Jessica Childers v. Casey Cnty. Sch. Dist. Bd. of Educ.

CourtCourt of Appeals for the Sixth Circuit
DecidedAugust 1, 2024
Docket23-5713
StatusUnpublished

This text of Jessica Childers v. Casey Cnty. Sch. Dist. Bd. of Educ. (Jessica Childers v. Casey Cnty. Sch. Dist. 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
Jessica Childers v. Casey Cnty. Sch. Dist. Bd. of Educ., (6th Cir. 2024).

Opinion

NOT RECOMMENDED FOR PUBLICATION File Name: 24a0339n.06

No. 23-5713

UNITED STATES COURT OF APPEALS FILED FOR THE SIXTH CIRCUIT Aug 01, 2024 KELLY L. STEPHENS, Clerk ) JESSICA CHILDERS, ) Plaintiff - Appellant, ON APPEAL FROM THE ) UNITED STATES DISTRICT ) v. COURT FOR THE WESTERN ) DISTRICT OF KENTUCKY ) CASEY COUNTY SCHOOL DISTRICT BOARD ) OF EDUCATION, et al., ) OPINION Defendants - Appellees. ) )

Before: GIBBONS, BUSH, and LARSEN, Circuit Judges.

JOHN K. BUSH, Circuit Judge. Jessica Childers required a private space and dedicated

time to pump breastmilk after she returned from maternity leave. Administrators at her school

challenged some of her desired accommodations. After Childers received a poor evaluation and

faltered in some of her assigned tasks, the Casey County School District declined to renew her

employment contract. She sued those administrators and the District, alleging that they

discriminated against her, retaliated against her, created a hostile work environment, and

intentionally inflicted emotional distress on her. The district court, however, granted summary

judgment for defendants on all issues. We affirm.

I

Childers, a special education teacher, took ten weeks of maternity leave after giving birth

to her son. As she prepared to return to the classroom, she worked with her supervisor, Principal

Daran Wall, to identify a space where she could pump breastmilk for her baby. They settled on No. 23-5713, Childers v. Casey Cnty. Sch. Dist. Bd. of Educ., et al.

her classroom, which had “a chair, a table, a plug in, and a door that locked . . . from the inside,

and [where she could] put a cover over the window” on the door. Childers Dep., R. 18-2, PageID

109.

Childers returned from maternity leave in October 2020. On October 7, Barry Lee, the

school’s special education director, met with all special education teachers to discuss schedules.

Childers proposed a schedule that included two thirty-minute periods of personal time, a sixty-

minute planning period, and a twenty-minute lunch period. According to Childers’s testimony,

Lee questioned the purpose of personal times Childers listed in her schedule; when she explained

that she set these periods to pump breastmilk, Lee “got very loud, and he got very angry, and he

smacked the paper on the table, and he told me, this wasn’t going to work” because “[t]here’s no

way he’s going to pay [her not] to see kids and—he’s not going to pay [her] to do nothing.” Id. at

PageID 115. After the meeting, Lee and Wall met privately with Childers, and Lee explained that

“he was concerned because of the large amount of time (2.5 hours per day) on [Childers’s] daily

schedule that she was not with students” and that Childers needed “to maximize instruction time

with students.” Wall Resps. To Pl.’s Interrog. Reqs., R. 18-3, PageID 163. Lee also inquired as

to whether any adjustments could be made to ensure [Childers] was supporting her students.” Id.

On October 8, Childers, Lee, and another school employee met to discuss how long

Childers needed to pump: Childers testified that Lee directed her to shorten her pumping sessions

to twenty minutes, which he concluded was an appropriate amount of time based on his

conversations with others, and cut her planning period by thirty minutes to compensate for time

not seeing students. But Wall never asked her to reduce the number of pumping sessions. And

Childers never actually reduced her pump sessions, in either the personal times or her planning

period.

2 No. 23-5713, Childers v. Casey Cnty. Sch. Dist. Bd. of Educ., et al.

Over the course of the school year, someone entered Childers’s classroom while she

pumped three times. And the cover on her classroom door was once removed on January 7, 2021.

The next day, Wall sent an email asking staff to remove door covers as part of a district-wide safety

audit. Childers did not remove her window cover. Wall later asked her in person to remove the

cover as part of that audit, but Childers continued to keep hers up.

A new child joined the special education department while Childers took maternity leave.

Once she returned to school, Childers was responsible for verifying that the new student’s

paperwork complied with standards to secure federal funding for the child’s education. Although

she identified that the child’s paperwork was not completed while she was on leave, Childers failed

to timely submit a verification form for the child, resulting in a loss of federal funding.

Wall advised teachers on what to include in a binder as part of his evaluation of their

performance, but teachers chose what specific documents would be considered. During his

evaluation of Childers, Wall rated her as “Developing,” rather than “Accomplished.” Childers

explained why she disagreed with this evaluation and appealed it to a committee that reviewed

teacher evaluations, but this committee ultimately upheld her evaluation. Childers was a contract,

not tenured, teacher, and ultimately the District declined to renew her contract in 2021.

Childers sued the District, Lee, and Wall, asserting discrimination, retaliation, hostile work

environment, outrageous conduct, and gross negligence claims against them. The parties cross-

moved for summary judgment—defendants on all issues and Childers on liability. The district

court granted defendants’ motion for summary judgment and denied Childers’s partial motion for

summary judgment. Childers timely appealed.

3 No. 23-5713, Childers v. Casey Cnty. Sch. Dist. Bd. of Educ., et al.

II

We review a grant of summary judgment de novo. Morgan v. Trierweiler, 67 F.4th 362,

366 (6th Cir. 2023). Summary judgment is appropriate if “the movant shows that there is no

genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.”

Fed. R. Civ. P. 56(a). A genuine issue of material fact exists when “the evidence is such that a

reasonable jury could return a verdict for the nonmoving party.” Anderson v. Liberty Lobby, Inc.,

477 U.S. 242, 248 (1986). In this analysis, the court “must view all the evidence and draw all

reasonable inferences in the light most favorable to the non-moving party.” Rhinehart v. Scutt,

894 F.3d 721, 735 (6th Cir. 2018) (citing Anderson, 477 U.S. at 251–52, 255).

III

A. Title IX and Kentucky Civil Rights (KCRA) Claims

Childers appeals the district court’s grant of summary judgment for defendants on her

claims brought under Title IX of the Education Amendments of 1972, 20 U.S.C. § 1681 et seq.

and the KCRA, Ky. Rev. Stat. Ann. § 344.040 et seq. Title IX and KCRA make similar

mistreatment unlawful. Title IX states that, subject to exceptions inapplicable here, “[n]o person

in the United States shall, on the basis of sex, be excluded from participation in, be denied the

benefits of, or be subjected to discrimination under any education program or activity receiving

Federal financial assistance.” 20 U.S.C.

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