Lewis v. Baltimore City Board of School Commissioners, 187 F. Supp. 3d 588

Jamie Lewis, an assistant principal since 2007, had a deteriorating relationship with her principal Wanda Young in 2011; Young issued warnings for attendance and incomplete evaluations and ultimately issued a written reprimand.
Lewis filed a complaint with the school system’s EEO Office in December 2011 alleging harassment by Young (including an anonymous insulting letter and public reprimands); Staff Investigations later substantiated the complaint and Young was demoted.
Lewis took FMLA leave for stress-related illness (Jan–May 2012), returned in June 2012 and briefly worked as an assistant principal at Coppin Academy; the Board asserts that hire lacked required approvals and removed her from that position.
The Board reassigned Lewis to a teacher position for the 2012–2013 year and Conley gave her an unsatisfactory annual evaluation based on attendance and incomplete observation reports; Lewis resigned in September 2012.
Lewis sued the Board and various individuals alleging sex discrimination/hostile work environment, retaliation, and ADA violations (confidentiality and disability). The Board moved for summary judgment; the court granted it in full.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Individual liability under Title VII/ADA	Lewis sued individual supervisors (e.g., Jones, Young)	Individuals cannot be held liable under Title VII or the ADA	Court dismissed claims against individual defendants
Hostile work environment (sex discrimination)	Young’s remarks, public reprimands, and anonymous letter constituted sex-based harassment	Harassment was motivated by personal/workplace dispute and performance issues, not sex	Court held plaintiff failed to show harassment "because of" sex; summary judgment for defendants
Retaliation for filing EEO complaint	Filing complaint was protected activity; reassignment, removal from Coppin, and negative evaluation were retaliatory adverse actions	Reassignments and evaluation were based on legitimate, non-retaliatory reasons: attendance, incomplete observations, and system needs; decisionmakers lacked knowledge of complaint; temporal gap	Court found no causal connection and that defendants proffered legitimate reasons; summary judgment for defendants
ADA — confidentiality/disability	Young disclosed Lewis’s psychiatrist note and called her "crazy"; Lewis was disabled by job-related stress	Lewis’s impairment was temporary and not a qualifying ADA disability; disclosure did not fall within protected ADA medical-inquiry/confidentiality rules	Court held Lewis failed to show a qualifying disability and that the disclosure violated the ADA; summary judgment for defendants

Lissau v. Southern Food Serv., 159 F.3d 177 (4th Cir. 1998) (individuals not liable under Title VII)
Baird ex rel. Baird v. Rose, 192 F.3d 462 (4th Cir. 1999) (individuals not liable under ADA/Title VII)
Pueschel v. Peters, 577 F.3d 558 (4th Cir. 2009) (elements of hostile work environment claim)
Oncale v. Sundowner Offshore Servs., Inc., 523 U.S. 75 (U.S. 1998) (same-sex harassment evidentiary routes)
Ziskie v. Mineta, 547 F.3d 220 (4th Cir. 2008) (must show target of hostility because of sex)
Lack v. Wal-Mart Stores, Inc., 240 F.3d 255 (4th Cir. 2001) (sex-specific comments insufficient without proof of gender-based motive)
Davis v. Coastal Int’l Sec., Inc., 275 F.3d 1119 (D.C. Cir. 2002) (distinguishing workplace grudge from sexual motivation)
Burlington N. & Santa Fe Ry. Co. v. White, 548 U.S. 53 (U.S. 2006) (standard for materially adverse action in retaliation claims)
Pollard v. High’s of Baltimore, Inc., 281 F.3d 462 (4th Cir. 2002) (temporary impairment generally not an ADA disability)
Porter v. U.S. Alumoweld Co., 125 F.3d 243 (4th Cir. 1997) (limits on employer medical inquiries and confidentiality under ADA)