Bouknight v. South Carolina Department of Corrections

CourtDistrict Court, D. South Carolina
DecidedSeptember 16, 2020
Docket3:19-cv-00456
StatusUnknown

This text of Bouknight v. South Carolina Department of Corrections (Bouknight v. South Carolina Department of Corrections) is published on Counsel Stack Legal Research, covering District Court, D. South Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bouknight v. South Carolina Department of Corrections, (D.S.C. 2020).

Opinion

GSES DSR Ky 6, ‘A * ae iG x nS oS IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF SOUTH CAROLINA COLUMBIA DIVISION FRANCES S. BOUKNIGHT, § Plaintiff, § § VS. § CIVIL ACTION NO. 3:19-0456-MGL § SOUTH CAROLINA DEPARTMENT OF § CORRECTIONS, § Defendant. § ORDER ADOPTING THE REPORT AND RECOMMENDATION AND GRANTING IN PART AND DENYING IN PART DEFENDANT’S MOTION FOR SUMMARY JUDGMENT I. INTRODUCTION Plaintiff Frances S. Bouknight (Bouknight) filed this lawsuit against her former employer, Defendant South Carolina Department of Corrections (SCDOC), alleging Title VII claims ofhostile work environment, constructive discharge, sex discrimination, and retaliation. The Court has federal question jurisdiction over this action in accordance with 28 U.S.C. § 1331. The matter is before the Court for consideration of the Magistrate Judge’s Report and Recommendation (Report) suggesting SCDOC’s motion for summary judgment be granted in part and denied in part. Specifically, she recommends the Court grant SCDOC’s motion for summary judgment as to Bouknight’s claims of hostile work environment, constructive discharge, and sexdiscrimination, and deny it as to her retaliation cause of action. The Magistrate Judge submits

the Report in accordance with 28 U.S.C. § 636 and Local Civil Rule 73.02 for the District of South Carolina. The Magistrate Judge makes only a recommendation to this Court. The recommendation has no presumptive weight. The responsibility to make a final determination remains with the Court.

Mathews v. Weber, 423 U.S. 261, 270 (1976). The Court is charged with making a de novo determination of those portions of the Report to which specific objection is made, and the Court may accept, reject, or modify, in whole or in part, the recommendation of the Magistrate Judge or recommit the matter with instructions. 28 U.S.C. § 636(b)(1). The Magistrate Judge filed the Report on May 29, 2020, Bouknight and SCDOC filed their objections on June 26, 2020, and they filed their replies to each others’ objections on July 10, 2020. The Court has reviewed the objections from both parties, but holds them to be without merit. It will therefore enter judgment accordingly.

II. FACTUAL AND PROCEDURAL HISTORY Bouknight is woman who served as the Adult Education Director for the Palmetto Unified School District (the District) beginning in the fall of 2011. The District operates within the South Carolina Department of Corrections. Bouknight’s supervisor, Randy Reagan (Reagan), was, at all relevant times to this lawsuit, Superintendent of the District. In Bouknight’s position as the Adult Education Director, she supervised around fifty percent of the school leaders in the District’s correctional facilities. This included hiring, monthly training, in-school observation, annual reviews, and discipline.

