The opinion of the court was delivered by: Wm. R. Wilson, Jr. United States District Judge
Pending is Defendant Richard Young's ("Young") Motion for Summary Judgment.*fn1
Plaintiff responded*fn2 and Young replied.*fn3
Plaintiff, Emanuel Vance, brings his cause of action under 42 U.S.C. § 1983 and alleges that Young violated his Fourteenth Amendment rights through inequitable work assignments and by disciplining Plaintiff more severely than another similarly situated employee.
Plaintiff is an African American who taught in the Brinkley Public Schools from 1984 to 2002.*fn4 Plaintiff worked as an Industrial Education Instructor, teaching students fundamental carpentry, brick masonry, and concrete finishing through hands-on training.*fn5 In order to provide this type of training, Plaintiff asked for, and was assigned, maintenance duties that included pouring concrete, working on bathrooms, and building shelves. Plaintiff was also assigned work that had nothing to do with his curriculum.*fn6
Beginning in September 2001, the principal of the school, Defendant Randolf Cannon ("Cannon"), reprimanded Plaintiff for allegedly leaving campus without signing out and for leaving his students unsupervised.*fn7 Plaintiff refutes Cannon's charges -- stating that, at most, he was three minutes late to his class on one occasion, and missed lunch duty on another occasion.*fn8
On March 20, 2002, Cannon wrote Young and recommended non-renewal of Plaintiff's contract. Based on this, Young notified Plaintiff that termination would be recommended to the school board. On May 16, 2002, the school board agreed with Young's recommendation.*fn9
Plaintiff alleges that he was summarily terminated for minor infractions, while, on the other hand, Young hesitated to discipline a similarly situated Caucasian employee -- Coach Scott Barnes ("Coach Barnes").*fn10 Barnes coached football and taught school. According to school correspondence, Coach Barnes received numerous reprimands for severe offenses that included threatening other teachers, punching another coach in the stomach, and otherwise openly disregarding school policy.*fn11 Moreover, Coach Barnes was placed on a "Teacher Improvement Plan" for two years before being cited for non-compliance.*fn12 By comparison, there is no evidence that Plaintiff was given the option of signing up for a "Teacher Improvement Plan" before being formally reprimanded.
Plaintiff argues that Defendant Young (1) violated his right to equal protection by recommending his termination for minor infractions, while being more lenient with Coach Barnes; and (2) by requiring Plaintiff and his students to provide free maintenance work for school renovations, even though some required tasks did not conform to the course curriculum.
Young argues that (1) there is no evidence creating a disputed material fact that Young's termination recommendation was racially motivated; and (2) there is no evidence that assigning Plaintiff routine maintenance work was discriminatory.
Summary judgment should seldom be used in discrimination cases.*fn13 It is appropriate only when there is no genuine issue of material fact, so that the dispute may be decided on purely legal grounds.*fn14 The Supreme Court has established guidelines to assist trial courts in determining whether this standard has been met:
The inquiry performed is the threshold inquiry of determining whether there is the need for a trial -- whether, in other words, there are any genuine factual issues that properly can be resolved only by a finder of fact because ...