Standridge v. Blount County Board Of Education

IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ALABAMA

SOUTHERN DIVISION

GLENDA KATLYN KON ]

STANDRIDGE, ]

]

Plaintiff, ]

]

v. ] 2:23-cv-1021-ACA

]

BLOUNT COUNTY BOARD ]

OF EDUCATION, ]

]

Defendant. ]

MEMORANDUM OPINION

After Plaintiff Glenda Katlyn Kon Standridge, a special education teacher

with Defendant Blount County Board of Education, became pregnant, she applied

for four different teaching positions with the Board. The Board did not offer her any

of the positions but instead hired other candidates who did not yet have teaching

certificates. Ms. Standridge alleges that the failure to hire her was pregnancy

discrimination, in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C.

§ 2000e-2(a)(1).

The Board moves for summary judgment. (Doc. 9). The court WILL

GRANT IN PART and DENY IN PART the motion. Because Ms. Standridge has

not presented evidence of pregnancy discrimination with respect to the transitional

kindergarten position at Cleveland Elementary School, the court WILL GRANT

the motion and WILL ENTER SUMMARY JUDGMENT in favor of the Board

as to that position. But Ms. Standridge has presented enough evidence to create a

factual dispute about the other three positions at issue in this case, so the court WILL

DENY the motion as to those positions.

I. BACKGROUND

When ruling on a motion for summary judgment, the court “view[s] the

evidence and all factual inferences therefrom in the light most favorable to the non-

moving party, and resolve[s] all reasonable doubts about the facts in favor of the

non-movant.” Washington v. Howard, 25 F.4th 891, 897 (11th Cir. 2022) (quotation

marks omitted). Where the parties have presented evidence creating a dispute of fact,

the court’s description of the facts adopts the version most favorable to the non-

movant. See id.; see also Cantu v. City of Dothan, 974 F.3d 1217, 1222 (11th Cir.

2020) (“The ‘facts’ at the summary judgment stage are not necessarily the true,

historical facts; they may not even be what a jury at trial would, or will, determine

to be the facts.”).

The Board hired Ms. Standridge in 2018 as a special education collaborative

teacher. (Doc. 10-2 at 62). When it initially hired Ms. Standridge, she lacked an

Alabama teacher’s certificate but had an interim certificate. (Id. at 10). The State

gave her a teacher’s certificate in March 2020. (Id. at 163). She also held a bachelor’s

degree in liberal arts, a master’s degree in collaborative education, and a certification

in early childhood education. (Id. at 6).

By 2022, Ms. Standridge was tenured and teaching eighth, ninth, and tenth

grade students at the Blount County Learning Center. (Doc. 10-4 at 11; doc. 10-2 at

168). Students at the Learning Center are enrolled at other public schools but receive

special education services at the Learning Center. (Doc. 10-4 at 11). Also by 2022,

Ms. Standridge had four children and had gone through two pregnancies while

employed at the Learning Center. (See doc. 10-2 at 66, 79).

In May 2022, Ms. Standridge began applying for positions at other schools.

(Id. at 14). The Board requires teachers to have a four-year education degree and a

valid Alabama teacher’s certificate. (Doc. 10-4 at 128; doc. 10-7 at 10). However,

the Board considers candidates eligible for hire even before they receive their

certificate as long as they are eligible to receive it. (Doc. 10-7 at 12). If the Board

hires a candidate who is eligible for certification but has not yet received a certificate,

the Board will help the candidate to apply for an interim education certificate (if

enrolled in a master’s program) or a provisional certificate (if taking certain classes

and taking a test called the Praxis). (Id. at 7). Getting one of those provisional

certificates takes three to nine months. (Doc. 10-8 at 8). Board policy states that

“[o]ther things being equal, the Superintendent will give preference to the candidate

who has procured the more advanced [degree] or experience.” (Doc. 10-4 at 128; see

doc. 10-7 at 10–11). The Superintendent has advised principals and directors, who

make recommendations about who to hire, that they can also consider interviews.

(Doc. 10-11 ¶ 3).

