, in May 2014, Vinova learned that her one-year contract would not be renewed for the 2014-2015 school year. Vinova subsequently brought suit against the Henry County Board of Education and other related entities, alleging violations of Title VI, KRS § 344.040, Title VII, and Title IX. Presently before the Court is the Henry County Board of Education's motion for summary judgment, which, for the reasons set forth below, is GRANTED.
The parties appear to agree on the basic factual background.1 Amanda Vinova taught fourth grade at New Castle Elementary in Henry County, Kentucky, during the school years of2010-2014. [R. 1-1 at 4.] During that time period, Defendant Henry County Board of Education (the Board) was the entity responsible for the administration of the public schools in Henry County. [Id. at 3.] Lauren Hale also taught at New Castle Elementary during the time that Vinova worked there. Hale and Vinova were married in New York on May 18, 2013.2 [R. 20-3 at 5.] At some point before January 2013, Hale allegedly sent a notification to the interim principal Staci Hoene, announcing her wedding engagement to Vinova.3 [R. 1-1 at 4.] In January 2013, Hoene apparently included the wedding engagements of other teachers at the school in a public announcement but did not include the engagement of Vinova and Hale.4 On January 9, 2013, Hale sent an e-mail to Hoene, informing her that she and Vinova planned to get married on May 18, 2013, and that they were "hurt when you made a point to mention every faculty member that was getting married except us." [R. 19-5.] Ms. Hoene responded the same day and apologized, stating that she was unaware of Vinova's engagement and any omission was unintentional. [Id.] At some point later on, and before Vinova and Hale's wedding, the school had a bridal shower for them, and several staff members gave them gifts and cards, although Vinova does not recall who organized or attended the shower. [R. 20-3 at 8-9.]
Vinova alleges that after her marriage to Hale, she was treated differently and unfairly because of their same-sex relationship. In her deposition, Vinova testified that although otherstaff members did not make any overtly negative comments to her, she felt she was ignored and unwanted. [R. 20-3 at 9-10.] As further evidence of allegedly disparate treatment, Vinova contends that she was required to submit new social security cards in order to have her married name listed on her name plate, even though she believed other teachers who were married that same year did not have to submit similar documentation. [R. 1-1 at 4; R. 20-3 at 15-16.]
On June 30, 2013, after Vinova and Hale's wedding, Vinova signed a one-year contract of employment for the 2013-2014 school year. Vinova testified that during the 2013-2014 school year, she had "all good reviews in all of the areas" in which she was evaluated, and the principal at the time referred to her as "phenomenal."5 [R. 20-3 at 8.] Vinova also testified that during that same year, she and another teacher organized an Energy Team Project for some fourth-grade students that won a nationally recognized competition. [Id.] According to Vinova, although it was her "innovative idea" for the project, her name and contributions were deliberately omitted from the announcement about the project that was posted on the school's website. [R. 1-1 at 4; R. 20-3 at 24.] When she e-mailed Principal Eric Davis about the omission, however, he had it rewritten to include her. [R. 19-7, R. 19-8.]
Despite Vinova's apparent success as a teacher, the Superintendent of the Board, Tim Abrams, decided not to renew her contract for the 2014-2015 school year. [R. 19-3; R. 19-1 at 3.] Abrams also chose not to renew the contract of another teacher, Melissa Michael. [R. 19-1 at 3.] According to the Board, the school district anticipated a decline in enrollment in the numberof students attending New Castle Elementary in 2014. [R. 19-3; R. 19-1 at 3.] The Board claims that at that time there were ten non-tenured teachers at New Castle whose contracts required yearly renewal, and Principal Eric Davis recommended that the Board respond to the enrollment problem by not renewing the contracts for Michael and Vinova.6 [R. 19-3; R. 19-1 at 3.] Abrams then drafted a letter informing Vinova that her contract would not be renewed for the school year of 2014-2015, and Principal Eric Davis presented that letter to her on May 2, 2014. [R. 19-3; R. 19-9; R. 20-3 at 17-19.] The letter did not give any reasons for the non-renewal, and Vinova testified that Davis told her she could ask Abrams about it in writing if she wanted to know the reasons for it. [R. 19-9; R. 20-3 at 19.] Vinova further testified that she never asked Abrams for an explanation, and that Davis said he could not discuss it with her. [R. 20-3 at 19-20.] Vinova's wife, Lauren Hale Vinova, also had a contract that required yearly renewal, and Abrams chose to renew that contract for the 2014-2015 school year. [R. 19-3 at 3.]
