Cynthia Hopkins v. Canton City Board of Education, 477 F. App'x 349

Background

Hopkins, African-American, sued the Canton City Board of Education and three CCSD officials for race-based employment discrimination, retaliation, and related due‐process claims.
Hopkins was an administrator at Multi-County; Williams supervised her; Talarico and Robinson participated in personnel decisions; all are Caucasian.
Her contract as administrator was nonrenewed; she was transferred to Hartford Middle School with a coordinator title but same salary and reduced duties.
The Board and officials ultimately hired others for administrative positions and did not renew Hopkins’s administrator contract receipts; Hopkins alleged biased, race-based motives.
The district court granted summary judgment to defendants on all claims except public policy, and Hopkins appeals the remaining claims; this court affirms.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Hopkins proved state discrimination under §4112.02(A).	Hopkins asserts race-based adverse actions and disparate treatment were caused by defendants.	Defendants contend no prima facie case or evidence of pretext; hires were based on qualifications.	No genuine issue; no discrimination established.
Whether Hopkins proved pretext for hiring decisions.	Statistical disparities and alleged record-manipulation show pretext.	Board had legitimate, non-discriminatory hiring criteria; Hopkins offered no admissible competitor data.	No reasonable jury could find pretext.
Whether Hopkins proved retaliation under §4112.02(I).	Rejections followed her OCRC discrimination filing; timing suggests retaliation.	Individuals named did not participate in hiring decisions; no knowledge of protected activity by decisionmakers.	No prima facie case; no causation shown; summary judgment affirmed.
Whether Hopkins had a protected property interest and was deprived procedurally in the transfer.	§ 3319.02(C) creates a property interest against transfers to lesser duties during contract.	Transfer was mutual or not a deprivation; no due-process violation.	There was no deprivation; transfer assented to; no procedural violation.
Whether Hopkins has a substantive due process right in public employment.	Arbitrary transfer violated substantive due process.	No fundamental right breached absent impermissible purpose or equal protection violation.	No substantive due process violation found.

Key Cases Cited

McDonnell Douglas Corp. v. Green, 411 U.S. 792 (U.S. 1973) (burden-shifting framework for discrimination cases)
Texas Dept. of Cmty. Affairs v. Burdine, 450 U.S. 248 (U.S. 1981) (pretext framework within McDonnell Douglas)
Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574 (U.S. 1986) (summary-judgment standard; 'genuine issue' requires more than metaphysical doubt)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (U.S. 1986) (lack of genuine issue of material fact; summary judgment proper if no evidence)
Hazelwood School District v. United States, 433 U.S. 299 (U.S. 1977) (statistical disparities and labor-market comparison standards)
Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133 (U.S. 2000) (pretext evidence and non-dispositive in some cases)
Saucier v. Katz, 533 U.S. 194 (U.S. 2001) (Saucier procedure for qualified immunity considerations)