Guinan v. Roman Catholic Archdiocese of Indianapolis

50 F. Supp. 2d 845, 1999 U.S. Dist. LEXIS 7670, 84 Fair Empl. Prac. Cas. (BNA) 1458, 1999 WL 336262
CourtDistrict Court, S.D. Indiana
DecidedMay 7, 1999
DocketIP 98-16 C B/S
StatusPublished
Cited by2 cases

This text of 50 F. Supp. 2d 845 (Guinan v. Roman Catholic Archdiocese of Indianapolis) is published on Counsel Stack Legal Research, covering District Court, S.D. Indiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Guinan v. Roman Catholic Archdiocese of Indianapolis, 50 F. Supp. 2d 845, 1999 U.S. Dist. LEXIS 7670, 84 Fair Empl. Prac. Cas. (BNA) 1458, 1999 WL 336262 (S.D. Ind. 1999).

Opinion

ENTRY AFTER BENCH TRIAL

BARKER, Chief Judge.

This matter comes before the Court following a bench trial on April 1-2, 1999, in which Plaintiff, Ruth Ann Guinan (Guinan), claims that Defendant, Roman Catholic Archdiocese of Indianapolis (Archdiocese), violated the Age Discrimination in Employment Act (ADEA) by failing to renew her teaching contract. 1 For the reasons *847 discussed below, we find that Defendant did not violate the ADEA when it opted not to renew Plaintiffs teaching contract.

I. Findings of Fad

The events giving rise to this litigation took place at All Saints Elementary School (All Saints), which is located here in Indianapolis. The Archdiocese owns All Saints and had employed Guinan as a teacher at the school for eleven years. During that time, she primarily taught the fifth grade and was employed under a series of successive one-year contracts (a standard arrangement at All Saints and other parochial schools, as tenure is not offered by the Archdiocese). 2 ' At the end of the 1995-96 school year, Guinan’s employment- at All Saints concluded when the Archdiocese, through Mary Pat Sharpe (Sharpe), the principal of All Saints, opted not to renew Guinan’s teaching contract for the following school year. 3

Sharpe’s decision not to renew Guinan’s contract came during a very difficult time for All Saints. Sharpe had been principal at the school less than a year 4 and was hired at a time when All Saints, an inner-city school, was. suffering from a host of problems, including poor teacher moral, low test scores among the students, budgetary strains, and serious discipline concerns, to name just a few. By October 1995, the magnitude of the school’s problems had become increasingly evident, prompting the Indiana Department of Education, through its division of Performance-Based Accreditation (PBA), to inform Sharpe that it would be re-evaluating the school’s accreditation status because the students at All Saints had failed to ■ meet the minimum expectations in Indiana Statewide Testing for Educational Progress (ISTEP) total battery scores, language arts proficiency scores, and mathematics proficiency scores. (Defendant’s Exhibit L). 5 The PBA’s evaluation process began with a preliminary visit by state officials to All Saints to determine the need for an on-site review, which is a four-day review of school operations culminating in the issuance of an accreditation determination and a written report. In December 1995, after the preliminary visit, PBA officials informed Sharpe that an on-site review would be conducted. The on-site review subsequently took place in February 1996. Based on the review, PBA could give either five-year, two-year or probationary accreditation to All Saints. Probationary status is viewed as a very serious problem; such an assessment is made only in the most exceptional situations. At the time of trial, for example, only nine of the approximately 2000 schools under PBA review were on probationary status. Not surprisingly, therefore, the PBA review was a matter of great importance both to Sharpe and the Archdiocese.

In March 1996, Sharpe received the PBA report, together with the devastating news that All Saints had been placed on probationary status. 6 The report justified the accreditation decision on several grounds, including (1) “[t]he staff has not realized its potential in providing a quality educational environment,”- and (2) “[cjreative solutions have not been sought to correct problems caused by lack of school funding, environmental problems, changing family structures, and community focus.” (Defendant’s Exhibit L). While upset by the report, Sharpe had no disagreement with the PBA assessments. She perceived All Saints as suffering from a variety of problems and believed that as *848 principal it was her responsibility to bring the school back to five year accreditation status. In fact, Sharpe was determined to have the school off probationary status within a year, an ambitious goal by all measures.

Although Sharpe endorsed the PBA report and embraced its findings as a necessary first step to turning the school around, not everyone at All Saints shared her assessment. Guinan, in particular, expressed to Sharpe the belief that some of the PBA’s concerns were unfounded. Sharpe took Guinan’s comments to mean that Guinan was averse to making necessary changes and, given the brief history between the two educators (the 1995-96 school year was the first year Sharpe and Guinan had worked together), Guinan’s comments were influential in shaping Sharpe’s perception of Guinan.

During the PBA review process, Sharpe had begun to entertain the possibility that some of the teachers’ contracts should not be renewed. Knowing that such changes might be difficult to implement, Sharpe sought counsel regarding contract renewals from Mickey Lentz (Lentz), who, as the associate director for administrative personnel at the Archdiocese, was in a supervisory position relative to all the parochial schools. At Sharpe’s request, Lentz agreed to observe Guinan’s classroom to make an independent assessment of Gui-nan’s teaching. Lentz subsequently reported to Sharpe that she observed considerable disorder in Guinan’s classroom and very little instruction taking place. Lentz also told Sharpe that whatever decisions Sharpe felt were necessary regarding contract renewals she would support them.

As already alluded to, the relationship between Guinan and Sharpe continued to be a bit bumpy. Guinan believed Sharpe did not like her, and Sharpe believed she did not have Guinan’s full support. Tensions between the two women sometimes boiled over, as illustrated by a telephone conversation between them shortly after Guinan had been released from the hospital following a brief stay for a stress-related episode. During that conversation, Sharpe suggested that Guinan might want to consider teaching at a school less stressful than All Saints. Although Sharpe testified that she did not intend the comment to suggest that she wanted Guinan to leave, Guinan perceived the comment otherwise and reacted by screaming, crying and ultimately hanging up on Sharpe.

At trial, Sharpe did not explicate her personal feelings concerning Guinan, but did testify that, based on her observations of Guinan inside and outside the classroom, she disagreed with some of Guinan’s teaching and disciplinary techniques. 7 She had observed Guinan as she “ripped students apart” by yelling at them and humiliating them in front of other students. Although Sharpe could not specify how often she witnessed such conduct, she testified that it happened often enough to make a lasting impression on her. Sharpe also observed Guinan lose emotional control when confronted with difficult or challenging disciplinary situations.

In April 1996, Sharpe prepared a written outline of her concerns about Guinan’s performance, as well as Guinan’s teaching strengths, for the purpose of evaluating whether Guinan ought to remain as a teacher at All Saints. (Defendant’s Exhibits G, H).

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50 F. Supp. 2d 845, 1999 U.S. Dist. LEXIS 7670, 84 Fair Empl. Prac. Cas. (BNA) 1458, 1999 WL 336262, Counsel Stack Legal Research, https://law.counselstack.com/opinion/guinan-v-roman-catholic-archdiocese-of-indianapolis-insd-1999.