Shinic Davis v. Quaker Valley School District
693 F. App'x 131
| 3rd Cir. | 2017Background
- E.D., the only African-American student in his second-grade class at Osborne Elementary (QVSD), exhibited frequent disruptive emotional and physical outbursts during the 2011–2012 school year.
- Teacher Lindemann documented E.D.’s behavior, proposed and helped implement a tailored RTII (Responsive to Instruction and Intervention) behavioral plan that included classroom removal as a last resort. E.D. was suspended in May 2012.
- Plaintiff Shinic Davis repeatedly complained that Lindemann treated E.D. more harshly than non-minority classmates and filed a PHRC complaint; she also threatened litigation and refused to participate in the RTII plan.
- Davis identified D.I., a Caucasian classmate placed on an RTII plan, as a comparator but lacked evidence that D.I.’s misconduct was as frequent or severe as E.D.’s; pre-plan teacher notes for D.I. were not preserved.
- The District Court granted summary judgment for defendants, finding Davis failed to establish prima facie discrimination or retaliation; the Third Circuit affirmed on the prima facie grounds and declined to reach pretext.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Davis established a prima facie race‑discrimination claim for E.D. via a comparator | Davis: D.I. (non‑minority) engaged in similar conduct but was treated more favorably | Defs: D.I. was not "alike in all relevant aspects"—no evidence his misconduct matched E.D.’s frequency/intensity; RTII plans differ | Held: D.I. is not a valid comparator; prima facie discrimination not established |
| Whether spoliation inference should apply to missing pre‑RTII notes for D.I. | Davis: Missing notes would show comparator similarity; asks for adverse inference | Defs: No duty to preserve those notes; no evidence of bad faith suppression | Held: Denied—no reasonably foreseeable duty to preserve and no bad faith; no spoliation inference |
| Whether Davis established prima facie retaliation (causal link) based on timing of complaints and subsequent teacher actions | Davis: Escalation of complaints (Jan 2012) followed by intensified note‑taking (Feb 1) and removals (Mar 1) shows retaliation | Defs: Actions (note‑taking, RTII, limited removals) were responses to escalating behavior and predate formal litigation; RTII was individualized and nonretaliatory | Held: Temporal and other evidence insufficient to infer causation; prima facie retaliation not shown |
| Whether summary judgment was appropriate overall | Davis: Disputed facts and inferences should preclude summary judgment | Defs: No triable issues; nondiscriminatory reasons unrebutted at prima facie stage | Held: Affirmed summary judgment for defendants (no prima facie discrimination or retaliation established) |
Key Cases Cited
- Blunt v. Lower Merion School Dist., 767 F.3d 247 (3d Cir. 2014) (standard for reviewing summary judgment)
- Bull v. United Parcel Serv., Inc., 665 F.3d 68 (3d Cir. 2012) (elements for spoliation inference)
- Startzell v. City of Phila., 533 F.3d 183 (3d Cir. 2008) (comparator must be alike in all relevant aspects)
- Carvalho‑Grevious v. Delaware State Univ., 851 F.3d 249 (3d Cir. 2017) (causation standard for retaliation claims)
- Pryor v. Nat’l Collegiate Athletic Ass’n, 288 F.3d 548 (3d Cir. 2002) (Title VI and §1981 discrimination principles)
- Marra v. Phila. Hous. Auth., 497 F.3d 286 (3d Cir. 2007) (broad array of evidence may establish causation)
- Williams v. Phila. Hous. Auth. Police Dep’t, 380 F.3d 751 (3d Cir. 2004) (temporal gap alone may be insufficient for causation)
- Kachmar v. SunGard Data Systems, Inc., 109 F.3d 173 (3d Cir. 1997) (motives inquiry for causation is context‑specific)