Williams v. Birmingham Board of Education

CourtDistrict Court, N.D. Alabama
DecidedJune 4, 2024
Docket2:22-cv-00978
StatusUnknown

This text of Williams v. Birmingham Board of Education (Williams v. Birmingham Board of Education) is published on Counsel Stack Legal Research, covering District Court, N.D. Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Williams v. Birmingham Board of Education, (N.D. Ala. 2024).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ALABAMA SOUTHERN DIVISION

YANCEY WILLIAMS, ) ) Plaintiff, ) ) v. ) Case No.: 2:22-cv-978-ACA ) BIRMINGHAM BOARD OF ) EDUCATION, ) ) Defendant. )

MEMORANDUM OPINION Plaintiff Yancey1 Williams is male, over the age of 40, and a current employee of Defendant Birmingham Board of Education. Mr. Williams contends that the Board intentionally promotes and pays younger, female assistant principals more than the Board has paid and promoted him in violation of the Civil Rights Act of 1964 (“Title VII”), 42 U.S.C. § 2000e-2(a), and the Age Discrimination in Employment Act (“ADEA”), 29 U.S.C. § 623(a). (Doc. 1).2 The Board moves for summary judgment as to all claims asserted against it,

1 During his deposition, Mr. Williams testified that his first name is Yancey. (See doc. 18- 11 at 2). The court therefore DIRECTS the Clerk of Court to update the docket to reflect that the appropriate spelling of Mr. Williams’s name.

2 The complaint’s allegation of jurisdiction states that Mr. Williams also asserts claims under 42 U.S.C. § 1981; the Equal Pay Act, 29 U.S.C. § 606(d); and Alabama state law. (See doc. 1 ¶ 1). Mr. Williams does not plead any of those claims in his claims for relief. (See id. ¶¶ 20–48). Accordingly, the court’s analysis is limited to the claims Mr. Williams has pleaded. contending that Mr. Williams has not exhausted his administrative proceedings for his failure-to-promote claims and that the Board does not pay its assistant principals

with discriminatory intent. (Doc. 16). The court is persuaded by the Board’s first argument but not its second. Accordingly, the court WILL GRANT IN PART and DENY IN PART the Board’s motion and WILL ENTER SUMMARY

JUDGMENT in the Board’s favor as to Mr. Williams’s failure-to-promote claims. This case will proceed to trial as to Mr. Williams’s disparate pay claims. I. BACKGROUND

When approaching a motion for summary judgment, the court “view[s] the evidence and all factual inferences therefrom in the light most favorable to the non- moving party, and resolve[s] all reasonable doubts about the facts in favor of the non-movant.” Washington v. Howard, 25 F.4th 891, 897 (11th Cir. 2022) (quotation

marks omitted). Where the parties have presented evidence creating a dispute of fact, the court’s description of the facts adopts the version most favorable to the nonmovant. See id.; see also Cantu v. City of Dothan, 974 F.3d 1217, 1222 (11th Cir. 2020) (“The ‘facts’ at the summary judgment stage are not necessarily the true,

historical facts; they may not be what a jury at trial would, or will, determine to be the facts.”). Mr. Williams is male, over the age of 40, and a current employee of the Board.

(Doc. 18-14 at 49; doc. 18-11 at 3, 9). Mr. Williams has identified five other Board employees, whom he contends are younger and of the opposite gender, holding the same or a substantially similar title that he holds, and receiving better pay: (1) Fallin

Ladd (female, 41 years old); (2) Angelia Groves (female, 51 years old); (3) Erin Evans (female, 43 years old); (4) Raynada Moss (female, 43 years old); and (5) Nikedra Ward (female, 43 years old). (See doc. 26 at 7–10; see also doc. 18-1 at

