Condiff v. Hart County School District, 770 F. Supp. 2d 876

Condiff, a sixth/eighth grade language arts teacher on a one-year limited contract, reported sexually inappropriate conduct by a high school teacher involving her stepdaughter.
After reporting, Condiff was informed her contract would not be renewed for the 2008-2009 school year; later, two language arts positions were posted and Condiff was not placed on the qualified candidate list.
Condiff applied to multiple district positions but was not hired or interviewed for several openings; she remained employed elsewhere.
Plaintiff asserted Title IX retaliation, First Amendment retaliation, and Equal Protection (class of one) claims, plus § 1983 theories against the Board and the Superintendent.
Defendants moved for summary judgment, arguing improper party entity, lack of protected activity, no underlying constitutional violation, and no Monell-style policy.
The court granted summary judgment for defendants on all claims, holding the Hart County Board of Education is the proper entity, individual liability under Title IX/First Amendment is unavailable, no constitutional violation, and no equal protection/official-capacity liability.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Proper party: Hart County School District vs Board	Condiff sued the wrong entity; the Board is the proper defendant.	There is no separate Hart County School District entity; Board is the real party.	Hart County Board of Education is the proper defendant; Hart County School District dismissed.
Title IX retaliation against Line in his individual capacity	Line's actions caused retaliation for reporting harassment.	Title IX liability cannot attach to individuals; only funding recipient liable.	No individual liability under Title IX; dismissal of Line in his individual capacity.
Title IX retaliation against Board	Non-renewal and hiring decisions were retaliatory for reporting harassment.	Defendant provided legitimate, non-discriminatory reasons; no pretext shown.	Summary judgment for Board; plaintiff failed to show pretext.
First Amendment retaliation	Condiff's reports were protected speech and caused adverse action.	Speech occurred in official duties and was not protected; no causal link shown.	Summary judgment; speech not protected or not causally connected to actions.
Equal Protection (class of one)	Board treated Condiff differently without rational basis.	Engquist controls; no class-of-one claim against a public employer.	Summary judgment for Defendant; equal protection claim dismissed.

Garcetti v. Ceballos, 547 U.S. 410 (U.S. 2006) (speech as part of official duties not protected)
Engquist v. Oregon Dep't of Agric., 553 U.S. 591 (U.S. 2008) (class-of-one claims against government officials generally not viable)
Leary v. Daeschner, 349 F.3d 888 (6th Cir. 2003) (framework for First Amendment retaliation plaintiff's prima facie case)
Dixon v. Gonzales, 481 F.3d 324 (6th Cir. 2007) (causal connection in retaliation requires more than temporal proximity alone)
Thaddeus-X v. Blatter, 175 F.3d 378 (6th Cir. 1999) (definition of adverse employment action in retaliation context)