An African-American high school football coach, the first in a west Georgia high school’s history since desegregation, lasted only two seasons before getting fired. The school alleged that it acted due to the coach’s improper recruiting practices. The coach claimed that racial discrimination was the real reason. The 11th Circuit Court of Appeals recently upheld a summary judgment in favor of the school in the coach’s Title VII case. The outcome serves as a reminder to Georgia employers and employees that, in showing that the stated reason for termination was a mere pretext for discrimination, an employee must not simply show that the employer’s basis was incorrect or unfounded. As long as the employer honestly believed the nondiscriminatory reason for the firing, the action was not a pretext for discrimination, no matter how wrong that reasoning was.
The coach was Charles Flowers, who had won state championships in football and baseball while coaching at Shaw High School in Columbus from 1987 to 2005. In 2010, Troup High School hired Flowers, who became the first African-American football coach at the school since Troup County schools desegregated in 1973.
Shortly after Flowers took over the Troup football program, inquiries began coming in regarding recruiting violations, including letters about several Troup players who allegedly lived in neighboring Chambers County, Alabama. Among these players were two brothers, Jalen and Zanquanarious Washington. The school hired a private investigator, whose work uncovered that the boys lived in Troup County, but Flowers had made the Washington family’s rent payments in order to keep them in their Troup County apartment.
Based upon this information, the school fired Flowers. The coach sued, alleging that the firing was a racially discriminatory one in violation of Title VII. The trial court eventually granted summary judgment to the employer, however. Both sides agreed that the coach outlined a prima facie case of discrimination, but the school provided a legitimate, nondiscriminatory reason for the termination. With the school having provided a legitimate reason for its action, the coach needed sufficient proof that the stated reason for his dismissal — recruiting violations — was really just a pretext for racial discrimination. The court decided he lacked that evidence.
The coach appealed. He argued that his case did sufficiently make out a showing of pretext because the school never actually established that any of the allegedly ineligible players was in fact ineligible. He also argued that white coaches in the school district who had faced recruiting accusations were neither disciplined nor fired.
Each of the coach’s arguments met with defeat. Whether or not the purportedly problematic players were actually ineligible was irrelevant to the coach’s Title VII case. Merely proving that the principal’s belief that led to the coach’s termination was erroneous or unfounded did not establish pretext. Even if the principal’s belief was 100% wrong, as long as the principal honestly believed that the coach broke the rules, the stated reason for termination was not a pretext for discrimination, and the employee did not have a Title VII case.
The coach’s unequal treatment argument was not a winner because the improper recruiting violations that the two white coaches committed were not as egregious as Flowers’ conduct, since Flowers’ actions involved relatively large sums of money and were done “in a manner especially likely to go undetected.”
As a Georgia employer or employee, it is important to understand that there are several aspects in a successful Title VII discrimination case. For reliable answers and diligent representation regarding your Title VII discrimination issues, reach out to the Georgia racial discrimination attorneys at Parks, Chesin & Walbert. Our attorneys can offer your the advice and advocacy you need regarding your discrimination case.
To speak with one of our lawyers about your case, call 404-873-8048.
More blog posts:
Eleventh Circuit Affirms Dismissal of Georgia Employee’s Race and Age Discrimination Claims, Atlanta Employment Attorneys Blog, March 11, 2015
Federal Court in Georgia Grants Summary Judgment to Employer in White Male Discrimination Case, Atlanta Employment Attorneys Blog, Aug. 11, 2014