Discrimination • Education • Civil Procedure • Motion Practice • Judgments

Daniels v. Sch. Dist. of Philadelphia, PICS Case No. 14-0204 (E.D. Pa. Jan. 28, 2014) Bartle, J. (10 pages).

Where defendants satisfied their evidentiary burden under the McDonnell Douglas framework, and defendants’ failure to disclose evidence was substantially justified and harmless, there was no clear error of law or miscarriage of justice to support a new trial or amending of the judgment. Denied.

Plaintiff Dorothy Daniels, an African-American school teacher, filed for post-trial relief from judgments in favor of defendants School District of Philadelphia and Leslie Mason, plaintiff’s supervising principal, on plaintiff’s claims of age and race discrimination, seeking judgment as a matter of law, or in the alternative, a new trial or an amended judgment.

Following partial summary judgment, the issue at trial was whether plaintiff’s transfer and replacement by a younger, Caucasian teacher, and plaintiff’s subsequent inability to choose the school she would be transferred due to her failure to receive notice constituted age and/or race discrimination on the part of defendants.

The instant court denied plaintiff’s motion for judgment as a matter of law, as plaintiff had failed to file the required motion for judgment as a matter of law prior to the jury’s verdict; however, the court noted that, even if she were eligible, plaintiff would not be entitled to judgment as a matter of law for the same reasons the court denied plaintiff’s motions for a new trial or amended judgment.

In support of her motions, plaintiff contended that the court erred in failing to exclude Pennsylvania Department of Education website printouts regarding plaintiff’s and her replacement’s teaching certifications, contending they were improperly disclosed only a week before trial.

The court found that the school district’s failure to produce the printouts was substantially justified and harmless to plaintiff, noting that teaching certification records are not kept by the school district but by the Department of Education on its website, which is accessed by the district when necessary. The district obtained the printout pursuant to comments by the instant court and provided it to plaintiff in supplemental disclosure; furthermore, the information was publicly accessible at all times, and plaintiff failed to articulate how the preparation of her case would have been affected by earlier disclosure of the printouts.

Plaintiff also contended that the jury was improperly instructed as to defendants’ burden under the McDonnell Douglas framework, which requires a defendant to produce evidence of non-discriminatory reasons for its actions; plaintiff asserted that no defense witness provided testimony as to the reason for defendants’ actions.

However, the court found that the record established that defendants had required plaintiff, due to budget cuts, to obtain additional teaching certifications in order to keep her position, and that plaintiff failed to obtain those certifications. Moreover, plaintiff’s replacement did possess the additional required certifications. Defendants also asserted that plaintiff’s failure to be notified of her transfer was due solely to a clerical mistake.