Between May and July 2022, Ms. Standridge applied for various positions,

including the four positions at issue in this case. (See doc. 10-4 at 135; doc. 10-2 at

23; see also doc. 16 at 5 n.1). Marlana Matthews, the principal of Cleveland

Elementary School (doc. 10-3 at 5), interviewed Ms. Standridge twice (doc. 10-2 at

14). Ms. Standridge’s first interview with Ms. Matthews—for a position not at issue

in this case—went poorly because a parent had confronted Ms. Standridge that

morning about his belief that she had abused his child, “rattl[ing]” her. (Id. at 14–

16; doc. 10-3 at 34). Ms. Standridge told Ms. Matthews that she loved the children

but “struggle[d]” with the adults and found working entirely in a self-contained

classroom “very mentally taxing.” (Doc. 10-2 at 15). She also explained that staying

at the Learning Center would not help her gain experience for advancement. (Id. at

15–16).

Several weeks later, Ms. Matthews invited Ms. Standridge to interview for a

position teaching transitional kindergarten. (Id. at 16–17). Transitional kindergarten

was a pilot program put on by Cleveland Elementary School under which special

education students and typical students shared a classroom with the intention of

transitioning the special education students into regular classes. (Doc. 10-7 at 15, 17;

see also doc. 10-2 at 17; doc. 10-4 at 16). The program did not require the teacher to

hold a special education certificate. (Doc. 10-7 at 15–17).

Before the interview, Ms. Standridge’s son, a student at Cleveland Elementary

School, revealed to Ms. Matthews that Ms. Standridge was pregnant. (Doc. 10-2 at

18). Ms. Matthews told Ms. Standridge, “Oh, my gosh, you are going to have your

hands full.” (Id. at 18). Ms. Matthews continued to make frequent comments about

how many children Ms. Standridge was going to have, particularly as

Ms. Standridge’s pregnancy became more visible. (Id. at 24).

Ms. Matthews testified that the second interview also did not go very well.

(Doc. 10-3 at 34). She felt Ms. Standridge “was more interested in leaving [the

Learning Center] than trying to come [to Cleveland Elementary School]—her

interview came across as her trying to get out of where she was versus trying to be

in our school.” (Id. at 21). Ms. Matthews conceded that she did not write that

impression down in her interview notes, though she did write down that

Ms. Standridge had “used the word stuck with 7th, 8th, and 9th grade.” (Id. at 21–

22).

Ms. Matthews recommended Emilee Nelson for the transitional kindergarten

position. (Id. at 22). Ms. Nelson had graduated with a bachelor’s degree and was

planning to enroll in a master’s program but did not have either a general education

certificate or a special education certificate by the time of the interview. (Doc. 10-3

at 24–26). She received her early childhood education certificate in June 2022

(before the school year began) and an interim certificate in special education in

March 2023 (after the school year had begun). (Id. at 24, 92). Ms. Matthews testified

that she recommended Ms. Nelson for the position because she had a strong

interview, completed her residency at Cleveland Elementary School and then

worked as a substitute teacher for a first grade classroom there for the rest of the

school year, had experience working at a pre-K center, had a son with autism, and

expressed a desire to continue her education in special education. (Id. at 29). The

Board approved Ms. Matthews’s recommendation. (Doc. 10-11 at 6).

The Learning Center also has a transitional program called “Crosswalks.”

(Doc. 10-4 at 16). One of the jobs Ms. Standridge applied for was a K-3 and K-4

Crosswalks position. (Id. at 41). The director of the Learning Center, Steven Love,

conducted the interviews for this position. (See id. at 72). By this time, he knew that

Ms. Standridge was pregnant. (Doc. 10-2 at 40; doc. 10-4 at 35). Mr. Love—who

had also sat in on the interviews for the Cleveland positions—testified that he felt

Ms. Standridge had made clear in her interview that she did not want to stay at the

Learning Center and “was looking for any and every opportunity to leave.” (Doc.

10-4 at 35; see also id. at 45, 54). Mr. Love agreed, however, that his interview notes

do not reflect Ms. Standridge explicitly saying she wanted to leave the Learning

Center. (Id. at 46).

Mr. Love recommended Ashley Seals for the Crosswalks position. (Id. at 21).

Ms. Seals had a Virginia teaching certificate but no Alabama teaching certificate.

