ADVERSE EMPLOYMENT ACTIONS AND PUBLIC SCHOOL ...

no evidence greater than hearsay. Moreover, she failed in every instance to show that the males
were accused of sexual harassment, sending sexually suggestive birthday cards, and so on. The
court found the same on Reed’s retaliation claims. The important point that failed for Reed here
was her assertion that there was a causal connection between the time of her gender
discrimination complaint and the board’s decision to not renew her contract. Reed had been an
employee for almost 19 years and the board chose to non-renew her some 3 months after her
claim and an investigation of egregious behaviors on her part. Finally, Reed argued that the
defendants maliciously prosecuted her. Once again, Reed failed to provide any evidence above
the level of hearsay.
App.).
Disposition: Summary judgment was granted in full for the school district.
Citation: Tilghman v. Waterbury Board of Education, 154 Fed. Appx. 221, (2005 U.S.
Key Facts: Tilghman, along with a co-plaintiff, McKnight, (later dropped from the suit)
originally filed racial discrimination claims under 42 U.S.C. §§ 1983 and 1988 following non-
renewal of their 1-year contracts. Tilghman was able to establish a prima facie case of
discrimination--a weak one the court noted--but Tilghman was unable to rebut the board’s non-
discriminatory reasoning with any evidence. Thus, the District Court granted summary judgment
in favor of the Waterbury Board of Education. This appeal followed.
Issues: (1) Did the district court err in granting summary judgment to the board?
Holding: The court held that district court properly granted summary judgment.
Reasoning: Because Tilghman provided no sound evidence contrary to the board’s
assertions for non-renewal, granting summary judgment was the correct ruling.
Disposition: The district court ruling was affirmed.
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