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Rodney G. Brown v. Shelby County Board of Education
17-11089
| 11th Cir. | Dec 19, 2017
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Background

  • 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)
Read the full case

Case Details

Case Name: Rodney G. Brown v. Shelby County Board of Education
Court Name: Court of Appeals for the Eleventh Circuit
Date Published: Dec 19, 2017
Docket Number: 17-11089
Court Abbreviation: 11th Cir.