A judge denied a discrimination petition filed by a city school administrator because other employees were qualified for the positions and because a move to leave three administrative positions unfilled was too broad of a request.

The Times obtained a written copy Tuesday of Senior Judge Hugh Lawson’s reasons for denying Dr. Artrice Haugabrook’s petition in federal court against the Valdosta City School System.

The ruling also noted that the school system had offered Haugabrook a position as principal, which she refused.

Haugabrook claimed the Valdosta Board of Education failed to properly advertise the assistant superintendent of operations position. She also asserted that the system discriminated based on race during the initial hiring process regarding the director of teaching and learning and 6-12 curriculum director positions.  She also wanted the court to remove an administrator from the assistant superintendent of operations position and have the system advertise the 6-12 curriculum director position.

She filed discrimination charges with the Equal Opportunity Employment Commission in July, alleging that the Valdosta City School System refused to hire her for three school administrative positions because of her race and gender. The petition alleges violations of Title VII, the 14th Amendment and state law.

Based on the information provided, the judge ruled to deny this petition under success of merits and irreparable injury.  

SUCCESS ON MERITS

In claiming Title VII failure to promote claims, a plaintiff must prove that he or she is a member of a protected class, qualified for and applied for the promotion, was rejected and that other equally or less qualified employees who were not members of the protected class were promoted.

Lawson ruled that Haugabrook presented sufficient evidence regarding a prima facie case of race and sex discrimination; however, he added, a plaintiff must establish that the employer’s legitimate nondiscriminatory reason for the hiring decision was merely a pretext for unlawful discrimination.

During the hearing, the school system asserted that a nondiscriminatory reason for failing to promote Haugabrook was that the director of teaching and learning and 6-12 curriculum director positions would require a 12-month contract and additional work hours. According to the school system, Haugabrook expressed disinterest in a 12-month contract and did not want a job requiring more than 40 hours of work each week.

“The defendant’s reason is a subjective one,” Lawson notes, “but it constitutes a sufficient legitimate, nondiscriminatory reason.”

Haugabrook also claimed that another school employee, Scarlet Correll, was unqualified for the superintendent’s recommendation for the director of teaching and learning. However, Lawson ruled that Correll met the requirements for the position.

“In the court’s view, Correll’s administrative work as a psychologist and counselor can reasonably be interpreted as leadership experience,” the ruling states, as it exceeds the five- and 10-year requirements.

The ruling added that Haugabrook is more qualified than Correll in formal education, but based on the evidence presented Correll is qualified for either position.

Haugabrook’s other argument on the grounds of gender discrimination failed to establish pretext on the grounds that Alvin Hudson’s appointment to assistant superintendent of operations was discriminatory, the ruling states.

IRREPARABLE INJURY

The ruling states that Haugabrook’s request to block the filling of three positions is too broad. Haugabrook can only fill one position and it is apparent that she wishes to remain in administration. Since Haugabrook applied for three positions, it is also clear that she does not seek any particular administrative position within the school district.

“Dr. Haugabrook has presented no evidence establishing that in the future there will be no administrative job openings within the Valdosta city school district,” the ruling states. “Thus, the court finds that in the event Dr. Haugabrook succeeds on her discrimination claims, there is a strong likelihood that there will be administrative positions available that Dr. Haugabrook would desire.”

FROM SCHOOL TO COURT

Haugabrook served as the director of student services until May 2010, until Valdosta City School System Superintendent Dr. Bill Cason demoted Haugabrook to an assistant principal position as part of a Reduction in Force Policy.

This demotion came, however, after Haugabrook refused a position as a principal, according to the ruling. After notice of the demotion, Haugabrook applied for two administrative positions: director of teaching and learning and 6-12 curriculum director.

The school system claimed Haugabrook’s claims of racial discrimination were unfounded.

During the July 16 hearing, the school system’s counsel moved to dismiss the petition on the basis that Haugabrook’s discrimination claims based on race were unfounded.

“The defendants asserted that there was no case or controversy because the school board had not voted to fill the director of teaching and learning or curriculum director positions,” the ruling states.

The defendants, according to the ruling, believe that until the school board hires Correll for either of the positions, Haugabrook has not been injured. The school system agreed to delay the board of education vote on the director of teaching and learning position until the hearing was held, the ruling states.

During a telephone conference on July 13, counsel for Haugabrook, based on information and belief, stated that the board of education would vote in favor of hiring Correll for the director of teaching and learning position.

The ruling goes on to state that that information, along with the account that Cason recommended Correll for the position, made the court believe that Haugabrook was in immediate or imminent danger of future injury.

This decision caused the school system’s motion to dismiss on these grounds to be denied.

On Monday, July 26, Correll was named the interim director of teaching and learning after the board of education approved the recommendation.

According to the Valdosta City School System, the system has spent $15,776 in legal fees in regards to the petition and hearing.