2 Although Bouknight and Reagan’s working relationship was initially pleasant, it began to sour in late 2015 to early 2016. The Magistrate Judge provides the following list of events, as Bouknight describes them, that are pertinent to her lawsuit against SCDOC: Late November 2015 Reagan directs “angry outburst” toward Bouknight in front of other SCDC employees. December 2015 Angry outburst in front of Principal Paul Martin [(Martin)]. Martin expresses concern to Bouknight about Reagan’s behavior. Mid-January 2016 Reagan treats Bouknight in an “angry manner” and excludes her from work duties. January 29, 2016 Reagan makes “venomous” comments to Bouknight during weekly staff meeting. March [4-8], 2016 Reagan confronts Bouknight about coworkers’ reports that she had said to others that he was a “poor leader.” Bouknight denies making this statement, but is issued [a Memorandum of Understanding] for “insubordination.” March 21, 2016 Reagan removes two employees from Bouknight’s supervision. April 4, 2016 Reagan directs “anger and blame” toward Bouknight at a meeting. Bouknight reports concerns to Human Resources about Reagan’s behavior toward her. April 15, 2016 Meeting with Human Resources: Reagan is informed of Bouknight’s complaints about his “bullying.” April 27, 2016 Reagan gives Bouknight a negative performance evaluation. [May 12, 2016. Reagan learns of Bouknight’s purported failure to inform him of her prior relationship with an applicant for a position at the District.] May16, 2016 Reagan reassigns duties away from Bouknight. June 7-9, 2016 Bouknight complains of retaliation to Reagan’s supervisor and Human Resources. Reagan takes away staff assistant to Bouknight. . . . July 19-26, 2016 Reagan changes Bouknight’s position description to remove supervisory duties. August 1-18, 2016 Bouknight complains to Reagan’s supervisor and legal counsel and has several meetings with them. August 19, 2016 Reagan removes all supervisory duties from Bouknight. August 22, 2016 Bouknight files Sexual Harassment/Hostile Work Environment Complaint with [SCDOC]. September 15, 2016 Reagan receives a written warning after investigation of Bouknight’s complaint. Early 2017 Reagan summons Bouknight to a meeting with Martin and berates Bouknight. March 28, 2017 Reagan “acts out in anger” toward Bouknight. Bouknight reports the outburst in an Incident Report to Human Resources on May 23, 2017. April 25-26, 2017 Reagan “ridicules and screams at Bouknight” in front of staff. April 26, 2107 Bouknight complains to Reagan’s supervisor. May 23, 2017 Bouknight reports the March and April 2017 outbursts in an Incident Report to Human Resources. May 31, 2017 Bouknight is demoted [and reassigned from being the Adult Education Director for the 4 District to being a teacher at the District’s Manning High School.] June 8, 2017 Bouknight grieves her demotion. Grievance is denied [on] June 19, 2017. June 6, 2017 Bouknight begins medical leave. July 13, 2017 Bouknight files an EEOC Charge. August 11, 2017 Bouknight resigns. Report at 2-3 (punctuation modified). Bouknight subsequently filed suit against SCDOC in the Richland County Court of Common Pleas. SCDOC removed the case to this Court; and thereafter filed a motion for summary judgment as to all of Bouknight’s claims, Bouknight filed a response in opposition, and SCDOC filed a reply. As the Court noted above, after the Magistrate Judge considered the motion, she suggested the Court grant SCDOC’s motion for summary judgment as to Bouknight’s claims of hostile work environment, constructive discharge, and sex discrimination, and deny it as to her retaliation cause

of action.

III. DISCUSSION AND ANALYSIS In considering Bouknight’s Title VII claims, because hers is a circumstantial case, the Court must employ the familiar burden-shifting scheme set out in McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973). Under the McDonnell Douglas framework, an employee must first establish a prima facie case of her Title VII claims. Id. at 802. Only if the employee successfully demonstrates a prima facie case does the burden shift to

the employer to articulate some legitimate, non-retaliatory reason for the adverse employment action. Id. If the employer does so, the burden shifts back to the employee to show that the articulated reason was actually a pretext for discrimination. Id. at 804. A. Bouknight’s Objections Bouknight lodges fourteen objections to the Magistrate Judge’s recommendation the Court grant SCDOC’s motion for summary judgment as to her hostile work environment, constructive discharge, and sex discrimination causes of action.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

McDonnell Douglas Corp. v. Green
411 U.S. 792 (Supreme Court, 1973)
Mathews v. Weber
423 U.S. 261 (Supreme Court, 1976)
Harris v. Forklift Systems, Inc.
510 U.S. 17 (Supreme Court, 1993)
Pennsylvania State Police v. Suders
542 U.S. 129 (Supreme Court, 2004)
Okoli v. City of Baltimore
648 F.3d 216 (Fourth Circuit, 2011)
Reeves v. Sanderson Plumbing Products, Inc.
530 U.S. 133 (Supreme Court, 2000)
Reya Boyer-Liberto v. Fontainebleau Corporation
786 F.3d 264 (Fourth Circuit, 2015)
Hartsell v. Duplex Products, Inc.
123 F.3d 766 (Fourth Circuit, 1997)
DeJarnette v. Corning Inc.
133 F.3d 293 (Fourth Circuit, 1998)
Jordan v. Alternative Resources Corp.
467 F.3d 378 (Fourth Circuit, 2006)
Green v. Brennan
578 U.S. 547 (Supreme Court, 2016)
Felicia Strothers v. City of Laurel, Maryland
895 F.3d 317 (Fourth Circuit, 2018)
Tamika Ray v. International Paper Company
909 F.3d 661 (Fourth Circuit, 2018)

Cite This Page — Counsel Stack

Bluebook (online)
Bouknight v. South Carolina Department of Corrections, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bouknight-v-south-carolina-department-of-corrections-scd-2020.