Clive Pettis, Sr. v. Nottoway County School Board, 592 F. App'x 158

Pettis appeals the district court's denial of his motion for summary judgment and the grant of summary judgment to the Nottoway County School Board and its superintendent, Grounard, on his claims of employment discrimination and retaliation under 42 U.S.C. § 1981, § 1983, and Title VII.
Pettis alleged his contract was not renewed because of his race and in retaliation for his complaints of discrimination.
The district court granted Defendants' summary judgment; Pettis' cross-motion for summary judgment was denied.
Pettis contends he performed satisfactorily, but the record showed coworkers and his supervisor complained about his interactions and performance, leading to disciplinary actions.
Pettis argued that his harassment complaints constituted protected activity and that a causal link existed between protected activity and nonrenewal; the court disagreed on both points.
Pettis challenged the district court's denial of his Rule 59(e) motion to alter or amend, arguing abuse of discretion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Prima facie discrimination established?	Pettis contends he was discriminated against because of race.	Grounard's evidence shows Pettis was insubordinate and failed to perform satisfactorily.	No prima facie discrimination; Pettis failed to show satisfactory performance.
Causal link for retaliation established?	Pettis asserts his EEOC complaint and protected activity caused nonrenewal.	Temporal proximity is lacking and no protected activity shown.	No causal connection; EEOC filing four years earlier does not prove causation.
Were harassment complaints protected activity?	Pettis argues his harassment complaints were protected opposition/participation activity.	Complaints were vague and not reasonably viewed as protected anti-discrimination activity.	Complaints not protected activity for retaliation purposes.
Rule 59(e) motion abuse of discretion?	District court erred in denying reconsideration.	Disagreement with rulings is not abuse of discretion.	No abuse of discretion; Rule 59(e) denied appropriately.

McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (establishes burden-shifting framework for discrimination claims)
Hill v. Lockheed Martin Logistics Mgmt., Inc., 354 F.3d 277 (4th Cir. 2004) (elements of discrimination claims within McDonnell Douglas framework)
Holland v. Washington Homes, Inc., 487 F.3d 208 (4th Cir. 2007) (protected activity includes opposition to discriminatory practices)
Kubicko v. Ogden Logistics Servs., 181 F.3d 544 (4th Cir. 1999) (definition of protected activity and causal links in retaliation claims)
Jordan v. Alternative Res. Corp., 458 F.3d 332 (4th Cir. 2006) (opposition activity requires belief that practice was unlawfully discriminatory)
Price v. Thompson, 380 F.3d 209 (4th Cir. 2004) (causation requires close temporal proximity or other supporting evidence)
Clark Cnty. Sch. Dist. v. Breeden, 532 U.S. 268 (2001) (temporal proximity must be very close to establish causation)
Lettieri v. Equant Inc., 478 F.3d 640 (4th Cir. 2007) (availability of additional evidence when temporal proximity is lacking)
Rossignol v. Voorhaar, 316 F.3d 516 (4th Cir. 2003) (standards for evaluating cross-motions for summary judgment)
Glynn v. EDO Corp., 710 F.3d 209 (4th Cir. 2013) (de novo review and summary judgment standards)
Wilkins v. Montgomery, 751 F.3d 214 (4th Cir. 2014) (Rule 59(e) standard for motions to alter or amend)
Hutchinson v. Staton, 994 F.2d 1076 (4th Cir. 1993) (mere disagreement with district court rulings does not support Rule 59(e))