A federal judge has denied post-trial relief to an African American former
schoolteacher in her discrimination lawsuit against the School District of Philadelphia, a case that ended with a defense verdict at trial.
Dorothy E. Daniels lost her case against the district and Leslie Mason, her former principal at Thomas Mifflin Elementary School, after a jury determined that race and age was not a factor in the defendants’ decision to transfer the plaintiff to another school within the district.
Daniels contended that her 2010 transfer, and the district’s subsequent decision to replace the plaintiff at Thomas Mifflin with a younger, white employee, was motivated by discrimination.
Following the trial, the record shows, Daniels filed motions seeking judgment as a matter of law, a new trial, or an altered or amended judgment.
Daniels argued that the trial court erred in denying her pretrial motion seeking to exclude printouts from the Pennsylvania Department of Education’s Teacher Information Management System website that showed the teaching certifications of Daniels and her replacement.
The printouts confirmed that Daniels didn’t have the necessary certification that would have enabled her to keep her job at Thomas Mifflin, court papers state.
It was uncontested that Daniels lacked the proper certification; the plaintiff merely asserted that the printouts should have been excluded as improperly disclosed since they were not produced by the district until one week before trial.
Several months before trial, Daniels had requested the “complete personnel file” of her replacement, records show, and the school district ended up producing what records it had in its possession at the time.
The district, however, doesn’t keep up-to-date teaching certifications in its files, but instead relies on the Education Department’s website for this information when needed.
In his Jan. 28 memorandum, U.S. District Court Judge Harvey Bartle, III, of the Eastern District of Pennsylvania, wrote that while Daniels argued that she didn’t have the opportunity to prepare a proper defense “and assess trial tactics and risk at trial,” because she didn’t have the requested information beforehand, the information was publicly available on the Education Department’s website.
Furthermore, Daniels, the judge wrote, “does not explain how she would have prepared differently had she been apprised of the printouts earlier or how that preparation would have affected the outcome of the trial.”
“Under these circumstances, we find that the failure to produce the printouts until the week before trial, when the School District obtained them, was both substantially justified and harmless,” Bartle wrote.
In her post trial motion, Daniels also took issue with a jury instruction that guided jurors on how they were permitted to consider the reasons that the defendants put forward for their conduct in transferring and replacing the plaintiff.
Under court precedent, a defendant bears only a burden of producing evidence of “legitimate, non-discriminatory reasons for its actions,” according to the judicial memorandum.
“It is not saddled with the burden of proof,” under what is known as the McDonnell Douglas burden-shifting framework for employment discrimination cases, Bartle noted.
The jury instruction in question explained how this burden affected its task in assessing the evidence.
Daniels maintained that none of the district’s witnesses ever testified to the reason for the defendants’ actions, and that the only support given at trial for this particular jury instruction was “speculation and innuendo,” court records state.
Bartle called this an “inaccurate description of the evidence presented at trial, and it misapprehends the allocations of evidentiary burdens in a case such as this one.
“Even excluding the printouts with which Daniels takes issue, the witness testimony described above that was presented by the defendants at trial satisfied their burden of going forward,” the judge wrote.
In the end, Bartle determined that there was no error of law that would justify granting a new trial, and that there was no miscarriage of justice to support amending or altering the judgment.