Rodney G. Brown v. Shelby County Board of Education
17-11089
| 11th Cir. | Dec 19, 2017Background
- Rodney Brown, an African-American special-education teacher, applied from 2009–2013 for 11 administrator/assistant principal openings with the Shelby County Board of Education.
- Brown possessed a master’s in special education (2005) and state certification as an educational administrator (2006).
- Brown alleges the Board hired less-qualified white applicants for each position, and for three rejections he also claimed retaliation after filing an EEOC charge.
- The Board produced specific, nondiscriminatory reasons for each hire: selected candidates had more relevant experience and performed better in interviews.
- The district court granted summary judgment to the Board, finding the Board’s reasons legitimate and Brown failed to show pretext or causal link for retaliation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Race discrimination in hiring | Brown: Board repeatedly passed him over for less-qualified white candidates; this pattern shows discriminatory motive | Board: Selected candidates were more qualified, had more leadership/age-group experience, and interviewed better — legitimate nondiscriminatory reasons | Affirmed: Board met its burden; Brown failed to show the reasons were false or that race was the real reason |
| Retaliation after EEOC charge | Brown: Three non-hires were motivated by retaliation for his prior EEOC charge | Board: Non-hires were based on qualifications and interview performance — legitimate non-retaliatory reasons | Affirmed: Even assuming prima facie case, Brown failed to show pretext or causal link |
Key Cases Cited
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (establishes burden-shifting framework for circumstantial discrimination claims)
- Vessels v. Atlanta Indep. Sch. Sys., 408 F.3d 763 (11th Cir. 2005) (summary judgment review standard and viewing evidence for nonmovant)
- Rice-Lamar v. City of Ft. Lauderdale, 232 F.3d 836 (11th Cir. 2000) (section 1981 elements same as Title VII in employment context)
- Crawford v. Carroll, 529 F.3d 961 (11th Cir. 2008) (plaintiff bears ultimate burden to prove discrimination by preponderance)
- Kidd v. Mando Am. Corp., 731 F.3d 1196 (11th Cir. 2013) (plaintiff cannot establish pretext merely by showing superior qualifications)
- Chapman v. AI Transp., 229 F.3d 1012 (en banc) (employer’s credible interview-performance reason can be legitimate nondiscriminatory reason)
- Damon v. Fleming Supermarkets of Fla., Inc., 196 F.3d 1354 (11th Cir. 1999) (court’s role is to detect discriminatory animus, not to second-guess employment decisions)
- Chapter 7 Tr. v. Gate Gourmet, Inc., 683 F.3d 1249 (11th Cir. 2012) (elements of retaliation claim and causation requirement)
- Brown v. Ala. Dep’t of Transp., 597 F.3d 1160 (11th Cir. 2010) (burden-shifting in retaliation context and proving pretext)
