ADVERSE EMPLOYMENT ACTIONS AND PUBLIC SCHOOL ...

Specifically, the court noted that in over 200 reported incidents by Woods only one could
possibly be construed as racism and even it was inadmissible because it was hearsay. While there
was no evidence of racial strife, the court did take advantage to point out that there was
significant personal strife between Woods and teachers. Moreover, Woods had other teachers file
complaints and levy criticism against her other than the clique--some of which were African
American. The court noted that the record reflected that Woods’ abrasive personality was a
major factor in her struggles.
Next, Woods failed to survive the required burden-shifting analysis to determine whether
or not she had suffered a Title VII violation based on her termination. In the analysis, Woods had
to carry four burdens. One, she was from a protected class being an African American woman.
Two, Woods did successfully perform her job as evidenced by her evaluations and multiple
contract offerings. Three, she did suffer an adverse employment action having been terminated.
However, on step four, Woods faltered. There, Woods was required to proffer admissible
evidence that similarly situated administrators not of Woods’s protected class were not subjected
to such harassment. Woods failed to produce this evidence and relied upon generic statements
such as no other White assistant principal before or after has been forced to bear such
discriminatory practices. Woods did identify one similar situation in the district where two
administrators had mailed test scores of students on postcards to their homes. The scores were
easily visible on the postcard. However, the two administrators were carrying on a practice that
had been initiated prior to their arrival at the school, so they received reprimands for the incident.
Woods obviously argued that this was disparate treatment; this argument was ill-founded. The
postcard incident was distinguishable in so much that the administrators were not collecting
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