Weatherington v. Dothan City Bd. of Educ.
| Decision Date | 28 December 2020 |
| Docket Number | Case No. 1:19-cv-414-RAH-SMD (WO) |
| Parties | LATESHA WEATHERINGTON, Plaintiff, v. DOTHAN CITY BOARD OF EDUCATION, Defendant. |
| Court | U.S. District Court — Middle District of Alabama |
Plaintiff LaTesha Weatherington ("Weatherington") brings this employment discrimination action against Defendant Dothan City Board of Education (the "Board" or "DCS"). Before the Court is the Board's Motion for Summary Judgment ("Motion"). (Doc. 18.) The motion has been briefed and is ripe for review. For the reasons stated more fully below, the motion is due to be granted.
Weatherington is presently employed as a school principal by DCS, for whom she has worked continuously, albeit in various positions, since 2003. (Doc. 18-1, p. 49; Doc. 1, p. 4.) Weatherington, a black female, filed this suit after applying for, and being subsequently rejected from, several job openings within the DCS school system. She submits two explanations for the Board's decision to hire other candidates. The first is race discrimination, which she alleges pursuant to both 42 U.S.C. §1983 and Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. § 2000e, et seq., and the second is retaliation, which she also alleges pursuant to Title VII. (See Doc. 1.) Weatherington separately asserts that the Board awarded higher salaries to two of her male comparators in violation of the Equal Pay Act, 29 U.S.C. § 206(d). (Id., p. 10.)
DCS offers a more innocent explanation for hiring other candidates. According to several of the DCS personnel responsible for hiring, neither race nor retaliation played a role in the Board's review of applications, its interview process, or its hiring decisions. Instead, DCS contends that, as to each of the vacancies forming the basis of Weatherington's suit, it hired the most qualified candidate. (See Doc. 19; Doc. 18-2; Doc. 18-3; Doc. 18-6; Doc. 18-7.) In response to Weatherington's Equal Pay claim, DCS challenges Weatherington's assertion that she was equally situated to certain named male comparators, and highlights the differences between the first-year probationary principal contract that she held, and the three-year principal contract that her alleged male comparators held. (Doc. 19, p. 50.) It insists Weatherington's gender was not a consideration for determining which contract she was awarded or her salary. (Doc. 18-5; Doc. 19, pp. 50-53.)
To be sure, Weatherington is a well-qualified school administrator. She boasts two bachelor's degrees - one from Alabama State University and one from Troy University in Dothan - and obtained her master's degree in Education Leadership in 2009, as well as an Education Specialist degree in 2018 - both from Troy University in Dothan. (Doc. 18-1, pp. 54-56.)
Weatherington's history as a DCS employee has been long and largely without incident. DCS first hired her in 2003 to be a teacher (and for a short time, the program specialist) at PASS Academy, where she remained until 2012. (Id., pp. 13-14.) Weatherington went on to work in several administrative positions at Dothan High School, where she spent one year as the ninth-grade coordinator and one year as assistant principal. (Id., pp. 16, 20.) She also had a short tenure as principal of Honeysuckle Middle School from October 2014 through December 2015 before the superintendent removed her from the position. (Id., pp. 19-20.) She returned to Dothan High as assistant principal in February 2016.1 (Id., pp. 25-26.) Weatherington remains employed by DCS, and most recently stepped into the position of principal at PASS Academy, for which she was awarded a three-year principal contract in the summer of 2020. (Id., p. 49.)
Of course, Weatherington's employment with DCS, though it has not lapsed, has not been entirely without discord. This is largely because, in December 2015, then-Superintendent Dr. Charles Ledbetter ("Ledbetter") made the decision to remove her from her position as principal of Honeysuckle Middle School. Because this event is a focus of Weatherington's claims, it is discussed in detail below.
Weatherington applied for and was interviewed to fill the vacant principal position at Honeysuckle Middle School in the fall of 2014. (Doc. 18-1, pp. 24-25.) The interviewing committee recommended Weatherington to the Board for hire, and DCS subsequently issued her a principal contract. (Id.) Being that it was her first principal contract, the contract was probationary, as is customary for all first-time principals. (Doc. 18-5, p. 2.) Her first day on the job was in October 2014. (Doc. 18-1, p. 25.)
