Keenan Meadors sued Independent School District No. 1 of Tulsa County in the United States District Court for the Northern District of Oklahoma raising claims of age discrimination, retaliation, due process violations, and breach of fiduciary duty under ERISA. Before the court is Defendant Independent School District No. 1 of Tulsa County’s motion for summary judgment.
Statement of Undisputed Facts
Keenan Meadors was hired as a campus police officer for the Independent School District No. 1 of Tulsa County in August 2010 after retiring from the Tulsa Police Department. He received positive performance reviews from 2012 through May 2017 and was promoted from police officer to sergeant. In February 2017, Meadors filed a complaint against two superior officers, including allegations of sexual harassment by Deputy Chief Matthias Wicks. An investigation confirmed employee concerns about physical expressions of affection in the workplace but found no evidence of sexual harassment or misconduct.
When a vacancy for Chief of Campus Police arose, Meadors opposed Deputy Chief Wicks’ appointment by signing a Letter of No Confidence and submitting his own application. Despite the opposition, Wicks was selected as the new chief. After Wicks became chief, Meadors began receiving negative feedback and was eventually demoted from sergeant to police officer in 2017 following an incident where he covered a security camera.
In April 2019, the District proposed a reorganization plan that eliminated the position of campus police officer and created a new role of school safety officer. Meadors was notified of the proposal and encouraged to apply for the newly created positions. He requested and was granted a pre-termination hearing on May 23, 2019. The Board approved the reorganization plan, eliminating 179 employment positions, including all police officer positions, effective June 30, 2019.
Meadors applied for one of the newly created school security officer positions but was not selected. He filed a complaint with the Equal Employment Opportunity Commission on February 7, 2020, alleging age discrimination and retaliation.
Legal Analysis
Age Discrimination in Employment Act (ADEA) Claim: The court found that Meadors established a prima facie case of age discrimination and that the District provided legitimate, nondiscriminatory reasons for not rehiring him. However, the court concluded that Meadors presented sufficient evidence to create a jury question on whether the District’s reasons were pretextual.
To show pretext, Meadors pointed to several factors. He highlighted that the District’s claim of his disobedience to a security camera directive in 2017 had already been disputed in a previous hearing, where the School Board declined to adopt the District’s findings. Meadors also noted inconsistencies in the District’s stated reasons for not rehiring him, with different explanations given at different times. Furthermore, he argued that the District relied on subjective criteria in its decision-making process, which could be viewed as evidence of pretext when coupled with other circumstantial evidence. Notably, Meadors presented evidence that one member of the selection team had previously expressed concerns about his age, indicating potential age-based bias. The court found these factors sufficient to create a jury question on the issue of pretext and denied summary judgment on the ADEA claim.
Title VII Retaliation Claim: The court granted summary judgment on claims arising from Meadors’s 2017 demotion, finding them time-barred. However, the court denied summary judgment on the claim that the District’s decision not to rehire Meadors in 2019 was retaliatory.
To establish pretext for the retaliation claim, Meadors presented evidence of his positive performance reviews from 2012 through May 2017. He argued that the negative feedback and performance issues cited by the District all arose after he engaged in protected activity by reporting alleged sexual harassment by Deputy Chief Wicks. Meadors contended that the timing and nature of the negative feedback suggested it might have been fabricated or exaggerated in response to his protected activity. He also emphasized that Chief Wicks, who was involved in the decision not to rehire Meadors, had been the subject of Meadors’s initial complaint. The court found this evidence sufficient to create a jury question on whether the District’s stated reasons for not rehiring Meadors were pretextual. As a result, the court denied summary judgment on the retaliation claim related to the 2019 decision not to rehire him.
Due Process Claims: The court granted summary judgment on Meadors’s procedural and substantive due process claims. The court found that Meadors received adequate process regarding the elimination of his position and had no protected interest in reemployment following the reorganization. The court also concluded that Meadors failed to present evidence of conscience-shocking behavior to support his substantive due process claim.
ERISA Claim: The court granted summary judgment on Meadors’s ERISA claim, finding that the retirement plans at issue were “governmental plans” exempt from ERISA’s requirements, and Meadors failed to present evidence to dispute this classification.
The court granted summary judgment on Meadors’s due process and ERISA claims but denied summary judgment on his age discrimination and retaliation claims related to the 2019 decision not to rehire him.
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