Marion Carter v. Pulaski CO Special School Dist, 956 F.3d 1055

Marion L. Carter, an African‑American teacher at Joe T. Robinson High School, also coached the cheer and dance teams and received supplemental pay for each.
In April 2017 the district superintendent nonrenewed Carter’s supplemental cheer and dance contract, citing “conduct unbecoming a professional employee” based on (1) declining participation, (2) parental complaints about inappropriate cheer routines, and (3) misconduct by cheerleaders during out‑of‑town travel.
The School Board upheld the nonrenewal after a hearing; the district filled the cheer coach role with an African‑American woman and eliminated dance teams district‑wide.
Carter sued under Title VII, 42 U.S.C. § 1983 (Equal Protection), and the Arkansas Civil Rights Act alleging race discrimination; the district court granted summary judgment for the District.
On appeal the Eighth Circuit reviewed de novo, applied the McDonnell Douglas burden‑shifting framework, and considered whether Carter presented direct evidence or a prima facie case (including a comparator) and whether the District’s reasons were pretextual.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Carter established an inference of racial discrimination via a comparator	Populis (white coach) performed a vulgar routine and was not disciplined, so Carter was treated differently	Populis was not similarly situated: different facts, no evidence of low participation or travel misconduct for Populis	Populis not similarly situated; no inference of discrimination established
Whether the District’s proffered reasons were pretextual	District produced little documentary proof of low participation; Chicken Express incident was not serious enough to justify removal, so reasons are pretext	District had a factual basis: principal testimony, supporting documentation of declining participation, and investigator’s conclusion about travel misconduct	Plaintiff failed to raise a genuine dispute of material fact on pretext
Whether summary judgment was appropriate	Carter: factual disputes and alleged inconsistencies defeat summary judgment	District: no genuine dispute as to material facts; entitled to judgment as a matter of law	Affirmed summary judgment for the District

McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (establishes burden‑shifting framework for discrimination claims)
Harvey v. Anheuser‑Busch, Inc., 38 F.3d 968 (8th Cir. 1994) (employees must be similarly situated in all relevant respects to serve as comparators)
Torgerson v. City of Rochester, 643 F.3d 1031 (8th Cir. 2011) (evidence must create a genuine dispute about the employer’s proffered reason to survive summary judgment)
Tolan v. Cotton, 572 U.S. 650 (2014) (summary judgment requires viewing evidence in the nonmovant’s favor on credibility questions)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986) (legal standard for summary judgment)