ADVERSE EMPLOYMENT ACTIONS AND PUBLIC SCHOOL ...

In March 2007, Von Kleist and Flores met and discussed the complaints and a specific
complaint from Laura Bryan. Bryan was a teacher to whom Flores had directed a number of
sexual advances. Following her rejection of Flores, he had delayed reporting her 2006-2007
evaluation for over 3 months and then delivered it with low ratings. Von Kleist met in August
with Bryan to discuss her complaint to her union representative from May 2007 concerning
Flores. In September, Von Kleist and Flores, along with union and teacher representatives met to
discuss the plaintiff’s interactions and behaviors with Bryan. During the meeting, Flores
acknowledged certain behaviors but denied others. Flores was directed, among other things, to
not enter Bryan’s classroom, not seek interaction with her unless in the presence of another adult,
and not to engage in any sexual innuendo with Bryan.
Later that same month, Von Kleist was notified that two student teachers were being
removed from Mill Street due to Flores’s conduct. In November 2007, Carol Raner, another Mill
Street teacher, filed a complaint against Flores for his harassing behaviors and intimidating
practices. In a meeting with Raner and Von Kliest, Flores apologized for his actions. Flores’ final
act occurred in February 2008. Disregarding Von Kleist’s directive, Flores entered Bryan’s
classroom sat in the back and just stared at her. Bryan promptly reported the incident to Von
Kleist who, in turn, requested Paul Boylan, the school district’s attorney, to investigate Flores’s
employment history. Von Kleist placed Flores on paid administrative leave on February 11,
2008, and informed him that the district would be considering his termination due to
insubordination and his continued harassment of female teachers.
Von Kleist reported that Boylan’s investigation uncovered a litany of sexual harassment
incidents at his previous jobs. In fact, Flores had been terminated by the Glenn County Sherriff’s
Department, where he had served as a deputy, due to inappropriate sexual favor requests during
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