(Id. at 33–34, 37). Mr. Love testified that he recommended her because he was

impressed by her interview, she had great references, and she wanted to be at the

Learning Center. (Doc. 10-4 at 35). The Board offered Ms. Seals the position in June

2022. (Id. at 136). She received her Alabama teacher’s certificate in October 2022,

after the start of the school year. (Id. at 140).

During Ms. Standridge’s fourth and fifth pregnancies, Mr. Love made

comments like, “well, you know what causes [pregnancy,] don’t you?” (Doc. 10-2

at 27). He also asked if her family had cable, from which Ms. Standridge inferred

that he meant “if you don’t have cable, all you do is have sex.” (Id. at 27). And he

made comments about five kids being a lot of kids. (Id. at 38–39). When

Ms. Standridge asked what she could do better to get a different position, Mr. Love

told her that she was so good at her position that finding a replacement would be

difficult. (Id. at 41). He explained: “It is so much easier to fill a position here than it

is over there,” which Ms. Standridge believed referred to Cleveland Elementary

School. (Doc. 10-2 at 41).

Ms. Standridge also applied for a position at Locust Fork Elementary School.

(See id. at 23; doc. 11 at 18 ¶ 35; doc. 16 at 8 (not disputing ¶ 35)). Amy Williamson

is the principal of that school. (Doc. 10-6 at 4). Ms. Williamson and Ms. Standridge

attended the same church and both served in the choir, though Ms. Williamson knew

her by her nickname of “Katy” instead of her legal name of “Glenda.” (Id. at 7–9).

When the choir director asked Ms. Williamson to interview Ms. Standridge for a

position at Locust Fork Elementary School, she looked at the list of applicants and

thought Ms. Standridge had not applied because she did not see a “Katy Standridge”

on the list. (Id. at 9, 21). Ms. Williamson testified she never looked at

Ms. Standridge’s application before this lawsuit was filed. (Id. at 19).

Ms. Williamson recommended Amy Love for the position. (Doc. 10-6 at 10).

Ms. Love had worked at Locust Fork for two years as an instructional aide, then

completed her student teaching there. (Id. at 10). When Ms. Williamson

recommended her for the position, Ms. Love had finished her coursework for a

bachelor’s degree in elementary education but had not yet received her degree or a

teacher’s certificate. (Id. at 13–14). The Board accepted Ms. Williamson’s

recommendation and offered Ms. Love the position. (Id. at 92–93, 97). Ms. Love

received her degree in December 2022 and her teacher’s certificate in April 2023.

(Doc. 10-6 at 14; id. at 65).

In July 2022, Ms. Standridge applied for a position as a kindergarten teacher

at Cleveland Elementary School. (Doc. 1 ¶ 24; doc. 5 ¶ 24; doc. 10-2 at 30). Because

of Ms. Standridge’s two previous interviews, Ms. Matthews decided not to invite her

to interview for that position. (Doc. 1 ¶ 25; doc. 5 ¶ 25; doc. 10-3 at 34).

Ms. Matthews recommended Sydney Bailey for the position. (Doc. 10-3 at 152).

Ms. Bailey had a bachelor’s degree in psychology and was enrolled in a master’s

program due to conclude the following year, but she did not have any teacher

certifications. (Id. at 34, 37). Ms. Matthews attested that she selected Ms. Bailey

because she seemed like she would work well with younger children and she had

experience as a camp counselor and a substitute teacher for kindergarten and first

grade. (Doc. 10-1 at 5 ¶ 10). The Board accepted the recommendation. (See doc. 11

at 8 ¶ 12; doc. 16 at 6–7 (not disputing ¶ 12)). Ms. Bailey received an interim

employment certificate in March 2023. (Doc. 10-3 at 117).

Ms. Standridge attests that Ms. Nelson, Ms. Seals, Ms. Love, and Ms. Bailey

were not pregnant when the Board hired them or during the 2022–2023 school year.

(Doc. 15-1 ¶¶ 1–4). The Board objects to the affidavit on hearsay grounds but does

not dispute that the hired candidates were not pregnant at the time, nor does the

Board make any argument that Ms. Standridge’s claim fails because other candidates

were pregnant. (Doc. 17 at 6). Thus, for purposes of this motion, the court will accept

this fact as undisputed.

