Plaintiff Merrier A. Jackson Tartt sued defendant Unified School District No. 475 in the United States District Court for the District of Kansas, raising claims of racial discrimination and retaliation under 42 U.S.C. § 1981 and Title VII of the Civil Rights Act. Before the court is Defendant Unified School District No. 475’s motion for summary judgment.
Statement of Undisputed FactsMerrier A. Jackson Tartt, an African American woman, was hired by Unified School District No. 475 as an interim principal at Junction City High School for the 2020-2021 school year and then as the principal for the 2021-2022 school year. In November 2021, Tartt expressed concerns to the Associate Superintendent, Debra Gustafson, about a school board member, Ron Johnson, “over monitoring” her. Gustafson told Tartt that Johnson was racist and targeting the district’s only two black administrators.In January 2022, Gustafson met with Tartt to discuss concerns about Tartt’s interactions with other staff members. Tartt sent a memorandum to Gustafson and Superintendent Dr. Reginald Eggleston complaining that Gustafson’s comments were “microaggressive” and “racist and inappropriate.” Shortly after, Tartt was informed she would not be submitted for early contract renewal.Tartt was placed on administrative leave in March 2022. Her final evaluation in April 2022 included mixed ratings, with some highly effective marks but also some developing and ineffective ratings. On May 3, 2022, the school board unanimously voted not to renew Tartt’s employment contract.
Evidentiary Disputes: The court noted that some of Tartt’s evidence, including statements from a former HR director about racial animus in the termination decision, was inadmissible as it was not based on personal knowledge.
Legal Analysis
Race Discrimination Claims: The court applied the McDonnell Douglas burden-shifting framework to analyze Tartt’s race discrimination claims. It found that Tartt established a prima facie case of discrimination. The court then determined that the school district articulated legitimate, non-discriminatory reasons for Tartt’s termination, including her failure to establish positive relationships with colleagues and creation of a negative workplace atmosphere.At the pretext stage, the court found that Tartt failed to demonstrate that the district’s reasons for her termination were pretextual. Tartt’s arguments primarily focused on whether the district’s decision was wise or fair, rather than showing it was motivated by racial animus. The court concluded that Tartt did not provide evidence showing that race was a criteria or motivating factor in the decision not to renew her contract.
Retaliation Claims: For the retaliation claims, the court again applied the McDonnell Douglas framework. It found that Tartt established a prima facie case of retaliation based on the close temporal proximity between her complaint about Gustafson’s comments and the decision not to submit her for early contract renewal.However, the court noted that Tartt failed to make any arguments or provide evidence to show that the district’s legitimate, non-discriminatory reasons for her termination were pretextual in the context of retaliation. As a result, Tartt failed to meet her burden at the pretext stage.The court granted Unified School District No. 475’s motion for summary judgment on all of Tartt’s claims of racial discrimination and retaliation under both § 1981 and Title VII.
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