A principal sued her former school district, alleging that she suffered a series of adverse employment actions that constituted discrimination against her based on her gender and disability, and in retaliation for filing a claim with the Equal Employment Opportunity Commission. 

The events that formed the basis of her claim began when she was notified that her contract would not be renewed for the upcoming school year because her administrator’s endorsement was about to expire. She filed a charge with the EEOC, alleging that the decision to nonrenew her contract was in retaliation for an EEOC charge she had filed the year before.

A few weeks later, the district withdrew the nonrenewal and offered her a contract. Shortly thereafter, the district consolidated with another district. The principal was then reassigned to serve as the “Vocational/Alternative School Director” with her salary unchanged. This was a new position created as a result of the consolidation. She filed an amendment to her previous EEOC charge, alleging that she had been demoted in retaliation for filing her prior charges. She then resigned from the district.

The principal’s lawsuit was dismissed and she filed an appeal to the Fifth Circuit Court of Appeals. In her appeal, she argued that her reassignment was an adverse employment action because it was a demotion.

The Fifth Circuit Court determined that the reassignment was not a demotion. In doing so, it noted that there was no evidence indicating the reassignment was objectively worse than her prior position as principal. The responsibilities of her new position were similar to her responsibilities as a principal, and the salary remained the same.

Although she claimed that the reassignment subjected her to dangerous working conditions and less interesting work, she was unable to support this claim, since she had no personal knowledge of the day-to-day responsibilities of the job. She testified that “director of the alternative and vocational schools” was a newly created position, no one had informed her of the director's responsibilities, and she never performed any of the responsibilities as she was on leave for the duration of her time in the position. 

Furthermore, the court found that there was no evidence to support a finding that she was reassigned to a position with a less prestigious reputation. It was a new position in a new consolidated school district and thus lacked any history upon which a reputation could be developed. Indeed, the fact that she moved from a high school position to a districtwide position suggested that it may have been a more prestigious position.

The Fifth Circuit Court of Appeals upheld the decision of the district court and dismissed the lawsuit.