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intelligence. However, dissent over sex was not limited to remarks. In Reed v. Rolla 31 Public<br />

School District (2005 U.S. Dist.), Reed created a great deal of strife when she contacted and<br />

threatened other school employees she believed were having a sexual relationship with the same<br />

man, also a school employee, with whom she was having an affair. Moreover, Reed was<br />

eventually charged with sexual harassment by more than one male employee. Herbert’s sexual<br />

relationship with a custodian that led to pregnancy out of wedlock created a significant amount<br />

of strife with her followers and her direct supervisor, the principal. While Herbert did establish a<br />

prima facie case of discrimination, it is undeniable that her behavior, which included lying about<br />

the father’s identity, created an inordinate strain on her followers as detailed in Herbert v. City of<br />

New York (2010 U.S. Dist.).<br />

Third, the last area where cases assimilated as “failed relationships with followers” was<br />

identified as lacking communicative skills or the ability to lead in six cases. In Desoto County<br />

School Board v. Garrett (1987 Miss.), Garrett and Payette’s reassignment notices listed poor<br />

interpersonal skills and leadership measures as reasons for reassignment. Likewise in Peterson v.<br />

Unified School District (1989 U.S. Dist.), Peterson’s contract was not renewed for his failure to<br />

communicate effectively with his faculty, staff, and parents. Terry, who was discussed for his<br />

interpersonal strife for a new program, also failed on the communicative level due to his<br />

indiscretion in humiliating a teacher in front of students and other teachers as detailed in Terry v.<br />

Woods (1992 U.S. Dist.). Moreover, in Brown v. Board of Education (1996 Kan.) and Woods v.<br />

Enlarged City School District (2007 U.S. Dist.), both Brown and Woods were unable to<br />

engender their followers because they failed to effectively communicate and, to their superiors,<br />

assume an effective leadership position. Finally, in King v. Charleston County School District<br />

(2009 U.S. Dist.), King used intimidation and threats to communicate his wishes when he felt<br />

364

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