11–13 ¶ 12, 16–17 ¶ 14, 25–26 ¶ 22, 28–29 ¶ 25, 29–30 ¶ 26). Before the court examines each employee’s compensation history, the court will first describe the Board’s compensation and promotion process. The court will then describe Mr. Williams’s compensation history before examining his alleged comparators’

compensation histories in turn. 1. The Board’s Compensation & Promotion Policies

The Board pays its personnel through a pay schedule. (See doc. 18-1 at 2 ¶¶ 4– 5; accord doc. 18-12 at 10; doc. 18-13 at 37). According to this pay schedule, employee compensation is determined based on three numbers: (1) the role of the employee (i.e., teacher, assistant principal, etc.), (2) the “rank” of the employee based on compensable certifications or education levels; and (3) the employee’s

“step,” which reflects the employee’s years of experience. (Doc. 18-1 at 2 ¶ 5). Each year, the Board votes and approves a new pay schedule. (Id. at 2 ¶ 4; see also, e.g., doc. 18-6 at 1–29) (the 2018 pay schedule). Relevant here, the pay

schedule includes: (1) the promotion policy for promotions to new employee roles; (2) the number of contract days for each employee; and (3) a set of tables for each employee role, which dictates employee compensation based on the employee’s rank

and step. (Doc. 18-6 at 3, 6–29). Each year, all employees should3 receive a step increase even if that employee is not promoted to a new position. (Doc. 18-1 at 3 ¶ 7).

Although the Board has revised its new position promotion policy on a few occasions (see doc. 18-1 at 4 ¶ 8), the same policy was in effect for all promotions relevant to this lawsuit (see doc. 18-14 at 49) (indicating that the “earliest” date the discrimination made the basis of Mr. Williams’s claims occurred is September

2020). That policy provides that when an employee is promoted, that employee will be placed on step 1 of the new schedule unless step 1 would not result in a 5% pay increase, in which case “the employee will be placed on the next appropriate step

that allows the employee to receive at least a 5% increase in pay[].” (Doc. 18-6 at 3, 32, 62; compare id. at 62, with doc. 18-7 at 3, and doc. 18-1 at 4 ¶ 8).4 The lack of clarity in this case seems to stem from confusion about what “pay” means.

3 The court uses “should” because the Board’s compensation records reflect a substantial number of “clerical error[s]” and a “payroll system error” in multiple employees’ compensation calculations. (See, e.g., doc. 18-1 at 7–9 ¶ 10, 10 ¶ 11, 13 ¶ 13, 17 ¶ 14, 18 ¶ 15, 22 ¶ 19, 23 ¶ 20, 24 ¶ 21, 26 ¶ 23, 28 ¶ 24, 30 ¶ 26).

4 The Board did not provide the court with a complete copy of the FY2021 salary schedule, which was the schedule in effect at the time three of Mr. Williams’s alleged comparators, were promoted. (See doc. 18-6 at 90–117). The undisputed evidence is that the Board implemented a revised promotion policy in 2012 (see doc. 18-4 at 31; accord id. at 60, 85, 112; doc. 18-5 at 3; doc. 18-6 at 3, 32), and the Board did not change that policy again until October 1, 2021, which was after each alleged comparator’s promotion (see doc. 18-7 at 3; doc. 18-1 at 4 ¶ 8, at 16 ¶ 14, Board employees are paid a salary, but the Board also tracks employees’ “daily rate of pay” and “contract days.” (See doc. 18-1 at 4 ¶ 8; see also, e.g., doc.

18-9 at 12) (Mr. Williams’s personnel action form for his 2018 promotion). An employee’s daily rate of pay is calculated by dividing his salary by his contract days. (See doc. 18-1 at 12 ¶ 12). Different employees have different requirements for the

number of contract days they work: of relevance to this case, teachers work 187 contract days and assistant principals work 204 contract days. (See, e.g., doc. 18-6 at 32, 35, 49). And the Board’s policy about ensuring that an employee receives a “5% increase in pay[ ]” when promoted does not explain whether “pay” refers to the

daily rate or the salary. (See, e.g., id. at 32); see also supra at 4–5 n.4.

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Williams v. Birmingham Board of Education, Counsel Stack Legal Research, https://law.counselstack.com/opinion/williams-v-birmingham-board-of-education-alnd-2024.