II. DISCUSSION

Ms. Standridge alleges that the Board discriminated against her based on her

pregnancy, in violation of Title VII, by failing to promote her into the four positions

discussed above. (Doc. 1 ¶¶ 1, 33–37). The Board moves for summary judgment on

the ground that Ms. Standridge cannot prove discrimination. (Doc. 11 at 21).

Title VII prohibits covered employers from “discriminat[ing] against any

individual with respect to [her] compensation, terms, conditions, or privileges of

employment, because of such individual’s . . . sex.” 42 U.S.C. § 2000e-2(a)(1). The

term “because of sex” includes “because of or on the basis of pregnancy.” Id.

§ 2000e(k). A plaintiff may prevail on a Title VII claim in several ways, including

by presenting circumstantial evidence satisfying the burden-shifting framework set

out in McDonnell Douglas Corp. v. Green, 411 U.S. 792, 803–04 (1973) or by

demonstrating a “convincing mosaic of circumstantial evidence that warrants an

inference of intentional discrimination.” Lewis v. City of Union City, 918 F.3d 1213,

1220 & n.6 (11th Cir. 2019) (en banc). Ms. Standridge contends that she can satisfy

those two tests using circumstantial evidence. (See generally doc. 16).

Under the McDonnell Douglas framework, the plaintiff bears the initial

burden of establishing a prima facie case of discrimination. Chapman v. AI Transp.,

229 F.3d 1012, 1024 (11th Cir. 2000) (en banc). In pregnancy discrimination cases,

the plaintiff may do so by presenting evidence that (1) she belongs to a protected

group; (2) she was qualified for the position she sought; (3) she suffered an adverse

employment action; and (4) the employer treated similarly situated employees

outside the protected class differently. DuChateau v. Camp, Dresser & McKee, Inc.,

713 F.3d 1298, 1302 (11th Cir. 2013); Holland v. Gee, 677 F.3d 1047, 1055 (11th

Cir. 2012). If the plaintiff carries that burden, the “employer must articulate a

legitimate, nondiscriminatory reason for the challenged employment action.”

Chapman, 229 F.3d at 1024. If the defendant does so, the plaintiff must present

evidence from which a jury could find that the proffered reasons were pretextual. Id.

at 1024–25. Establishing that a reason is pretextual requires the plaintiff to show

“both that the reason was false, and that discrimination was the real reason.”

St. Mary’s Honor Ctr. v. Hicks, 509 U.S. 502, 515 (1993); see also Brooks v. Cnty.

Comm’n of Jefferson Cnty., 446 F.3d 1160, 1163 (11th Cir. 2006).

The Board contends that Ms. Standridge cannot make out a prima facie case

of discrimination because for three of the positions, the interviewers concluded that

another candidate was equally or more qualified. (Doc. 11 at 25–28, 31–33). This

argument fails because the second element of the prima facie case does not ask

whether the selected candidate was more qualified than the plaintiff but instead

whether the plaintiff was qualified for the position. See DuChateau, 713 F.3d at

1302; see also Walker v. Mortham, 158 F.3d 1177, 1193 (11th Cir. 1998) (“Although

a plaintiff may be forced to address relative qualifications if the defendant presents

them to rebut the plaintiff’s presumption of discrimination, the plaintiff need not

introduce evidence regarding relative qualifications before then; she need only prove

that she herself was qualified to perform the coveted job.”).

The Board also contends that Ms. Standridge cannot establish her prima facie

case with respect to the Locust Fork position because Ms. Williamson did not know

that Ms. Standridge had applied. (Doc. 11 at 34). But the Eleventh Circuit’s

formulation of the prima facie case does not require Ms. Standridge to establish that

the interviewer knew of the plaintiff’s application. She need only establish that she

is a member of a protected group, she was qualified for the position, she was not

hired, and she was treated differently than similarly situated employees outside her

protected class. See DuChateau, 713 F.3d at 1302; Holland, 677 F.3d at 1055. The

court declines to find that Ms. Standridge failed to make out a prima facie case based

on a requirement that the Eleventh Circuit has never set forth.

