Pamela Azar v. Town of Lincoln
173 A.3d 862
| R.I. | 2017Background
- Pamela Azar, a former Lincoln School Department employee, sued the Town of Lincoln, Lincoln School Committee, and Finance Director John Ward alleging employment discrimination and retaliation for advocating for her disabled son's education; suit filed August 2012.
- Azar claimed a hostile work environment after Lincoln filed truancy charges against her son (2006 and later 2009) and that the 2009 charges were retaliatory for her advocacy about her son’s placement.
- At trial (June 2016) Azar testified about exclusion and being summoned to the office; witnesses described strained relations between Azar and colleagues centered on disputes over her son’s placement.
- Defendants presented testimony that Azar’s son missed nearly a full school year (2008–2009) and that Lincoln had legitimate grounds under §16-19-1 to file truancy charges.
- After both sides rested, defendants moved for judgment as a matter of law; the trial justice held hostile-work-environment claims time-barred and found insufficient evidence of retaliation, and granted judgment for defendants.
- On appeal, the Supreme Court reviewed de novo and affirmed: hostile-work-environment claims were untimely, CRPDA retaliation claim failed for lack of administrative exhaustion, and RICRA retaliation lacked proof of pretext.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether plaintiff proved a timely hostile work environment | Azar argued conduct beginning in 2006–2008 produced a hostile environment | Lincoln argued the complained-of acts occurred before the statutory period and could not support a claim | Hostile-work-environment claims barred: alleged acts occurred before leave in Oct 2008 and outside limitations period |
| Whether plaintiff exhausted administrative remedies under the CRPDA | Azar proceeded in court without filing with RI Commission for Human Rights | Lincoln argued exhaustion is required before suit under CRPDA | CRPDA retaliation claim dismissed for failure to exhaust administrative remedies |
| Whether filing of 2009 truancy charges was retaliatory under RICRA | Azar contended charges were retaliatory due to disagreement over son's placement | Lincoln argued charges were legally justified due to the son’s extended absences | Court assumed prima facie case but held Lincoln offered legitimate, nondiscriminatory reason; Azar failed to show pretext; judgment for defendants |
| Whether dismissal of truancy charges indicated retaliation | Azar suggested dismissal showed retaliatory motive or pretext | Lincoln showed dismissal corresponded to resolution of placement and return to school | Dismissal insufficient to show pretext or discriminatory motive; no retaliation proven |
Key Cases Cited
- Roach v. State, 157 A.3d 1042 (R.I. 2017) (standard of review for Rule 50 motions)
- McGarry v. Pielech, 47 A.3d 271 (R.I. 2012) (burden-shifting framework and standard for evaluating sufficiency of evidence)
- Crowley v. L.L. Bean, Inc., 303 F.3d 387 (1st Cir. 2002) (timing rule for hostile-work-environment claims and continuing-violation analysis)
- National Railroad Passenger Corp. v. Morgan, 536 U.S. 101 (U.S. 2002) (scope of hostile-work-environment claims and timely acts requirement)
- Richardson v. Rhode Island Department of Education, 947 A.2d 253 (R.I. 2008) (requirement to exhaust administrative remedies before court under state statute)
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (U.S. 1973) (three-step burden-shifting framework for discrimination/retaliation claims)