Raines v. Seattle School District No 1
2:09-cv-00203
W.D. Wash.Feb 7, 2013Background
- Raines is a black woman over 40 who worked for Seattle School District No. 1 from 1971 to 2010 as a teacher and then a principal.
- She brings WLAD claims for race, gender, and age discrimination and retaliation; her response relies on a single declaration with no factual support for race/gender/retaliation.
- The court grants summary judgment on race, gender, and retaliation claims, dismissing those with prejudice.
- The remaining WLAD claim is age discrimination; Raines alleges harassment by Patrick Johnson from 2007 to 2010 aimed at retirement.
- Johnson allegedly placed her on a Plan of Assistance, forced her into a Principal Improvement Plan, transferred her to another school, and required frequent meetings; she retired in 2010 after FMLA leave.
- The court analyzes whether the retirement constitutes a constructive discharge and whether the “terms or conditions” of employment were adversely affected.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Raines was constructively discharged for age discrimination | Raines contends Johnson’s actions made conditions intolerable, forcing retirement | Johnson's actions did not render working conditions intolerable; retirement was voluntary | No genuine issue; Raines failed to show constructive discharge |
| Whether any actions by Johnson altered terms or conditions of employment to support age discrimination | Disciplinary steps and transfers affected her employment due to age | Actions did not have a tangible impact on salary or duties | No actionable adverse action; no evidence of impact on pay or responsibilities |
Key Cases Cited
- Short v. Battle Ground School Dist., 169 Wn. App. 188, 279 P.3d 902 (2012) (constructive-discharge standard; intolerable conditions and resignation presumption)
- Tyner v. Wash., 137 Wn. App. 545, 154 P.3d 920 (2007) (adverse action requires more than inconvenience; tangible impact needed)
- Kirby v. City of Tacoma, 124 Wn. App. 454, 98 P.3d 827 (2004) (tangible impact on workload/pay necessary for adverse action)
- Hill v. BCTI Income Fund-I, 144 Wn.2d 172, 23 P.3d 440 (2001) (adopts McDonnell Douglas framework for age discrimination)
- Crownover v. Dep’t of Transp., 165 Wn. App. 131, 265 P.3d 971 (2011) (comparators and evidence needed to support age-discrimination claim)