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Court dismisses female principal's gender discrimination claim against School System

Kimberley Ann Hart sued the Goodrich Area Schools and the President of the School Board alleging gender discrimination.  One month after executing a new one-year contract with Hart, the Board suspended her with pay and banned her from the school premises.  No fool, Hart immediately began applying for other jobs and secured a three-year contract with another school district at a higher pay rate.  She then sued her past employer, alleging that it had illegally discriminated against her and retaliated when she complained.

The School System sought summary disposition of Hart's claim.  It argued that she had not suffered any adverse employment action by reason of the suspension, and that she hadn't proved a discriminatory or illegal motivation for the Board's actions.  With regard to the suspension, the Court held that the fact of the suspension wasn't proof of an adverse employment action, because she continued to receive her paycheck.  The Court acknowledged that such a suspension was humiliating and could led to difficulties in future employment, but maintained that Hart's lawyers had not submitted proof of such an impact.

With regard to the Board's motivation, Hart pointed to the fact of a demeaning comment about "this young lady" offered at a public meeting by Michael Tripp, the President of the School Board, and the acknowledgement by three board members of male-female issues that contributed to her suspension.  The higher court held that these facts did not create a sufficient basis for a reasonable jury to find an inference of gender discrimination.  It based this decision in part on the fact that the offensive "young lady" comment was not made in a context directly related to Hart's employment status.

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