Plaintiff Karen A. Cason sued defendants St. Louis Public Schools, Board of Education of St. Louis Public Schools, and Superintendent Kelvin Adams in the United States District Court for the Eastern District of Missouri raising claims of gender discrimination under Title VII and the Missouri Human Rights Act, retaliation under Title VII and the MHRA, violation of 42 U.S.C. § 1983, and intentional infliction of emotional distress. Before the court is Defendant Adams’s motion for summary judgment.
Statement of Undisputed Facts
Defendant Adams was Superintendent of the St. Louis Public School District from 2008 until his retirement in 2022. Due to declining enrollment, Adams recommended closing several schools in 2021. Around that time, Adams conducted a review of various departments in the District’s Central Office to determine if any positions should be cut. As a result, Adams wrote the 2021-2022 Central Office Reorganization Plan, which identified staff reductions across seven departments, including eliminating the Administrative Review Officer position held by Plaintiff.
Adams recommended reassigning the responsibilities of that position to Network Superintendents to focus on restorative justice and bring them closer to school-level decisions. The Board of Education voted in favor of the Reorganization Plan, and Plaintiff was terminated in June 2021 along with several other employees. Plaintiff filed a Charge of Discrimination in December 2021, received her right to sue letter in early 2022, and filed this suit in April 2022.
Legal Analysis
Individual Liability Under Title VII: The court noted that the Eighth Circuit has squarely held that supervisors may not be held individually liable under Title VII. Therefore, to the extent that Plaintiff brought a Title VII action against Defendant Adams in his individual capacity, Adams was entitled to summary judgment.
Official Capacity Claim: While supervisory employees may be joined as party defendants in Title VII actions in their official capacities, such claims are typically dismissed as duplicative when the same claims are asserted against the employer. However, due to the dismissal of the claim against SLPS for failure to prosecute, the court addressed the merits of the official capacity claim against Adams.
Legitimate, Non-Discriminatory Reason for Termination:
The court found it unnecessary to decide whether Plaintiff established a prima facie case of discrimination because Defendant Adams presented a legitimate and unrebutted reason for her termination. Plaintiff’s position was eliminated as part of a reorganization plan due to reduced conferences post-pandemic, and her responsibilities were reassigned to other positions. The court noted that Plaintiff produced no evidence suggesting this reason was pretextual.
Rule 59(e) Motion: The court denied Plaintiff’s motion to reconsider, finding that it lacked merit. The court rejected Plaintiff’s argument about not having time to respond to a motion to strike, noting that Plaintiff relied on inapplicable procedural rules. The court also found that Plaintiff’s claim of “newly discovered evidence” from another discrimination case against St. Louis Public Schools did not affect the court’s previous order, which was based on Plaintiff’s failure to show cause rather than the substance of the summary judgment motions.
The court granted Defendant Adams’s motion for summary judgment, denied Plaintiff’s motion to reconsider, and denied as moot Plaintiff’s motion for the court to grant her motion to reconsider.
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