Duggins v. Appoquinimink School District

921 F. Supp. 2d 283, 2013 WL 472283, 2013 U.S. Dist. LEXIS 15297
CourtDistrict Court, D. Delaware
DecidedFebruary 5, 2013
DocketC.A. No. 12-72-MPT
StatusPublished

This text of 921 F. Supp. 2d 283 (Duggins v. Appoquinimink School District) is published on Counsel Stack Legal Research, covering District Court, D. Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Duggins v. Appoquinimink School District, 921 F. Supp. 2d 283, 2013 WL 472283, 2013 U.S. Dist. LEXIS 15297 (D. Del. 2013).

Opinion

MEMORANDUM ORDER

MARY PAT THYNGE, District Judge.

I. INTRODUCTION

This is an employment discrimination case. On January 1, 2012, Felicia R. Dug-gins (“Duggins”) filed suit against the Appoquinimink School District (“District”) alleging violations of the Rehabilitation Act of 1973 § 501 et seq., 29 U.S.C. § 791 et seq. and the Americans with Disabilities Act of 1990, 42 U.S.C. § 12111 et seq. (“ADA”), the Family Medical Leave Act, 29 U.S.C. § 2601 (“FMLA”), and Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e-2(a) (“Title VII”).1 Duggins claims that she was wrongly demoted by defendant. Currently before the court is the District’s motion for summary judgment.

II. BACKGROUND2

Felicia Duggins has worked in the educational field since 1992. After eleven years in the Christiana School District employed as a high school teacher, she was promoted to an Assistant Principal position in 2003 within the Appoquinimink School District. In 2007, she was promoted to a Principal position at the newly-built Appoquinimink High School (“AHS”). Duggins was a principal at AHS for approximately two years.

During this time, Duggins was involved in several incidents within the capacity of her position. Duggins was periodically evaluated by the District and by the teachers of AHS. After her first year, her initial evaluation in August 2008 as Principal was relatively positive. Following her second year, a series of reviews placed her performance significantly lower. Both the teacher surveys conducted in March 2009 and her summative evaluation in July 2009 revealed failures in leadership. This summative evaluation stated the morale of the teachers was low due to her ineffective leadership; she behaved in an unprofessional fashion; and her performance required improvement. In addition, Duggins missed at least two key meetings involving both her superiors and the parents of her students. During this time, Duggins alleges she was exhausted due to a significant workload, at least one racially charged encounter with a parent, and a diagnosis of severe depression. In March 2009, the District required Duggins to submit to a drug test in light of her behavior. The results were negative for illegal substances.

In April 2009, at a meeting with the Deputy Superintendent of the District and [288]*288her mentor, Dr. Marion Profitt, Duggins was notified by Dr. Profitt that her performance had not improved. Duggins alleges her depression worsened until she took medical leave under the FMLA from May 13, 2009 through June 22, 2009, which was approved by the District. Upon her return, Duggins was informed she had been reassigned as the Assistant Principal for Middletown High School. For two years thereafter, she continued to receive her salary at a Principal’s rate, until July 1, 2011, when her pay was reduced, consistent with the level of the position as Assistant Principal.

On August 21, 2009, Duggins filed a racial and disability discrimination charge with the Equal Employment Opportunity Commission (“EEOC”). The EEOC subsequently issued a right to sue letter on October 26, 2011.3

III. STANDARD OF REVIEW

A. Standard on Motion for Summary Judgment

Summary judgment is appropriate if the “pleadings, the discovery and disclosure materials on file, and any affidavits show that there is no genuine issue as to any material fact and the movant is entitled to a judgment as a matter of law.”4 Once there has been adequate time for discovery, Fed.R.Civ.P. 56(c) mandates judgment against the party who “fails to make a sufficient showing to establish the existence of an element essential to that party’s case, and on which that party will bear the burden of proof at trial.”5 When a party fails to make such a showing, “there can be no ‘genuine issue as to any material fact’ since a complete failure of proof concerning an essential element of the non-moving party’s case necessarily renders all other facts immaterial.”6 The moving party is therefore entitled to judgment as a matter of law because “the nonmoving party has failed to make a sufficient showing on an essential element of her case with respect to which she has the burden of proof.”7 A dispute of material fact exists where “the evidence is such that a reasonable jury could return a verdict for the nonmoving party.”8

The moving party bears the initial burden of identifying portions of the record which demonstrate the absence of a genuine issue of material fact.9 However, a party may move for summary judgment with or without supporting affidavits.10 Therefore, “the burden on the moving party may be discharged by ‘showing’ — that is, pointing out to the district court — that there is an absence of evidence supporting the nonmoving party’s case.” 11

If the moving party has demonstrated an absence of material fact, the nonmoving party must then “come forward with specific facts showing that there is a genuine issue for trial.”12 If the nonmoving party bears the burden of proof at trial, he “must go beyond the pleadings in order to survive a motion for summary judg[289]*289ment.”13 That party “may not rest upon the mere allegations or denials of his pleadings, but must set forth specific facts showing that there is a genuine issue for trial.”14 At the summary judgment stage, the court is not to “weigh the evidence and determine the truth of the matter, but to determine whether there is a genuine issue for trial.”15 Further, “there is no issue for trial unless there is sufficient evidence favoring the nonmoving party for a jury to return a verdict for that party.” 16 The threshold inquiry therefore is “determining whether there is a need for trial— whether, in other words, there are any genuine factual issues that properly can be resolved only by a finder of fact because they may reasonably be resolved in favor of either party.”17

B. The McDonnell Douglas Standard

Both Duggin’s disability claim and her FMLA claim are analyzed under the framework set forth in McDonnell Douglas Corp. v. Green.18 This analysis is comprised of three separate phases. In the initial phase, a plaintiff bears the burden of establishing a prima facie case of discrimination or retaliation.19 If the plaintiff successfully presents a prima facie case, the burden then shifts “to the employer to articulate some legitimate, nondiscriminatory reason” for the adverse employment action.20

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Bluebook (online)
921 F. Supp. 2d 283, 2013 WL 472283, 2013 U.S. Dist. LEXIS 15297, Counsel Stack Legal Research, https://law.counselstack.com/opinion/duggins-v-appoquinimink-school-district-ded-2013.