Mary Stennett v. Tupelo Public School District
619 F. App'x 310
5th Cir.2015Background
- Mary Alice Stennett, a 38‑year educator with advanced degrees and multiple administrative certifications, worked for Tupelo Public School District (TPSD) in various administrative/teaching roles, including effectively serving as an assistant principal at the district alternative school.
- After TPSD outsourced the Fillmore Center in 2010, Stennett (then 64) and the three other oldest employees were not rehired full‑time; younger staff were rehired or transferred.
- In 2011–2012 Stennett (then 66) applied for seven TPSD positions (assistant principals, testing coordinator roles, administrative intern, lead teacher); she was interviewed for two and not hired for any; substantially younger applicants filled all positions.
- Stennett sued under the ADEA alleging age discrimination for TPSD’s refusal to hire her for each of the seven positions; the district court granted summary judgment to TPSD, finding she had not shown she was “clearly better qualified.”
- On appeal, the Fifth Circuit reviewed the record de novo under Reeves and related precedent, focusing on whether Stennett raised a genuine issue of material fact that TPSD’s nondiscriminatory reasons were pretextual.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Stennett established a prima facie ADEA claim for each position | Stennett: she was qualified, in protected class (age ≥40), rejected, and younger applicants were hired | TPSD did not dispute prima facie elements | Held: Stennett established prima facie case for each job |
| Whether TPSD met its McDonnell Douglas burden of production | Stennett: N/A (burden on employer) | TPSD: proffered legitimate, nondiscriminatory reasons (better qualified hires, job fit, specific skills) | Held: TPSD met production burden (court assumes legitimate reasons) |
| Whether Stennett produced sufficient evidence of pretext to defeat summary judgment | Stennett: showed superior/pertinent qualifications, failure to interview for 5 positions, reliance on unlisted/subjective criteria, and non‑rehiring of other oldest employees | TPSD: reasons that successful applicants were better qualified and appropriate hiring discretion | Held: A reasonable jury could disbelieve TPSD’s reasons; summary judgment improper (case reversed and remanded) |
| Proper standard for reviewing summary judgment in discrimination cases | Stennett: courts must view the whole record and may combine prima facie evidence with other evidence of pretext (Reeves) | TPSD: district court required showing of being "clearly better qualified" | Held: Court rejects district court’s heightened ‘‘clearly better qualified’’ requirement; applies Reeves and reverses summary judgment |
Key Cases Cited
- Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133 (discusses use of McDonnell Douglas burden shifting at summary judgment and combining prima facie evidence with pretext evidence)
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (establishes burden‑shifting framework for discriminatory‑treatment claims)
- Burdine v. Texas Dep’t of Comm’y Affairs, 450 U.S. 248 (employer’s burden of production is one of production, not persuasion)
- St. Mary’s Honor Ctr. v. Hicks, 509 U.S. 502 (discusses inferences from prima facie case and proof of pretext)
- Gross v. FBL Fin. Servs., Inc., 557 U.S. 167 (holds plaintiff must prove but‑for causation under the ADEA)
- Patterson v. McLean Credit Union, 491 U.S. 164 (plaintiff not limited to one method to prove pretext; qualifications evidence probative)
- Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574 (summary judgment standard: review record as a whole)