Yolanda S. Wright v. Fairfield Board of Education, et al.

District Court, N.D. Alabama·Decided August 27, 2026·No. 2:24-cv-00093·Unknown

Opinion

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

YOLANDA S. WRIGHT, ) ) Plaintiff, ) ) v. ) Case No. 2:24-cv-93-GMB ) FAIRFIELD BOARD OF ) EDUCATION, et al., ) ) Defendants. )

MEMORANDUM OPINION AND ORDER Plaintiff Yolanda S. Wright brings claims against her employer, the Fairfield Board of Education and the Fairfield City School District (collectively, “the Board”),1 for retaliation in violation of the False Claims Act, 31 U.S.C. § 3730(h)(1), and for a violation of her rights under the First Amendment to the United States Constitution. Doc. 6 at 13–15. The parties consented to the jurisdiction of a United States Magistrate Judge pursuant to 28 U.S.C. § 636(c). Doc. 19. Two motions are pending before the court. The Board has filed a motion for summary judgment. Doc. 38. Wright filed a brief and evidence in opposition to the motion (Doc. 43), and the Board then moved to strike portions of Wright’s evidentiary materials.

1 The Board clarified in its answer that the Fairfield Board of Education and the Fairfield City School District are “one in the same as the Board operates the school district.” Doc. 11 at 1. Neither party moved to dismiss the Fairfield City School District even though both have operated as if the Fairfield Board of Education is the sole defendant. See Doc. 43 at 1 (listing the Board as the only defendant in the style and body of the response). Doc. 46. Both motions are fully briefed (Docs. 39, 43, 46, 47, 51 & 52) and ripe for decision.

For the reasons that follow, the motion to strike (Doc. 46) is due to be denied and the motion for summary judgment (Doc. 38) is due to be granted. I. MOTION TO STRIKE

In her opposition to summary judgment, Wright relies on (1) an affidavit from a former interim member of the Board, Eric Major; and (2) a declaration she prepared after her deposition. See Docs. 43-1 & 43-2. The Board moves to strike portions of both documents. Doc. 46 at 7–13.

A. The Major Affidavit When Wright filed suit, she attached Major’s affidavit to her pro se complaint. Doc. 1-1 at 5. Two months later, she amended her complaint at the court’s direction

but did not attach the affidavit to the amended pleading. Doc. 6. She nevertheless relies on the affidavit in her response to the motion for summary judgment. See Doc. 43-1 at 7–8 (citing Doc. 1-1 at 5). The Board argues that the court should strike the affidavit either in whole or

in part because (1) Wright did not incorporate it into her amended complaint and so it is not properly before the court, and (2) it contains privileged material. Doc. 46 at 7–10; Doc. 52 at 2–6. While the affidavit and its contents have been the source of

an evidentiary dispute in this case (see Doc. 31), the court rejects the Board’s two 2 arguments for striking it. First, the Board contends that Wright cannot rely on the Major Affidavit in

her opposition because it was not attached to her amended complaint. See Doc. 46 at 7 n.7; Doc. 52 at 2–3. Under Federal Rule of Civil Procedure 56, a party opposing summary judgment may rely on an affidavit that is based on personal knowledge,

sets out facts that would be admissible in evidence, and shows that the affiant is competent to testify on the matters stated. Fed. R. Civ. P. 56(c)(4). It is true that an amended complaint supersedes an original complaint and its attached exhibits such that “the original pleading is abandoned by the amendment, and is no longer a part

of the pleader’s averments against his adversary,” Dresdner Bank AG v. M/V Olympia Voyager, 463 F.3d 1210, 1215 (11th Cir. 2006) (quoting Proctor & Gamble Def. Corp. v. Bean, 146 F.2d 598, 601 n.7 (5th Cir. 1945)), but Rule 56 does not

require the party to incorporate a document into her operative pleading for it have evidentiary value at summary judgment.2 The court will not strike the affidavit for this reason.3 The Board alternatively argues that the court should strike portions of the

2 For that matter, “nothing in the Rule suggests that the affidavits or declarations themselves have to have been produced in discovery in order to be considered in support of or in opposition to a motion for summary judgment.” Benoit v. City of Lake City, Fla., 343 F. Supp. 3d 1219, 1224 (M.D. Fla. 2018). 3 The Board also complains that Wright did not take the additional step of attaching the affidavit to her opposition brief. See Doc. 52 at 3 (noting that Wright cites to the inoperative complaint in her brief). This technicality is not a basis for excluding the affidavit. 3 affidavit protected by the attorney-client privilege. Doc. 46 at 7–10; Doc. 52 at 3–6. Particularly, it claims privilege over the parts of the affidavit that (1) mention

Major’s motion to table the vote on Wright’s nonrenewal after her presentation during the executive session, and (2) the Board’s consideration of that motion. See Doc. 46 at 7–9; Doc. 52 at 3–6. As the party invoking the privilege, the Board

has the burden of proving its applicability. Bogle v. McClure, 332 F.3d 1347, 1358 (11th Cir. 2003). The court previously determined that the attorney-client privilege attaches to the executive session after Wright left. Doc. 31 at 6. However, the court did not

make factual findings about the precise timing of Wright’s departure. See Doc. 31 at 10 n.3; Doc. 46 at 8. In its motion to strike, the Board does not point to any evidence that resolves the question whether Wright was in the room during Major’s motion or the discussion that followed. See Doc. 46 at 8–10; Doc. 52 at 3–5.4 For this reason,

the Board has not met its burden to prove that the attorney client privilege covers the statements in Major’s affidavit. B. Wright’s Post-Deposition Declaration

The Board also moves to strike portions of the declaration Wright prepared

4 Because the motion is not reflected in the minutes of the open session, the Board speculates that it “must have been during the privilege portion of the executive session.” Doc. 46 at 9. Knowing that Major made the motion during the executive session, however, does not necessarily mean it was privileged without also knowing when Wright left the room. 4 after her deposition. Doc. 46 at 10–12; see Doc. 43-2. Under the “sham affidavit” rule, a party who “‘has given clear answers to unambiguous questions which negate

the existence of any genuine issue of material fact . . . cannot thereafter create such an issue with an affidavit that merely contradicts, without explanation, previously given clear testimony.’” Strickland v. Norfolk S. Ry. Co., 692 F.3d 1151, 1161 (11th

Cir. 2012) (quoting Van T. Junkins & Assocs., Inc. v. U.S. Indus., Inc., 736 F.2d 656, 657 (11th Cir. 1984)). The court may exclude a plaintiff’s affidavit or declaration when it “completely contradicts her deposition” and there is “no way that [the] statements could be read together.” Id.; see Furcron v. Mail Ctrs. Plus, LLC, 843

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Yolanda S. Wright v. Fairfield Board of Education, et al., (N.D. Ala. 2026).

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