Thomas Taylor worked as a math and science teacher at School of the Woods. As a first-year teacher, the Head of School and the high school principal provided regular feedback to Taylor on lesson plans and assisted him with grading and assignment issues as they arose. The School contended that Taylor refused to take constructive criticism, communicate consistently, or participate in any proposed collaborative efforts to help Taylor improve as a teacher.
Taylor is openly gay and believed his sexual orientation was the cause of what he considered harassment throughout his time at the School. In fact, Taylor said he told the Head of School via email of workplace harassment and said that the harassment was having a negative effect on his health. In the same email, Taylor requested reasonable accommodations to address his health concerns and to stop the harassment.
In response, the Head of School scheduled a meeting for May 5, 2021, which Taylor alleged did not occur. On June 12, 2021, the Head of School informed Taylor that the School was not renewing his employment contract.
Taylor filed suit against the School claiming (1) discrimination based on sexual orientation under Title VII; and (2) disability discrimination under the Americans with Disabilities Act (ADA).
Taylor argued that he was discriminated against on the basis of his sexual orientation based on subjective beliefs that he developed after receiving constructive criticism and instruction.
To establish a prima facie case of discrimination under Title VII, a plaintiff must show he: (1) is a member of a protected class; (2) was qualified for his position; (3) was subject to an adverse employment action; and (4) was replaced by someone outside the protected class, or, in the case of disparate treatment, shows that others similarly situated were treated more favorably.
The School argued that Taylor failed to establish a case of discrimination based on sexual orientation because he failed to identify a similarly situated employee that was treated more favorably. In fact, Taylor admitted in his deposition that all teachers were required to provide their study guides and receive feedback from the Head of School. The School argued that it could demonstrate legitimate, non-discriminatory reasons for its decisions. Specifically, Taylor’s performance as a teacher and his unwillingness to collaborate or communicate with the administrators who were trying to help him improve.
Taylor argued that the reasons were pretext, and he was harassed based on his sexual orientation. Taylor also argued that the School’s subsequent positive reference when later seeking a substitute teacher job was proof of pretext.
The Court concluded that there was insufficient evidence to establish discrimination. The Court reasoned that, during the two years Taylor worked at the School, multiple complaints from students and parents were reported about Taylor’s lesson plans and overall ability as a teacher. For example, nine of eleven students in Taylor’s pre-calculus course raised various concerns, including that he was dismissive and unapproachable, and the students relied on other teachers (and students) to teach them pre-calculus. When the School attempted to mentor and aid Taylor in improving as a teacher, Taylor responded by making accusations against the principal and not cooperating with the School’s attempt to improve his teaching ability.
The Court concluded that the School had legitimate concerns about Taylor’s teaching ability, supported by numerous complaints from students, parents, and student advisors. The School sought to assist Taylor in improving and succeeding as a teacher. Other junior teachers in similar positions were open to constructive feedback and worked with the School to improve. Taylor, on the other hand, was combative and adverse to any plan for improvement. Taylor considered any critique or administrative meeting “harassment,” creating an impasse between the administration and Taylor. The Court concluded that the School had legitimate, nondiscriminatory reasons for terminating Taylor’s employment.
The Court did not find persuasive that providing a recommendation for a new job as a substitute teacher was proof of pretext. The School reasoned that a substitute teacher does not plan the curriculum or have the responsibility for the students’ ultimate success. The Court concluded that this showed the School had no ill will toward Taylor or his future success. The Court granted summary judgment on Taylor’s sexual orientation discrimination claim.
For Taylor’s disability discrimination claim, Taylor argued that he was experiencing high blood pressure, agitation, and sleepless nights as a direct consequence of the treatment he experienced at the School. The School argued that Taylor did not provide any evidence that he was treated differently or subjected to adverse employment actions due to a disability or a perceived disability, and Taylor never requested a reasonable accommodation.
The Court said that merely stating that Taylor was experiencing these conditions did not establish a disability under the ADA. Taylor did not provide a doctor’s note, diagnosis, medical information, or evidence of disability, either at the time or throughout discovery. The Court concluded that Taylor failed to prove that he had a disability under the ADA. The Court granted the School’s motion for summary judgment.
Note: This school was able to dispute that their decision to terminate the teacher was based on a discriminatory motive because they had documented concerns about the teacher’s performance, including from parents and students, and they had addressed these concerns by working with the teacher and providing regular feedback.
Taylor v. Sch. of the Woods (S.D.Tex. Feb. 22, 2024) 2024 U.S.Dist.LEXIS 30181.