Alexander Harris v. Powhatan County School Board, 543 F. App'x 343

Harris, a 72-year-old African American, worked for the Board since 1957 and was last Director of Maintenance and Custodial Services before his position was eliminated on March 10, 2009.
His duties included scheduling work orders, supervising staff, budgeting, training, and maintaining facilities infrastructure.
School employees operate on annual contracts; Harris filed an intent-to-return for 2009-2010 in November 2008, but supervisor Imig delayed submission to discuss retirement and potential job elimination.
Board proposed eliminating fourteen positions in 2009-2010, with Harris’s position among them; each eliminated position in the maintenance/custodial area was held by someone over age 70.
Harris claimed an agreement to receive payment for unused annual leave upon retirement, alleging he lost about $19,500; the Board treated leave payout issues as not contractually binding and unused on appeal.
The Board reassigned Harris’s duties to a younger employee (Russell Wilson) with a $10,000 stipend and did not renew Harris’s contract for the 2009-2010 year.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Board’s reasons were pretext for age discrimination	Harris argues retirement belief and budget shortfall were pretextual motives.	Board contends retirement belief and budget impacts justified elimination.	Material facts create triable issues; pretext exists.
Whether Harris established race discrimination under Title VII	Evidence of racial motive through anti-NAACP comments or related conduct.	No substantial evidence linking race to termination; reasons tied to retirement/budget.	No genuine race-discrimination inference; Title VII claim dismissed.
Whether summary judgment on ADEA claim was proper	Evidence shows possible discriminatory motive; issues remain subject to jury.	If reasons are non-discriminatory, summary judgment should stand.	ADEA claim vacated for further consideration on remand.

Hill v. Lockheed Martin Logistics Mgmt., Inc., 354 F.3d 277 (4th Cir. 2004) (applies McDonnell Douglas to ADEA and defines principal decisionmaker concept)
Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133 (Supreme Court 2000) (pretext evidence can support discrimination finding)
Gross v. FBL Fin. Serv., Inc., 557 U.S. 167 (Supreme Court 2009) ("but-for" causation standard for ADEA claims)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (Supreme Court 1986) (summary judgment standard requiring no genuine dispute of material fact)
Holland v. Washington Homes, Inc., 487 F.3d 208 (4th Cir. 2007) (prima facie case for discrimination and evidence handling in retaliation context)
McDonnell Douglas Corp. v. Green, 411 U.S. 792 (Supreme Court 1973) (establishes burden-shifting framework for discrimination claims)