Hamilton v. Southland Christian School, Inc.
2012 U.S. App. LEXIS 9865
11th Cir.2012Background
- Hamilton was hired as a teacher at Southland Christian School in January 2008.
- She conceived a child in January 2009, got married the following month, and was pregnant at that time.
- In April 2009 she told administrators she was pregnant and requested maternity leave for the next school year.
- She was fired a few days after the meeting, allegedly for premarital sex and its consequences.
- She filed an EEOC charge in May 2010 and then a federal Title VII pregnancy discrimination claim along with state-law claims.
- The district court granted summary judgment on pregnancy discrimination and marital-status claims, and dismissed the invasion-of-privacy claim without prejudice.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was Hamilton's pregnancy-discrimination claim properly disposed on summary judgment? | Hamilton asserts she presented circumstantial evidence of discrimination tied to pregnancy. | Southland maintains no prima facie case was shown and the reason given was premarital conduct, not pregnancy. | Summary judgment reversed; issue for jury on discrimination. |
Key Cases Cited
- Hosanna-Tabor Evangelical Lutheran Church & School v. Equal Employment Opportunity Comm'n, 132 S. Ct. 694 (2012) (ministerial exception discussed)
- Armstrong v. Flowers Hosp., Inc., 33 F.3d 1308 (11th Cir.1994) (pregnancy discrimination framework (direct/indirect evidence))
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (burden-shifting framework)
- Texas Department of Community Affairs v. Burdine, 450 U.S. 248 (1981) (burden-shifting framework continued)
- Smith v. Lockheed-Martin Corp., 644 F.3d 1321 (11th Cir.2011) (circumstantial-evidence standard for discrimination)
- Wilson v. B/E Aerospace, Inc., 376 F.3d 1079 (11th Cir.2004) (direct versus indirect evidence in employment discrimination)
- Wright v. Southland Corp., 187 F.3d 1287 (11th Cir.1999) (circumstantial evidence sufficiency standard)
- Moton v. Cowart, 631 F.3d 1337 (11th Cir.2011) (summary judgment review standard; favorable view to non-movant)