Brookhaven School District discrimination lawsuit revived by new opinion

Published 3:30 pm Wednesday, September 27, 2023

BROOKHAVEN — A lawsuit filed by educator Larenda Harrison vs the Brookhaven School District has been revived by a new court opinion. Harrison sued the school district for discrimination resulting from a 2019 incident where she alleged discrimination based on sex and race. 

Her case was originally dismissed by US Court of Appeals Fifth Circuit Judge Taylor B. McNeel in Sept. 2021. Harrison had sued Brookhaven School District for the reimbursement of $2,000 in training expenses. 

A new opinion filed by the district court last Thursday revives her case. The judges wrote in their opening statement that until August 2023, her arguments would not have stated a Title VII claim because “they did not concern an ‘ultimate employment decision’ under our older (and narrower) Title VII.” 

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However, a recent court ruling in Hamilton v. Dallas County made certain Title VII “requires a broader reading than our ‘ultimate employment decision’ line of cases permitted and thus “end[ed] that interpretive incongruity” by removing that requirement.” US Court of Appeals Fifth Circuit reversed the district court’s decision to dismiss the case and remanded the case for further proceedings. The opinion states her alleged facts satisfy an adverse employment action prong and element using the lens of Hamilton v. Dallas County and thus poses a plausible Title VII claim. 

Some background

According to the court documents from the 2021 case, she alleged the school district’s failure to reimburse her costs to attend a career development program was an act of discrimination and retaliation. Her claims were dismissed on grounds of not qualifying as adverse employment action. 

She originally filed a charge of discrimination with the Equal Employment Opportunity Commission in  2019. Her charge described an incident where she was denied reimbursement of funds while three other males were compensated for the training. 

In 2020, she filed a complaint against the Brookhaven School District for violating her civil rights under Title VII. The case was dismissed with prejudice, meaning the ruling was final, by the district court because her claims did not qualify as adverse employment action.