Linda Eaton-Stephens v. Grapevine Colleyville ISD
16-11611
| 5th Cir. | Nov 13, 2017Background
- Linda Eaton-Stephens, an African-American counselor and the only Black employee at Heritage Middle School, worked there 2005–2014 and resigned after an investigation into alleged academic fraud involving another employee’s online coursework.
- Conflicts with coworkers (notably Marsha Fields and registrar Michaelanne Tapp) escalated from 2009–2014; Fields allegedly called Eaton-Stephens “the little black counselor.”
- School HR (Padgett and Lamb) confiscated Eaton-Stephens’s laptop after parents’ night complaints and found writings tied to another employee, prompting an investigation and a proposed termination/administrative-leave letter.
- Eaton-Stephens had intermittent FMLA leave for migraines during 2013–2014 and claims coworkers and a principal discouraged or harassed her for taking leave.
- She sued the Grapevine Colleyville ISD alleging Title VII race discrimination (disparate treatment and hostile work environment), ADA disability discrimination, retaliation, and an FMLA claim; the district court granted summary judgment for the School District, and Eaton-Stephens appealed.
Issues
| Issue | Eaton-Stephens' Argument | Grapevine Colleyville ISD's Argument | Held |
|---|---|---|---|
| Title VII disparate treatment (direct evidence) | Fields’s “little black counselor” comment is direct evidence of race-based discrimination | The speaker lacked authority over employment decisions; comment not proximate to adverse action | Court: Not direct evidence; too many inferences required |
| Title VII disparate treatment (circumstantial / pretext) | Investigation and resignation were motivated by race; coworkers’ conduct and laptop spoliation support pretext | Investigation legitimately based on alleged academic fraud; no evidence race motivated action | Court: Plaintiff established prima facie but failed to show pretext or racial motive; summary judgment affirmed |
| Title VII hostile work environment | Sequence of slights, harassment, and the racial epithet created a hostile environment | Incidents isolated, not severe or pervasive enough to alter employment terms | Court: No prima facie hostile-work-environment; summary judgment affirmed |
| FMLA claim (pleading and interference) | Complaint referenced FMLA; supervisor discouraged leave and coworkers harassed her for using FMLA | Complaint did not properly plead an FMLA interference claim; no evidence of actual interference or prejudice | Court: Complaint failed to plead FMLA claim properly; even if pleaded, no evidence of interference — dismissal stands |
Key Cases Cited
- Ramirez v. City of San Antonio, 312 F.3d 178 (5th Cir.) (summary judgment standard review)
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (Sup. Ct.) (burden-shifting framework for circumstantial discrimination)
- Ramsey v. Henderson, 286 F.3d 264 (5th Cir.) (hostile-work-environment pleading/evidence standards)
- Laxton v. Gap, Inc., 333 F.3d 572 (5th Cir.) (evidence to discredit employer’s proffered reason)
- King v. Ill. Cent. R.R., 337 F.3d 550 (5th Cir.) (spoliation/bad faith burden on plaintiff)
- E.E.O.C. v. WC&M Enters., Inc., 496 F.3d 393 (5th Cir.) (examples of pervasive/severe harassment supporting hostile-environment claim)
- Acker v. Gen. Motors, L.L.C., 853 F.3d 784 (5th Cir.) (elements of FMLA interference claim)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (Sup. Ct.) (pleading standard requiring fair notice)