Jaramillo v. Adams County School District 14
2012 U.S. App. LEXIS 11910
10th Cir.2012Background
- Jaramillo, a Hispanic female, served as principal at Hanson PreK-8 in Adams County SD-14.
- Hanson serves a predominantly Hispanic student body; Jaramillo was the district's only Hispanic principal.
- In 2008–2009, the district considered an English Language Learners policy, triggering community and staff controversy.
- Dr. Chandler, interim superintendent, confronted Jaramillo about alleged misinformation and demanded the name of a informant.
- Jaramillo refused to identify the informant; she was placed on paid administrative leave and later recommended for termination.
- The Board terminated Jaramillo on April 14, 2009; she filed suit under 42 U.S.C. § 1981 in 2009.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether pretext supports §1981 discrimination claim | Jaramillo shows pretext via weak rationale and disparate treatment. | Insubordination provides a legitimate nondiscriminatory reason; no pretext shown. | No pretext evidence; JM/Board upheld; no §1981 violation. |
| Whether district can be liable under cat's paw | Chandler's bias proximate cause of termination. | No proof of bias by Chandler or others; no proximate causation. | No cat's paw liability. |
| Whether evidence of institutional racism creates triable pretext | Quintana's comments indicate institutional racism influenced decision. | Vague, conjectural, and not tied to specific decisionmakers' bias. | Insufficient to create triable pretext. |
| Whether insubordination finding itself creates pretext | Dr. Chandler's request was unreasonable; insubordination was mischaracterized. | Jaramillo refused to comply after multiple notices; valid insubordination. | Not enough to show pretext; valid nondiscriminatory basis. |
Key Cases Cited
- Crowe v. ADT Sec. Servs., Inc., 649 F.3d 1189 (10th Cir. 2011) (pretext standards and weaknesses in proffered reasons)
- Staub v. Proctor Hosp., 131 S. Ct. 1191 (2011) (proximate cause and supervisor bias in discriminatory discharge)
- Santana v. City and Cnty. of Denver, 488 F.3d 860 (10th Cir. 2007) (conjecture insufficient to defeat summary judgment)
- Zokari v. Gates, 561 F.3d 1076 (10th Cir. 2009) (institutional racism not a substitute for personal knowledge)
- Young v. Dillon Cos., 468 F.3d 1243 (10th Cir. 2006) (employer's business judgment not to be second-guessed)