Martin v. Shelby County Board of Education, 2:15-cv-02169

Background

Sharon Martin, an African-American interventionist at Vincent Middle High School for ~20 years, applied in April 2014 for a higher‑paying registrar/data manager position; she was not hired.
The vacancy was posted; 96 applicants applied; a three‑member school interview panel (principal Clint Dixon, INOW trainer Faith Pack, counselor Maite Miller) interviewed six candidates, including Martin and five others.
The panel decided not to use the numerical scoring on the standardized interview form and instead used a subjective “comprehensive” evaluation; the panel recommended Karen George, a white candidate, who the superintendent and Board approved.
Martin had strong performance evaluations, computer training/degree, INOW access, awards, and work experience she argued made her better qualified than the selected candidate.
Martin alleged race discrimination under Title VII against the Board and § 1983 equal protection claims against individual board members (official and individual capacities).
The district court granted summary judgment for defendants, finding Martin failed to produce sufficient circumstantial evidence that the hiring decision was motivated by racial discrimination or that the Board’s proffered nondiscriminatory reason was pretextual.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Martin established a prima facie Title VII failure‑to‑hire claim and proffered evidence of pretext	Martin: She is a protected class member, qualified, not hired, position filled by a white person; panel deviated from procedures, post‑hoc justifications (appearance/welcome committee) mask discrimination, and historic exclusion of Black staff shows disparate treatment	Board: Panel legitimately concluded George was "best fit" after interview consensus; selection process and superintendent/Board approval were race‑neutral; deviations from numeric scoring were permissible and not evidence of racial animus	Held for defendant: Martin met prima facie elements but failed to show that employer's stated reasons were pretextual or to produce a convincing mosaic of circumstantial evidence of intentional discrimination; summary judgment for Board granted
Whether deviations from hiring procedures (abandoning numeric scoring, subjective emphasis on "welcome committee") support an inference of racial discrimination	Martin: Panel’s abandonment of objective scoring and focus on subjective criteria disadvantaged her and others and suggests bias/pretext	Board: Panel legitimately used holistic evaluation; deviations affected candidates of all races (including white candidates like Gibson) and do not show discriminatory motive	Held for defendant: Procedural deviations alone—especially when they impacted applicants of all races—did not create a triable issue of intentional race discrimination
Whether § 1983 official‑capacity claims against individual board members survive (i.e., liability of entity via officials)	Martin: Individual officials sued in official capacity are liable for discriminatory hiring as agents of the Board	Defendants: Official‑capacity suits are suits against the Board; same standards apply as Title VII; no discrimination shown under Title VII	Held for defendant: Official‑capacity § 1983 claims fail for same reasons as Title VII claim; summary judgment for defendants
Whether individual‑capacity § 1983 claims against Board members (and "cat’s paw" theory as to Dixon/Pack) survive	Martin: Individual board members are liable because they approved the hire and were influenced by biased subordinates (Dixon/Pack) — cat’s paw liability	Defendants: Board members were not personally involved in selection, had no knowledge of applicants’ races, and the recommendation flowed from panel and superintendent; no evidence of discriminatory animus by decisionmakers	Held for defendant: No personal discriminatory conduct or causal link shown; cat’s paw theory fails because Martin did not show discriminatory animus by the subordinate decisionmakers

Key Cases Cited

White v. Beltram Edge Tool Supply, Inc., 789 F.3d 1188 (11th Cir.) (summary judgment standard and viewing facts in light most favorable to nonmovant)
Trask v. Secretary, Dept. of Veterans Affairs, 822 F.3d 1179 (11th Cir.) (elements of prima facie failure‑to‑hire case)
Flowers v. Troup County, Ga. School Dist., 803 F.3d 1327 (11th Cir.) (burden‑shifting framework and plaintiff’s ultimate burden to prove intentional discrimination)
Smith v. Lockheed‑Martin Corp., 644 F.3d 1321 (11th Cir.) ("convincing mosaic" approach to circumstantial evidence of discrimination)
Staub v. Proctor Hospital, 562 U.S. 411 (U.S.) (cat’s paw theory of liability)
Brown v. American Honda Motor Co., 939 F.2d 946 (11th Cir.) (limitations of raw statistical proof without contextual application data)
Hurlbert v. St. Mary’s Health Care System, Inc., 439 F.3d 1286 (11th Cir.) (employer’s deviation from standard procedures may evidence pretext)
Jenkins v. National Waterworks, Inc., 502 Fed. Appx. 830 (11th Cir.) ("best fit" explanation is a legitimate nondiscriminatory reason)