In December 2015 - 15 months after her tenure at Honeysuckle began - Ledbetter called Weatherington in to meet with him. (Doc. 18-1, pp. 27-28.) It was at this meeting that Ledbetter informed Weatherington that he was removing her from her position as Honeysuckle principal, and he handed her a letter with a notice that she was being reassigned to PASS Academy. (Id., pp. 28-29.) According to Weatherington, Ledbetter explained that he wanted to go in a different direction.(Id.) This did not sit well with Weatherington, who apparently refused to sign the transfer letter and left the meeting without saying anything further. (Id.)
After the meeting, Weatherington first contacted her representative at the Alabama Education Association ("AEA"), Rhonda Hicks. (Id., pp. 29-30.) Next, she called Franklin Jones, who was serving on the Board of Education at the time. (Id., pp. 29-30.) Weatherington did not lodge any formal complaints on her own behalf with either Ledbetter or the Board concerning her transfer from Honeysuckle, nor did she communicate about the transfer with anyone else other than her lawyer, Clint Daughtrey, who the AEA had assigned to her. (Id., pp. 39-42.)
Weatherington's displeasure with the transfer spurred Daughtrey to initiate a series of conversations with DCS, all of which took place between December 2015 and February 2016.2 (Id., pp. 35-36.) During this time, Weatherington remained on leave, and did not report to work at Honeysuckle or anywhere else. (Id., pp. 36-37.) By February 2016, Daughtrey and DCS had negotiated a Settlement Agreement ("Settlement Agreement"), (Doc. 18-8), under which Weatherington would request a voluntary transfer to Dothan High as an assistant principal, and DCS would continue paying Weatherington under her probationary principal contract through itsend date in July 2016. (Doc. 18-1, pp. 35-36; Doc. 18-8, pp. 1-2.) By its terms, the Settlement Agreement further specified that Weatherington would be "free to apply for any and all positions posed as vacant by the Board," and that the Settlement Agreement itself could not "be held against her... in considering her application." (Doc. 18-8, p. 2.) In July 2016, Weatherington "revert[ed]" to an eleven-month assistant principal contract. (Id.)
After her transfer from Honeysuckle and return to Dothan High, Weatherington applied for six separate job openings in the DCS system.3 (See Doc. 1.) For each position made the basis of this suit, the Board made the final hiring decisions based on recommendations submitted by the superintendent and relevant personnel. The facts relating to each position, viewed in the light most favorable to Weatherington, are explained in turn.
In April 2016, Weatherington applied for the Supervisor of Exceptional Educational Services vacancy. (Doc. 18-1, pp. 112-13.) The position was based in the central office and entailed assisting the director of the special education department, overseeing the staff in the department, and monitoring legal updates relevant to educating students with disabilities. (Doc. 18-7, p. 1.) It was CarolCunningham, a white female and the Director of Exceptional Student Services at the time, who interviewed Weatherington for the position and recommended hiring a different candidate, Alicia Hales, as the superintendent. (Id.; Doc. 18-1, pp. 117-18.)
As it relates to Weatherington's qualifications for the position, Weatherington points to her time as the designated "special ed administrator" at PASS Academy and Dothan High School. (Doc. 18-1, p. 114.) By contrast, Hales, a white female, already had direct involvement with the Exceptional Services department throughout her time as a school psychometrist. (Doc. 18-7; see Doc. 18-11.) Then-superintendent Ledbetter agreed with Cunningham's assessment that Hales was more qualified, and the Board hired Hales in May 2016 on his recommendation. (Doc. 18-4, p. 3.)
Todd Weeks was serving as the interim DCS superintendent in May 2017 when the Board was hiring for the vacant Cloverdale Elementary principal position. (Doc. 18-1, pp. 64-65.) Weatherington applied for the position and was interviewed by Weeks, a process that was unlike her other DCS interview experiences.4 (Id., p.66.) Additionally, in her deposition, and as DCS points out in its Motion, Weatherington took issue with the outgoing principal's show of favoritism, which she believed to have clouded DCS's judgment in hiring for this position.5 (Doc. 18-1, pp. 77-79; Doc. 19, p. 13.) Weeks ended up recommending Christy Martin, a white female, to the Board for hire based on her history working at Cloverdale and her proven track record as part of its administration. (Doc. 18-3, pp. 1-2.) The Board adopted Weeks' recommendation.
Weatherington applied for the Highlands Elementary Principal position in June 2018, but DCS did not select her for an interview. (Doc. 18-1, pp. 95, 98.) Based on the affidavit of Dr. Phyllis Edwards ("Edwards"), who became superintendent of DCS in February 2018, DCS assembled an interview committee for this position, and the...
To continue reading
Request your trial