Rebecca Cartee-Haring was hired by Central Bucks West High School in 2007, ultimately serving as the Head Coach of the girls’ lacrosse team. The School makes year-to-year coaching appointments and reserves the right not to reappoint a coach from year to year.
The captain of the girls’ lacrosse team during the 2018-2019 athletic season was a student identified as Rita Roe. Conflicts between Cartee-Haring and Roe arose, and Roe’s mother, Jane Doe, claimed that Cartee-Haring was bullying her daughter.
Once the 2018-2019 season began, Doe continued to make allegations to the School District about how Cartee-Haring was treating her daughter. Multiple times throughout the season, Cartee-Haring told the School that she was experiencing a negative mental state and severe stress. The Director of Human Resources encouraged Cartee-Haring to use the employee assistance program.
In May 2019, the School District launched an investigation into allegations that Cartee-Haring was bullying Roe. The investigative report concluded that Cartee-Haring did not engage in any behavior that rose to the level of bullying, but, at times, did not maintain the utmost professionalism.
That summer, one lacrosse team member hosted a pool party at her family’s home. Cartee-Haring was invited and attended.
For the 2019-2020 school year, the District hired a female in her 20s as the Head Coach of the girls’ lacrosse team instead of Cartee-Haring. In May 2020, Cartee-Haring filed a charge of discrimination with the Equal Employment Opportunity Commission (EEOC), which issued a right to sue letter in August 2020.
In September 2021, Cartee-Haring reapplied for the Head Coach position. In November 2021, Cartee-Haring interviewed for the position. The interviewers scored the two final candidates, and Cartee-Haring received a score of 193, whereas the other candidate received a score of 203. Cartee-Haring was not selected for the position, and emailed the Director of Human Resources that she felt she had been discriminated against due to her filing the lawsuit against the District.
The District investigated Cartee-Haring’s retaliation concerns, at first internally, and then by hiring a private law firm. Both investigations concluded that there had been no retaliation or discrimination. In June 2022, Cartee-Haring filed an amended Charge of Discrimination against the District with the EEOC and the Pennsylvania Human Relations Commission. Cartee-Haring received a right-to-sue letter from the EEOC in September 2022.
Cartee-Haring’s lawsuit alleged a host of claims, including gender discrimination, disability discrimination, and retaliation.
Gender Discrimination
For the gender discrimination claim, the District argued that (1) there was no adverse employment action since Cartee-Haring’s one year contract was simply not renewed; (2) a woman was hired to replace her; and (3) even if Cartee-Haring had enough evidence to establish a gender discrimination claim, the District had legitimate, nondiscriminatory reasons for not rehiring Cartee-Haring as Head Coach, principally, her mishandling of the conflict between herself and Rita Roe.
In response, Cartee-Haring argued that (1) the non-renewal was an adverse employment action; (2) there was an inference of sex discrimination because male coaches remained employed by the District even when they attended parties at the homes of players.
The Court agreed that nonrenewal of an employee’s contract was an adverse employment action. However, the Court concluded that Cartee-Haring failed to show that members of the opposite sex were treated more favorably. While Cartee-Haring argued that male coaches attended parties hosted by student athletes and retained their coaching positions, the Court reasoned that Cartee-Haring did not provide any evidence that the male coaches were found to have mishandled an escalating situation with a student athlete or that the male coaches were subject to an investigation for bullying a student athlete, like Cartee-Haring was in this case.
The Court also agreed that the District had a legitimate, non-discriminatory reason for terminating Cartee-Haring’s employment apart from the pool party, namely, the unprofessional conduct resulting from the conflict between her and Rita Roe. The Court granted the District’s motion for summary judgment on the gender discrimination claims.
Disability Discrimination
For the disability discrimination claim, Cartee-Haring argued that she was not reappointed as Head Coach due to a perceived disability. Specifically, Cartee-Haring argued that she suffered from depression and migraines, and that she sent an email to the Director of Human Resources stating that she was under severe stress, behind on her classwork, and was in great physical pain, requesting advice on how to handle the situation. The District argued that this was not enough to show that the District regarded her as having a disability, and that stress was not a disability recognized by the ADA.
The Court determined that Cartee-Haring failed to make a threshold showing that she was disabled under the ADA. While her complaint alleged that she had a mental condition resulting from her experiences as Head Lacrosse Coach, which substantially affected major life activities such as concentrating, sleeping, and interacting with others, the evidence only established that Cartee-Haring was experiencing generalized stress, which does not rise to the level of “disabled’ under the ADA. The Court also determined that the Director of Human Resource’s statement encouraging Cartee-Haring to use the employee assistance program did not establish the School as regarding Cartee-Haring as having a disability. The Court dismissed the disability discrimination claims.
Retaliation
Lastly, the Court considered Cartee-Haring’s claims that she was retaliated against for filing her initial lawsuit when the District chose not to hire her as Head Coach for the 2021-2022 season. The District argued that its decision to not hire Cartee-Haring a second time was unrelated to her filing the lawsuit. The lawsuit was filed in April 2020, and she applied for the job in September 2021, a 17-month difference, which was too long to establish a causal link for retaliation. Even assuming that Cartee-Haring could establish a causal connection, the District argued it had a legitimate non-discriminatory reason for not hiring her: the interview panel used objective scoring criteria and another candidate scored higher than Cartee-Haring.
The Court agreed with the District, finding no causal connection between the lawsuit and the decision not to hire Cartee-Haring. The Court likewise agreed with the District that the decision not to hire Cartee-Haring was due to objective scoring criteria when compared to the other candidate. The Court dismissed the retaliation claim.
Note: This case provides a relevant overview of the types of claims an employee may bring when their employment contract is not renewed. Here, the School had investigated the Coach’s concerns as they arose and had documentation to support its decisions.
Cartee-Haring v. Cent. Bucks Sch. Dist. (E.D.Pa. June 11, 2024) 2024 U.S.Dist.LEXIS 103302.