Because the Board’s only arguments with respect to the prima facie case are

unpersuasive, it “must articulate a legitimate, nondiscriminatory reason for the

challenged employment action.” Chapman, 229 F.3d at 1024. The Board asserts that

for three of the positions, the interviewers who made hiring recommendations

believed that the selected candidates were better qualified, and for one of the

positions, the interviewer did not know Ms. Standridge had applied. (Doc. 11 at 25–

27, 31–34). Because the Board presents evidence from each of the interviewers

consistent with those reasons (see doc. 10-3 at 21, 29, 34; doc. 10-4 at 35; doc. 10-6

at 9, 21), it has carried its burden, see Tex. Dep’t of Cmty. Affs. v. Burdine, 450 U.S.

248, 254 (1981) (“The defendant need not persuade the court that it was actually

motivated by the proffered reasons. It is sufficient if the defendant’s evidence raises

a genuine issue of fact as to whether it discriminated against the plaintiff.”) (citation

omitted). As a result, to survive under the McDonnell Douglas framework,

Ms. Standridge must present evidence from which a reasonable jury could find that

those reasons are pretextual. See Chapman, 229 F.3d at 1024–25.

“[T]o establish pretext at the summary judgment stage, a plaintiff must

demonstrate such weaknesses, implausibilities, inconsistencies, incoherencies, or

contradictions in the employer’s proffered legitimate reasons for its action that a

reasonable factfinder could find them unworthy of credence.” Gogel v. Kia Motors

Mfg. of Ga., Inc., 967 F.3d 1121, 1136 (11th Cir. 2020) (en banc) (quotation marks

omitted). Ms. Standridge contends that she can show pretext because she presented

evidence that the selected candidates were not qualified for the positions at all, the

interviewers violated Board policy by failing to give preference to the candidate with

the more advanced degree and more experience, Ms. Matthews and Mr. Love lacked

any written notes from the interviews substantiating their testimony that they

recommended candidates who had better interviews, Mr. Love made comments

indicating that he felt it would be easier to find a substitute for Ms. Standridge if she

remained at the Learning Center, and a jury could disbelieve Ms. Love’s assertion

that she did not know Ms. Standridge had applied. (Doc. 16 at 28–38).

Not all of Ms. Standridge’s arguments are persuasive. In particular, the court

rejects her arguments that the Board was required to recommend her because she

had a more advanced degree and more experience and that the lack of

contemporaneous notes from Ms. Matthews and Mr. Love rebuts their testimony

about their interview impressions. (See id. at 33–35). But Ms. Standridge has

presented sufficient evidence to require a jury to determine whether the Board’s

reasons for three of its hiring decisions were pretextual.

The court begins with the transitional kindergarten position at Cleveland

Elementary School. Ms. Standridge argues that the selected candidate, Ms. Nelson,

was unqualified for the position because she lacked a special education certificate

until March 20, 2023. (Id. at 29). However, the undisputed evidence is that the

transitional kindergarten position did not require a special education certificate.

(Doc. 10-7 at 15–17). And Ms. Nelson received the required certificate—an early

childhood certificate—in June 2022, before the school year began. (Doc. 10-3 at 92).

Ms. Standridge has not presented evidence from which a jury could find that

Ms. Nelson lacked the required qualifications.

The Board presents evidence that Ms. Matthews selected Ms. Nelson because

she had a better interview, had worked at Cleveland Elementary School before, had

a child with special needs and had worked at a pre-K center, and was continuing her

education in special education. (Id. at 29). By contrast, Ms. Matthews felt that

Ms. Standridge’s interview went badly and that Ms. Standridge wanted to leave the

Learning Center more than she wanted to work at Cleveland Elementary School. (Id.

at 21, 34). Ms. Matthews’s interview notes do not contradict her testimony about her

impression of Ms. Standridge’s interview. (See id. at 18–20). And “a subjective

reason for an employer’s action—such as poor interview performance—can be as

legitimate as any other reason.” Bass v. Bd. of Cnty. Comm’rs, Orange Cnty., 256

F.3d 1095, 1105 (11th Cir. 2001).

