Gatsas v. Manchester SD

2006 DNH 127
CourtDistrict Court, D. New Hampshire
DecidedNovember 7, 2006
Docket05-CV-315-SM
StatusPublished

This text of 2006 DNH 127 (Gatsas v. Manchester SD) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Gatsas v. Manchester SD, 2006 DNH 127 (D.N.H. 2006).

Opinion

Gatsas v . Manchester SD 05-CV-315-SM 11/07/06 UNITED STATES DISTRICT COURT

DISTRICT OF NEW HAMPSHIRE

Katherine Gatsas, Plaintiff

v. Civil N o . 05-cv-315-SM Opinion N o . 2006 DNH 127 Manchester School District also known as School Administrative Unit N o . 3 7 , Defendant

O R D E R

Katherine Gatsas brings this discrimination suit against

Manchester School District, also known as School Administrative

Unit N o . 37 (“the District”), claiming that she was subjected to

disparate treatment based on gender, in violation of 42 U.S.C.

2000e-2(a) (Count I ) and a related state statute (Count I I ) . She

also asserts claims of retaliation (Count III) and wrongful or

retaliatory discharge (Count I V ) .

Defendant moves for summary judgment. For the reasons set

forth below, defendant’s motion for summary judgment is denied.

STANDARD OF REVIEW

Summary judgment is appropriate when the record demonstrates

“that there is no genuine issue as to any material fact and that

the moving party is entitled to a judgment as a matter of law.” F E D . R . C I V . P . 56(C). In considering a motion for summary

judgment, the court must view the record “in the light most

hospitable” to the nonmoving party. Euromodas, Inc. v . Zanella,

Ltd., 368 F.3d 1 1 , 17 (1st Cir. 2004) (citing Houlton Citizens’

Coalition v . Town of Houlton, 175 F.3d 1 7 8 , 184 (1st Cir. 1999);

Garside v . Osco Drug, Inc., 895 F.2d 4 6 , 48 (1st Cir. 1990)). An

issue is “‘genuine’ if the parties’ positions on the issue are

supported by conflicting evidence.” Int’l Ass’n of Machinists &

Aerospace Workers v . Winship Green Nursing Ctr., 103 F.3d 196,

200 (1st Cir. 1996) (citing Anderson v . Liberty Lobby, Inc., 477

U . S . 2 4 2 , 250 (1986)). An issue is “‘material’ if it potentially

affects the outcome of the suit.” Id. at 199-200.

In support of its summary judgment motion, the moving party

must “identify[] those portions of [the record] which . . .

demonstrate the absence of a genuine issue of a material fact.”

Celotex Corp. v . Catrett, 477 U . S . 3 1 7 , 323 (1986). If the

moving party successfully demonstrates the lack of a genuine

issue of material fact, “the burden shifts to the nonmoving party

. . . to demonstrate that a trier of fact reasonably could find

in [its] favor.” DeNovellis v . Shalala, 124 F.3d 2 9 8 , 306 (1st

Cir. 1997) (citing Celotex, 477 U . S . at 322-25). Once the burden

shifts, the nonmoving party “may not rest upon mere allegation[s]

2 or denials of his [or her] pleading, but must set forth specific

facts showing that there is a genuine issue for trial.”

Anderson, 477 U.S. at 256.

BACKGROUND

The facts, set forth in the light most favorable to Gatsas

are as follows. Gatsas has worked for the District since 1998,

starting out as a long-term substitute teacher and later becoming

a member of the full-time staff, teaching primarily sixth grade

science. (Def.’s Mot. Summ. J., Ex. A (Gatsas Employment R.))

Gatsas earned a bachelor’s degree in 1978 and a master of

education degree in 1990, both from Notre Dame College in

Manchester, New Hampshire. (Gatsas Employment R.) Gatsas also

holds elementary education and principal certifications, (Gatsas

Employment R . ) , as well as a general special education

endorsement, from the New Hampshire Department of Education.

(Def.’s Mot. Summ. J., Ex. Q.)

In early 2003, the District posted a job vacancy

announcement seeking an interim assistant principal for Hillside

Middle School (“Hillside” or “the School”), the school at which

Gatsas taught. (Def.’s Mot. Summ. J., Ex. B (Job Posting.)) The

announcement disclosed that the job qualifications included a

3 masters degree in educational administration “or equivalent

required for certification,” New Hampshire certification as a

principal, a statement of eligibility, or enrollment in an

accredited certification program, and experience as a certified

teacher. (Job Posting.) The posting also indicated that the

successful candidate would be a “visionary” as well as a

“collaborator who utilizes the strengths of staff, students,

parents, and community in creating a quality learning

environment.” (Job Posting.) Notwithstanding the qualifications

described in the job posting, “when the District considers

candidates for interim positions, [it is] often more flexible

with respect to hiring criteria.” (Def.’s Mot. Summ. J., Ex. C

(Bass Aff.) ¶ 4.)

Six people, three men and three women, including Gatsas,

applied for the position. (Writ ¶ 12.) Of the six, four were

already employed at Hillside in various other capacities.

(Def.’s Mot. Summ. J., Ex. D (Donohue Aff.) ¶ 4 . Each candidate

was interviewed by Stephen Donohue, the principal of the School,

and Joseph Ferrisi, the assistant principal, who selected two

finalists, William Dupere and Stephen Harrises, for consideration

by a final selection committee. (Donohue Aff. ¶ 8.) After the

screening committee reviewed the candidates, the superintendent

4 and assistant superintendent made the ultimate decision to

appoint M r . Dupere, then a guidance counselor at Hillside, to

fill the interim assistant principal vacancy. (Writ ¶ 12.)

Following Dupere’s appointment to the interim position,

Gatsas’s teaching assistant at the time, Martha Folopoulos, had a

casual conversation with Hillside assistant principal Joseph

Ferrisi during which he agreed with a comment made by Folopoulos

to the effect that the principal “would have never hired somebody

like Kathie [Gatsas] because she’s a strong . . . woman.” (Pl.’s

Mot. Opp. Summ. J., Ex. 18 (Folopoulos Depo.) 11-12.)

Believing that she had been passed over for the interim

position because of her gender, and to express her

dissatisfaction with the District’s hiring decision, Gatsas

placed advertisements in several local newspapers criticizing the

District and Principal Donohue for the decision, and alleging

that Dupere was unqualified for the job and that the District

discriminates on the basis of gender. (Def’s. Mot. Summ. J.,

Ex. G.)

On or about April 1 4 , 2003, Gatsas filed charges with both

the New Hampshire Commission for Civil Rights and the federal

5 Equal Employment Opportunity Commission (“EEOC”), alleging gender

discrimination. (Writ ¶ 7.)

At the end of the 2002-2003 school year, after placing the

newspaper advertisements and filing discrimination complaints,

Gatsas received notification that her teaching assignment had

been changed for the following school year. (Writ ¶ 13.)

Instead of teaching sixth grade science, as she had in the past,

she was slated to teach seventh grade language arts, and was to

be relocated to a different classroom, Room G25, which was

located in the school’s basement and was generally considered to

be undesirable. (Writ ¶ 14.) In August, just prior to the start

of the 2003-2004 school year, Gatsas raised concerns about her

new assignment with her union representative. As a result, her

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