James Napier served as Director of the Middle School at Orchard School in Indiana. He was hired in 2016 and early in his tenure he was part of an all-male senior leadership team that some within the school community perceived as having a “frat boy” culture, which had drawn concern from faculty and board members even before a leadership change. In 2018, the School’s Board of Trustees hired Dr. Sherri Helvie as the new Head of School. Helvie, who held advanced degrees with an emphasis in women’s studies, promptly reorganized the School’s administrative structure. As part of this reorganization, she removed Napier from the Senior Administrative Team, although he retained his salary and most of his responsibilities.
Tensions emerged between Helvie and Napier during her first year. One early conflict involved Napier approving the posting of a job opening after Helvie had told him to wait. A more significant issue arose when Helvie began evaluating the necessity of two coordinator roles at the School, including one held by Angela Brothers. Helvie tasked Napier with updating the job description for the Middle School Coordinator position and, according to the School, directed that the task remain confidential. Napier disputed whether he was explicitly told to maintain secrecy but admitted he shared information about the review with Brothers, who was understandably distressed by the news. Helvie viewed this disclosure as a breach of trust and, shortly thereafter, informed Napier that his contract would not be renewed.
Following his termination, Napier wrote to the Board raising concerns about Helvie’s conduct but did not initially allege discrimination. He completed the school year and later reapplied for the same position, which had been publicly posted. The School declined to rehire him, and Brothers was ultimately appointed to the role. Napier filed suit, alleging sex discrimination and retaliation under Title VII.
To survive summary judgment on a Title VII discrimination claim, a plaintiff must either present direct evidence of discriminatory intent or proceed under the burden-shifting framework established in McDonnell Douglas Corp. v. Green. Under that approach, a plaintiff must first establish a prima facie case of discrimination by showing that he is a member of a protected class, was meeting his employer’s legitimate expectations, suffered an adverse employment action, and was treated less favorably than a similarly situated individual outside his protected class. If he does so, the burden shifts to the employer to articulate a legitimate, non-discriminatory reason for the adverse action. The plaintiff must then demonstrate that this reason is pretextual—that is, not the true reason for the employer’s decision.
Napier argued that his termination was motivated by sex bias, pointing to earlier concerns among some board members about an all-male leadership team and remarks allegedly made by other administrators about there being too many white men in leadership. He also sought to establish pretext by comparing his treatment to that of female employees whom he claimed were treated more favorably. The School, however, maintained that Helvie terminated Napier solely because of his breach of administrative trust, not because of his sex. The School emphasized that Helvie alone made the decision to terminate Napier, without input from the Board or other administrators.
The Seventh Circuit affirmed summary judgment for the School. The Court held that Napier had not presented sufficient evidence for a reasonable factfinder to conclude that sex was the reason for his termination. The Court noted that even accepting Napier’s account of events, he conceded that he disclosed confidential information about a staff member’s position and that Helvie had consistently identified this breach of trust as the basis for her decision. The Court declined to infer discriminatory intent from Helvie’s academic background, speculative claims about her comfort with certain male employees, or her decision to restructure the leadership team. The comparator evidence was also deemed insufficient, as the individuals Napier identified were not similarly situated in terms of role, responsibilities, or the nature of their conduct.
Napier’s retaliation claim also failed. Retaliation under Title VII requires a showing that the employee engaged in protected activity, suffered a materially adverse employment action, and that there was a causal link between the two. The Court acknowledged that Napier’s discrimination complaint constituted protected activity and that the School’s refusal to rehire him qualified as an adverse action. However, the Court concluded that Napier failed to establish the required causal connection. The administrator who led the rehiring process was not privy to all the details of Napier’s termination but was aware of his strained relationship with Helvie and believed she had valid concerns. The Court found no evidence that the decision not to rehire Napier was motivated by retaliation for his complaint, rather than by continued concerns about his prior conduct.
The Court upheld the trial court’s decision and dismissed the complaint.
Napier v. Orchard Sch. Found. (7th Cir. 2025) 2025 U.S. App. LEXIS 11955.
Note: LCW covered this case previously. This case illustrates the importance for schools of having clear, consistent, and well-documented reasons for employment decisions.