Vinova's Complaint alleges that other teaching positions within New Castle Elementary "were available" but "none were offered" to Vinova. [R. 1-1 at 4.] In Vinova's affidavit, she further alleges that two weeks after her termination, another teaching position opened for which she applied but was not given the opportunity to interview. [R. 20-1 at 2.] According to Vinova, the person who was hired for that position was an assistant teacher who "had not been a full-time teacher," and therefore Vinova claims she would have been the preferred candidate if not for the Board's discrimination against her. [Id.] Principal Davis concedes that a position to teach first grade came open, and that he knew Vinova applied for the position, but he states that he believedthe other candidate was a better fit because of her experience teaching the same children who would be moving into the first grade that year. [R. 22-1.]
Vinova subsequently brought suit against the Board, and several other Defendants, alleging that she was wrongfully terminated and discriminated against on the basis of her gender, her sexual orientation, and because of her same-sex marriage. [R. 1-1 at 5-7.] Although Vinova originally brought suit in Henry Circuit Court, the Defendants properly removed the case to federal court on the basis of federal question jurisdiction. [R. 1.] On November 24, 2015, this Court granted the Defendants' partial motion to dismiss Vinova's claims against all Defendants except the Henry County Board of Education, finding that Vinova's claims cannot be brought against individuals, and that New Castle Elementary is not a legal entity that can be sued. [R. 13 at 10-11.] The Board now argues it is entitled to summary judgment on all of Vinova's claims because no genuine issue of material fact exists such that a jury could find in Vinova's favor.
In addressing the remaining state law claims, because Kentucky is the forum state, the Court will use Kentucky's substantive law. Rawe v. Liberty Mut. Fire Ins. Co., 462 F.3d 521, 526 (6th Cir. 2006) (citations omitted). However, federal procedural law will govern as applicable, including in establishing the appropriate summary judgment standard.7 Weaver v. Caldwell Tanks, Inc., 190 F. App'x 404, 408 (6th Cir. 2006).
Summary judgment is appropriate when the pleadings, discovery materials, and other documents in the record show "that there is no genuine dispute as to any material fact and themovant is entitled to judgment as a matter of law." Fed. R. Civ. P. 56(a); Celotex Corp. v. Catrett, 477 U.S. 317, 323-25 (1986). "A genuine dispute exists on a material fact, and thus summary judgment is improper, if the evidence shows 'that a reasonable jury could return a verdict for the nonmoving party.'" Olinger v. Corp. of the Pres. of the Church, 521 F. Supp. 2d 577, 582 (E.D. Ky. 2007) (quoting Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 255 (1986)). The moving party has the initial burden of demonstrating the basis for its motion and identifying those parts of the record that establish the absence of a genuine issue of material fact. Chao v. Hall Holding Co., Inc., 285 F.3d 415, 424 (6th Cir. 2002). The movant may satisfy its burden by showing "that there is an absence of evidence to support the non-moving party's case." Celotex Corp., 477 U.S. at 325. Once the movant has satisfied this burden, the non-moving party must go beyond the pleadings and come forward with specific facts demonstrating there is a genuine issue in dispute. Hall Holding, 285 F.3d at 424 (citing Celotex Corp., 477 U.S. at 324).
The Court must then determine "whether the evidence presents a sufficient disagreement to require submission to a jury or whether it is so one-sided that one party must prevail as a matter of law." Booker v. Brown & Williamson Tobacco Co., 879 F.2d 1304, 1310 (6th Cir. 1989) (quoting Anderson, 477 U.S. at 251-52). In doing so, the Court must review the facts and draw all reasonable inferences in favor of the non-moving party. Logan v. Denny's, Inc., 259 F.3d 558, 566 (6th Cir. 2001). Summary judgment is inappropriate where there is a genuine conflict "in the evidence, with affirmative support on both sides, and where the question is which witness to believe." Dawson v. Dorman, 528 F. App'x 450, 452 (6th Cir. 2013).
At the outset, the Court notes that Vinova fails to respond to most of the arguments raised by the Board. Vinova's response to the motion primarily argues that she is claiming...
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