ADVERSE EMPLOYMENT ACTIONS AND PUBLIC SCHOOL ...

a part, or was a student record that she had some connection with. In late July, Woods removed
all photocopied material from her office and took it to her home.
During the Summer of 2003, Woods began displaying severe psychiatric distress by
crying uncontrollably and without end. In August, Woods was diagnosed with Post Traumatic
Stress Disorder (PTSD) citing her divisive work environment as the primary cause. During her
medical leave, the district investigated the reports of Woods copying and removing school
records from school grounds.
On December 18, 2003, Johns notified Woods that he was recommending her termination
and the vote would come before the board in January. Moreover, he noted in the termination
charges that Woods had exhibited great carelessness and imprudence regarding her misuse of
resources (personal and material), her copying of privacy-sensitive materials without
administrative approval and/or parental consent, and her removal of these items from school
grounds. This suit followed. The defendants promptly motioned for summary judgment.
Issues: (1) Was Woods subjected to a hostile working environment? (2) Was Woods’s
termination based on her race? (3) Was Woods subject to disparate treatment/intentional
discrimination? (4) Was Woods’s termination a retaliatory measure for her racial discrimination
claim? (5) Was Woods’s termination a retaliatory measure under the First Amendment?
Holding: The court held that Woods failed on all counts to establish a prima facie case of
racial discrimination due to inadmissible evidence or a lack of evidence.
Reasoning: Woods, the court noted, was certainly working in an environment that was
not conducive to harmony and success. However, her assertions that racial animus drove the
problems was unfounded in the record. The court noted that the record was without one iota of
admissible evidence to suggest that Woods was subjected to a hostile work environment.
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