Daniels v. School District
2013 U.S. Dist. LEXIS 159937
E.D. Pa.2013Background
- Daniels, an African-American female teacher born in 1950, sues the School District of Philadelphia and four administrators for race and age discrimination, retaliation, and constitutional claims.
- Daniels was hired in 2008 and underwent a series of forced transfers: Bregy (2008-09) to Mifflin (2009), then to Vare (2010-11), and then to Penrose (2011-12).
- Mason (Mifflin’s principal), Marianno (Vare’s principal), Christy (Vare’s assistant principal), and Pendino (Penrose principal) are sued; Meiers (a white, younger teacher) replaced Daniels at Mifflin.
- Daniels asserted claims under Title VII, 42 U.S.C. § 1981 and § 1983, the PHRA, the ADEA, and asserted retaliation and First Amendment/equal protection rights.
- The court granted in part and denied in part the defendants’ Rule 56 motion for summary judgment, dismissing several claims while allowing others to proceed, and ultimately issuing a comprehensive order outlining surviving claims and fully granting many others.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Liability under §1983/§1981 for the School District | Daniels contends policy/practice of discrimination exists. | District lacks an official policy; no Monell basis shown. | §1983/§1981 claims against District largely fail; some permitted for specific transfer events. |
| Discrimination claims tied to the 2010 Mifflin transfer | 2010 forced transfer and replacement show race/age discrimination | Neutral budget and certification rationale justify transfer | Survives against District for Title VII/PHRA/ADEA; Mason limited to failure to notify of transfer. |
| Retaliation claims across years | Protected activity linked causally to adverse actions | No causal link or protected activity shown for many actions | Most retaliation claims fail; limited Penrose 2011-2012 and termination-related claims also resolved against Daniels. |
| Hostile work environment claim | Summary judgment for all defendants; no stand-alone hostile environment claim. | ||
| Disciplinary memo at Vare and other 2010-2011 actions | Disciplinary actions were retaliatory or discriminatory | Actions were non-discriminatory and policy-based | Disciplinary memo at Vare not shown to be discriminatory; other 2010-2011 actions largely resolved in favor of defendants. |
Key Cases Cited
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986) (genuine disputes require enough evidence for a jury)
- Burlington N. & Santa Fe Ry. Co. v. White, 548 U.S. 53 (2006) (retaliation standard extends beyond ultimate employment action)
- Monell v. Dep’t of Social Servs., 436 U.S. 658 (1978) (municipal liability requires policy or practice)
- Bryan Cnty. v. Brown, 520 U.S. 397 (1997) (deliberate indifference standard for policy/ training)
- Fuentes v. Perskie, 32 F.3d 759 (1994) (burden shifting in discrimination cases; pretext standard)
- LeBoon v. Lancaster Jewish Cmty. Ctr., 503 F.3d 217 (3d Cir. 2007) (causation prong and temporal proximity notions in retaliation)
- Farrell v. Planters Lifesavers Co., 206 F.3d 271 (3d Cir. 2000) (causation in retaliation can use broader evidence)
- Ambrose v. Twp. of Robinson, Pa., 303 F.3d 488 (3d Cir. 2002) (protected activity knowledge by decisionmakers required)
- Moore v. City of Philadelphia, 461 F.3d 331 (3d Cir. 2006) (objectively reasonable belief in unlawful activity for protected activity)
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (framework for discrimination claims)
- Jones v. School Dist. of Phila., 198 F.3d 403 (3d Cir. 1997) (prima facie elements in discrimination claims)