Harold Smith v. Shelby Cnty. Bd. of Educ.

CourtCourt of Appeals for the Sixth Circuit
DecidedAugust 1, 2024
Docket23-5815
StatusUnpublished

This text of Harold Smith v. Shelby Cnty. Bd. of Educ. (Harold Smith v. Shelby Cnty. Bd. of Educ.) is published on Counsel Stack Legal Research, covering Court of Appeals for the Sixth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Harold Smith v. Shelby Cnty. Bd. of Educ., (6th Cir. 2024).

Opinion

NOT RECOMMENDED FOR PUBLICATION File Name: 24a0337n.06

Case No. 23-5815

UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT

FILED Aug 01, 2024 ) HAROLD C. SMITH, KELLY L. STEPHENS, Clerk ) Plaintiff-Appellant, ) ) ON APPEAL FROM THE v. ) UNITED STATES DISTRICT ) COURT FOR THE WESTERN SHELBY COUNTY BOARD OF EDUCATION, ) DISTRICT OF TENNESSEE Defendant-Appellee. ) ) OPINION

Before: LARSEN, READLER, and DAVIS, Circuit Judges.

DAVIS, Circuit Judge. Plaintiff-Appellant, Dr. Harold C. Smith is an educator who

worked for the Shelby County Board of Education (“SCBE”) public school system for 27 years.

When the SCBE mandated on-site, in-person instruction following the end of certain pandemic-

related restrictions in 2021, Smith did not return to the classroom. Due to his

immunocompromised status, Smith instead proposed to the SCBE that he continue virtual

instruction of his classes from his home. The SCBE countered Smith’s proposal with two options

that would have permitted extended remote instruction. But both options still would have required

Smith to teach his classes on-site at school—just from isolated locations. Smith rejected the

counterproposals, rebuffed entreaties to appear for on-site instruction, and eventually resigned his

position. He later sued the SCBE for disability discrimination. Concluding that Smith caused the No. 23-5815, Smith v. Shelby Cnty. Bd. of Educ.

breakdown in the interactive process, the district court granted summary judgment in the SCBE’s

favor. We agree and affirm.

I.

From 1994 through 2021, Smith held various teaching and administrative positions at the

SCBE schools (formerly known as Memphis City Schools). For the 2020-2021 school year, the

SCBE assigned Smith to teach science at Gordon Achievement Academy School (“Gordon”)—an

alternative school designed to give its students “a second chance for better opportunities.” (R. 33,

PageID 96). In early March 2020, the COVID-19 pandemic led the SCBE to shutter its schools

and transition its educators to virtual instruction from their homes. Shortly before the 2020-2021

school year began, Smith took leave under the Family Medical Leave Act (“FMLA”) to undergo

heart and kidney transplant surgeries. About six months later, medical providers from Smith’s

transplant recovery team provided a letter releasing him to return to work. The January 12, 2021,

letter explained that “[w]hile working virtually would be the safest option for [Smith] given his

immunosuppressed status,” the SCBE should discuss with his doctor and Smith whether “he would

be required to return to work in person.” (R. 39, PageID 344; R. 62-1, PageID 486, ¶ 17). Smith

had informed his medical providers that he could work virtually, but the letter nonetheless included

precautions to be taken should he be required to be in the presence of others. Specifically, the

letter stated that Smith should “wear a mask when interacting with individuals and practice

recommended social distancing guidelines and COVID precautions.” (R. 39, PageID 344).

Once Smith completed his FMLA leave, he worked remotely in accordance with the

SCBE’s policy for all teachers at that time. Within a month of his return, however, the SCBE

informed its employees and students that in-person instruction would resume on March 1, 2021.

Smith promptly requested to continue to teach his classes remotely due to his health status.

-2- No. 23-5815, Smith v. Shelby Cnty. Bd. of Educ.

In support of his request, he proffered a second letter from his medical providers both

“recommend[ing]” and “request[ing]” that he be permitted to “work from home in a virtual

capacity until at least one year post transplant,” or until July 2021. (R. 41, PageID 364).

In a March 2, 2021, e-mail, Gordon’s principal, Leviticus Pointer, acknowledged Smith’s

accommodation request, noted the SCBE’s proposal of two on-site accommodation options as well

as a possible leave of absence, and recommended that Smith contact the SCBE’s Advisor in the

Office of Professional Standards, Lauren Prater. As for the two options Pointer referenced, “Plan

A” would have permitted Smith to teach remotely from his classroom using virtual learning

technology, while his students observed from a nearby computer lab with an educational assistant

present. “Plan B” provided the same virtual instruction option as Plan A except that it allowed

Smith to instruct from the gymnasium, which had a private restroom and an isolated entrance.

Together, Pointer and Prater informed Smith that working from home was not a reasonable

accommodation and that the SCBE expected all employees to perform their duties “onsite and in-

person.” (R. 33, PageID 107). Pointer and Prater also discussed with Smith the possibility of

requesting additional leave of absence.

Smith turned down these options, preferring his previously requested work-from-home

proposal instead. He thus did not return to the school building. Pointer followed up with Smith

regarding his return to work and reiterated that the SCBE was unable to grant his requested

accommodation. Pointer also explained to Smith that if he was unable to report in-person to work,

he should follow the SCBE’s protocol for sick leave and reporting absences. Smith did not report

in person after that or utilize the sick leave protocol. As a result, the SCBE’s Office of Professional

Standards (“OPS”) launched an investigation. The investigation determined that Smith had

refused to return to the school building; that the SCBE had made various adjustments to the school

-3- No. 23-5815, Smith v. Shelby Cnty. Bd. of Educ.

building to accommodate Smith’s medical needs; that Smith had attempted to log onto Microsoft

Teams to virtually teach his classes; and that the SCBE had suspended Smith’s access to Microsoft

Teams to prevent him from attempting to work remotely. These results led the SCBE to issue a

Notice Letter advising Smith of the possibility of major discipline, up to and including termination,

for violating its policies. A few weeks later, the SCBE held a misconduct hearing, during which

Smith admitted his refusal to return to work on-site after his initial accommodation request was

denied nearly a month earlier.

The OPS determined that Smith violated two of its official policies: an ethics policy1

requiring employees to adhere to all policies and administrative rules; and a time-reporting policy2

requiring employees to report to work at the time designated by their principal. The OPS made a

formal recommendation to the SCBE’s superintendent to suspend Smith without pay for three

days. The superintendent adopted the OPS’s findings and confirmed Smith’s three-day

suspension. The SCBE also suspended Smith’s access to its network and computer systems.3

Smith suggests that he also asked to be considered for a different position that did not require him

to report in-person to Gordon, but it is unclear from the record whether and when any such request

1 Policy Number 4002 – Staff Ethics 2 Policy Number 4036 – Reporting Time 3 Smith asserted below that the SCBE constructively discharged him when it suspended his access to its network and computer systems. But he does no more than intimate this argument in his opening brief, mentioning it only once without any meaningful development. (ECF 30, Appellant’s Br. 18). Such “issues adverted to in a perfunctory manner, unaccompanied by some effort at developed argumentation, are deemed waived.

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