
Terminated African-American Employee Failed To Establish Prima Facie Case Of Retaliation
In this
case, the United States District Court held that a terminated
African-American administrative assistant/registrar at a Virginia high school
failed to establish a prima facie case of retaliation under Title VII. Assuming
that her discrimination complaint to the principal and the school board's
director of human resources during their meeting constituted protected
"opposition activity," she had not linked that complaint to her termination.
When she complained of discrimination, her job already hung in the balance. She
had not proffered evidence that her mention of discrimination contributed to the
principal's recommendation that her contract not be renewed for the following
year, or that her opposition activity precipitated the school board's decision.
Samuel v.
Williamsburg-James City County School Bd. ex rel. Koch