Preddie v. Bartholomew County Consolidated School Corp.
44 F. Supp. 3d 800
S.D. Ind.2014Background
- Mr. Preddie, African-American, with diabetes and his son with sickle cell anemia, worked for BCSC as a fifth-grade teacher after a prior second-grade stint.
- BCSC non-renewed his Regular Teacher’s Contract for the 2011-2012 school year due to persistent classroom-management deficiencies and related complaints.
- Dr. Clancy, CSA-Fodrea principal, provided evaluations, assigned mentors, and cited ongoing performance issues despite remediation efforts.
- Preddie claimed disability-based discrimination and retaliation under Title VII, §1981, ADA, and attempted FMLA-related claims, including leave rights and accommodations.
- BCSC moved for summary judgment, arguing Preddie was not a qualified disabled employee, had not requested accommodations, and failed to establish a prima facie case or FMLA notice.
- The court granted summary judgment for BCSC on all counts, finding lack of evidence on ADA, Title VII/§1981 discrimination and retaliation, and FMLA interference/retaliation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| ADA failure to accommodate claim viability | Preddie asserts failure to accommodate for disability and retaliation for opposing practices. | BCSC contends Preddie was not a qualified individual with a disability and never requested an accommodation. | ADA claims fail; no qualified-disability basis or accommodation demand; summary judgment for BCSC. |
| Title VII/§1981 discrimination and retaliation viability | Preddie alleges race-based discrimination and retaliation for pursuing Title VII rights. | BCSC asserts he did not meet legitimate expectations and lacked evidence of intentional discrimination or pretext. | Claims fail; no admissible direct evidence or prima facie case with sufficient proofs; summary judgment for BCSC. |
| FMLA interference viability | Preddie contends FMLA rights were denied (interference). | BCSC argues no proper notice or entitlement was demonstrated by Preddie. | Interference claim fails; insufficient notice of intent to take FMLA leave; summary judgment for BCSC. |
| FMLA retaliation viability | Preddie claims adverse action tied to protected FMLA activity. | BCSC notes no protected FMLA activity was proven since leave was not pursued. | Retaliation claim fails; no protected activity shown; summary judgment for BCSC. |
Key Cases Cited
- Hemsworth v. Quotesmith.Com, Inc., 476 F.3d 487 (7th Cir.2007) (summary judgment standard; evidence review)
- Zerante v. DeLuca, 555 F.3d 582 (7th Cir.2009) (record viewed in light most favorable to nonmovant)
- Ritchie v. Glidden Co., 242 F.3d 713 (7th Cir.2001) (papers not a paper trial; avoid factual disputes from mere speculation)
- Chiara-monte v. Fashion Bed Grp., Inc., 129 F.3d 391 (7th Cir.1997) (no inference from mere metaphysical doubt; need material facts)
- Adelman-Tremblay v. Jewel Cos., 859 F.2d 520 (7th Cir.1988) (deference to deposition over subsequent affidavit)
- Babrocky v. Jewel Food Co., 773 F.2d 857 (7th Cir.1985) (affidavits must be consistent with deposition)
- Amadio v. Ford Motor Co., 238 F.3d 919 (7th Cir.2001) (reasonable accommodation analysis when capable of aiding performance)
- Everroad v. Scott Truck Systems, Inc., 604 F.3d 471 (7th Cir.2010) (evidence of performance standards; job expectations)
- Salvadori v. Franklin Sch. Dist., 293 F.3d 989 (7th Cir.2002) (satisfactory performance requirement at time of termination)
- King v. Preferred Technical Grp., 166 F.3d 887 (7th Cir.1999) (FMLA retaliation framework)
- Keeton v. Morningstar, Inc., 667 F.3d 877 (7th Cir.2012) (pretext standard for discrimination claims)
- Boumehdi v. Plas-tag Holdings, LLC, 489 F.3d 781 (7th Cir.2007) (pretext and weaknesses in employer's proffered reasons)
- Balderston v. Fairbanks Morse Engine Div. of Coltec. Indus., 328 F.3d 309 (7th Cir.2003) (courts do not reexamine business decisions)