Accordingly, no reasonable jury could find pretext based on “weaknesses,

implausibilities, inconsistencies, incoherencies, or contradictions” in

Ms. Matthews’s proffered reasons for selecting Ms. Nelson over Ms. Standridge.

Gogel, 967 F.3d at 1136. Because Ms. Standridge relies on the same evidence to

support her convincing mosaic of circumstantial evidence (doc. 16 at 38–39), this

claim also cannot survive under that test. The court WILL GRANT the motion for

summary judgment as to Ms. Standridge’s failure-to-hire claim about the transitional

kindergarten position at Cleveland Elementary School.

The other three positions are different. Taking the disputed facts in

Ms. Standridge’s favor, all three of the interviewers knew that Ms. Standridge was

pregnant when she applied for those positions. (Doc.10-2 at 18, 40; doc. 10-6 at 7).

And although Ms. Williamson testified that she did not know Ms. Standridge had

applied, there is evidence that a mutual friend notified Ms. Williamson of

Ms. Standridge’s application. (Doc. 10-6 at 9, 21). Based on this evidence and the

fact that “Standridge” is not a very common name, a jury could reject

Ms. Williamson’s explanation that she did not realize “Glenda Standridge,” who had

applied for the position, was the same person as “Katy Standridge.” (See id. at 7–9).

Moreover, the Board hired three candidates who lacked the required

certifications over Ms. Standridge, who had the required certifications. (Doc. 10-2

at 6; doc. 10-3 at 117; doc. 10-4 at 140; doc. 10-6 at 14, 65). This was in violation

of the Board’s written policy that “[a] candidate seeking employment . . . must

have . . . a valid Alabama teacher’s certificate.” (Doc. 10-4 at 128). Although the

Board presents evidence that it routinely hires candidates who lack that qualification

as long as they are eligible to receive a certificate (doc. 10-7 at 12), it is still a

violation of the written policy. See Alexander v. Fulton Cnty., 207 F.3d 1303, 1340

(11th Cir. 2000), overruled in other part by Manders v. Lee, 338 F.3d 1304, 1328

n.52 (11th Cir. 2003) (en banc) (“[B]oth the Supreme Court and [the Eleventh

Circuit] have observed that evidence showing an employer hired a less qualified

applicant over the plaintiff may be probative of whether the employer’s proffered

reason for not promoting plaintiff was pretextual.”); see also Bass, 256 F.3d at 1108

(“[T]he fact that the [employer] promoted . . . an employee who was unqualified

under the [employer]’s criteria[ ] over [the plaintiff] supports an inference of

discrimination.”). And despite the Board’s assertion that Ms. Standridge also lacked

a teacher’s certificate when it hired her (doc. 11 at 6 ¶ 4), she had an interim

certificate when hired (doc. 10-2 at 10).

The Board presents evidence that Ms. Matthews and Mr. Love found the other

candidates to be a better fit for their schools in light of their belief that

Ms. Standridge wanted to leave the Learning Center more than she wanted to work

in the positions for which she had applied. (Doc. 10-1 at 5 ¶ 10; doc. 10-3 at 29, doc.

10-4 at 35). As stated above, “a subjective reason for an employer’s action—such as

poor interview performance—can be as legitimate as any other reason.” Bass, 256

F.3d at 1105. But for these positions, Ms. Standridge’s evidence that the candidates

were not qualified under the written hiring policy suffices to create a dispute of

material fact that a jury must resolve. The court WILL DENY the motion for

summary judgment with respect to Ms. Standridge’s failure-to-hire claim about the

Crosswalks position, the Locust Fork position, and the kindergarten position at

Cleveland Elementary School.

III. CONCLUSION

The court WILL GRANT IN PART and WILL DENY IN PART the

Board’s motion for summary judgment. The court WILL GRANT the motion as to

Ms. Standridge’s claim that the Board discriminated against her by failing to hire

her for the transitional kindergarten position at Cleveland Elementary School. The

court WILL DENY the motion as to Ms. Standridge’s claim that the Board

discriminated against her by failing to hire her for the Crosswalks position, the

Locust Fork position, and the kindergarten position at Cleveland Elementary School.

DONE and ORDERED this February 24, 2025.

ANNEMARIE CARNEY AXON

UNITED STATES DISTRICT JUDGE

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