Williams v. Galveston Independent School District

78 F. App'x 946
CourtCourt of Appeals for the Fifth Circuit
DecidedOctober 23, 2003
Docket03-40436
StatusUnpublished
Cited by6 cases

This text of 78 F. App'x 946 (Williams v. Galveston Independent School District) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fifth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Williams v. Galveston Independent School District, 78 F. App'x 946 (5th Cir. 2003).

Opinion

BENAVIDES, Circuit Judge. *

Plaintiffs-Appellants, administrators for the Galveston Independent School District (“GISD”), filed suit against their employer under 42 U.S.C. § 1981. Appellants allege that GISD discriminated against them on the basis of race in setting their salaries. The district court granted summary judgment in favor of GISD. Because we agree with the district court that Appellants have raised no genuine issue of material fact, we affirm.

I.

Appellant Dr. Patricia Williams serves as Executive Director of Employee and Community Relations for GISD. Appellant Terry Watkins serves as Executive Director of Human Resources. Both women are African-American.

GISD assigns each administrative position to a particular “pay grade,” a group of positions that fall within the same salary range. Dr. Williams and Ms. Watkins are both in pay grade 8, the highest level. At the time this suit was filed, two other employees were also listed at pay grade 8: E.J. Garcia, Assistant Superintendent of Curriculum and Instruction; and Paul McLarty, Chief Financial Officer. 1 Ms. Garcia and Mr. McLarty are both white.

*948 The roots of Appellants’ complaint go back to 2000, when GISD reorganized its upper administration. At that time, Dr. Williams was serving as Executive Director of Personnel, and Ms. Garcia was serving as Superintendent for Instruction. Their salaries were roughly equal. After GISD created the position of Executive Director of Employee and Community Relations, then-Superintendent Henry Boening approached Dr. Williams about taking the job. Dr. Williams alleges that Superintendent Boening promised that if Dr. Williams took the new position, her salary and responsibilities would stay commensurate with the salary and responsibilities assigned to Ms. Garcia. Dr. Williams accepted the new position, and Ms. Watkins succeeded her. 2

During the two years following this reorganization, GISD awarded Ms. Garcia and Mr. McLarty substantial raises. GISD claims that it was attempting to make top administrators’ salaries more competitive with market rates. 3 GISD says it did not give Appellants similar raises because Appellants’ salaries were at or above market rate for their positions. Between 1999 and 2002, the four administrators in grade 8 were paid the following salaries:

Garcia Williams McLarty Watkins
99-00 $72,630 $72,630 $73,000 n.a.
00- 01 $83,440 $75,129 $82,686 $71,648
01- 02 $94,249 $77,630 $92,499 $76,673

Dr. Williams learned of this divergence and filed a grievance. After Superintendent Boening and the school board denied her grievance, she filed this suit. Ms. Watkins subsequently joined the suit. 4 Appellants allege that the difference between their salaries and the salaries of their white colleagues constitutes race discrimination in violation of 42 U.S.C. § 1981. 5

The district court granted summary judgment in favor of GISD. The court concluded that Appellants could not succeed on their claim under § 1981 because their positions did not require substantially the same responsibility as those of their white colleagues. The court also determined that Appellants had failed to raise any genuine issue of material fact on the question of whether GISD’s proffered race-neutral explanations for the disparity were pretextual.

II.

We review a district court’s grant of summary judgment de novo. Price v. Fed. Express Corp., 283 F.3d 715, 719 (5th Cir.2002). Summary judgment is appropriate if the evidence, viewed in the light most favorable to the non-movant, raises no genuine issues of material fact and is entitled to judgment as a matter of law. Fed. R. Civ. P. 56(c); Price, 283 F.3d at 719.

III.

We evaluate claims of racial discrimination based only on circumstantial evidence under the familiar burden-shifting analysis of McDonnell Douglas Corp. *949 v. Green, 411 U.S. 792, 802-05, 93 S.Ct. 1817, 36 L.Ed.2d 668 (1973). 6 See Price, 283 F.3d at 719. Under this framework, plaintiffs begin by establishing a prima facie case of discrimination. Pratt v. City of Houston, 247 F.3d 601 (5th Cir.2001).

To establish a prima facie case of discriminatory compensation, a plaintiff must prove “(1) that she is a member of a protected class and (2) that she is paid less than a nonmember for work requiring substantially the same responsibility.” Uviedo v. Steves Sash & Door Co., 738 F.2d 1425, 1431 (5th Cir.1984); see also Pittman v. Hattiesburg Mun. Separate Sch. Dist., 644 F.2d 1071, 1074 (5th Cir. Unit A May 1981). 7 If a plaintiff’s job responsibilities are significantly different from the responsibilities of employees she cites as a point of comparison, then the plaintiff has not made out a prima facie case. Id. In considering whether two jobs require substantially the same responsibility, we have looked to the jobs’ duties, see Uviedo, 738 F.2d at 1431; Pittman, 644 F.2d at 1074, including the jobs’ relative supervisory authority and responsibility for revenue, see Cullen v. Ind. Univ. Bd. of Trs., 338 F.3d 693, 700 (7th Cir.2003).

Appellants attempt to found their prima facie case on a comparison between their positions and the positions held by Mr. McLarty and Ms. Garcia. 8 However, each employee’s responsibilities are plainly dissimilar from the responsibilities of the other three grade 8 employees. 9

As Executive Director of Employee and Community Relations, 10 Dr.

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Taylor v. United Parcel Service, Inc.
421 F. Supp. 2d 946 (W.D. Louisiana, 2006)
Boone v. Galveston Independent School District
126 F. App'x 660 (Fifth Circuit, 2005)
Williams v. Galveston Independent School District
541 U.S. 959 (Supreme Court, 2004)

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Bluebook (online)
78 F. App'x 946, Counsel Stack Legal Research, https://law.counselstack.com/opinion/williams-v-galveston-independent-school-district-ca5-2003.