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Tuesday, November 8, 2022

Court Upholds Ruling That School District Did Not Engage in “Reverse Discrimination”

Earlier this month, the Seventh Circuit Court of Appeals ruled in favor of a school district, finding that an athletic director could not maintain a “reverse” race discrimination claim against his employer (“School District”). Groves v. South Bend Community School Corporation

Groves had been a teacher in the School District for 16 years before transitioning to the role of athletic director in 2007. In 2017, Groves interviewed for a newly created position that encompassed the entire School District. After the application and interview process, Groves claims that he was passed up for the role in favor of his Black colleague and filed a civil rights lawsuit alleging he had been a victim of race discrimination and that the other candidate was only hired because he is Black.

Two years later, the School District again reconfigured its athletics program, eliminating the district-wide position and creating four hybrid Dean of Students/Dean of Athletics roles at each of the high schools within the District. Because of this structural change, Grove no longer had a job in the School District, and the same Black colleague he argued was underqualified in his original lawsuit was hired for one of the Dean positions. Groves added this claim to his discrimination lawsuit, again claiming that he was passed upon in favor of his colleague based on race.

The district court granted the School District's motion for summary judgment prior to trial, finding that Groves could not, as a matter of law, present a case that would result in reasonable jurors deciding that the School District had engaged in race discrimination. While Groves had claimed he was better qualified for the job than his colleague, the district court held that the evidence collected in the case did not support his claims.

Groves appealed to the Seventh Circuit Court of Appeals, but that Court upheld the district court's ruling in favor of the School District. The Court of Appeals determined that Grove had failed to overcome the School District’s legitimate justification for hiring the other candidate over him. The School District had presented sufficient evidence that the other candidate was better qualified, had performed better in interviews, and had a respectable reputation to rebuild the athletics program within the School District. Because Groves could not show that these justifications were false, and because he could not show that the School District had discriminated against him based on his race, the Court of Appeals upheld the district court's ruling in favor of the School District.

Post Authored by Erin Monforti & Julie Tappendorf, Ancel Glink


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