These kids are really mean to the teacher. Is this a “hostile environment”?

Marie Youngblood had taught at Willowridge High School in Fort Bend ISD for just one semester when the principal informed her that he would be recommending nonrenewal of her contract at the end of the year.  At the end of the year, Ms. Youngblood was again informed that the contract would not be renewed. She retired before that happened. Then she filed the lawsuit.

In the suit, Ms. Youngblood claimed that she was subjected to racial discrimination because her classroom was a “hostile work environment.” That term usually comes into play when an employee is treated badly by supervisors.  But in this case, the teacher claimed that the students in her class created the racially charged, hostile environment.  She alleged that the high school students objected to an African-American teaching Spanish, and that this led to disparaging comments about her teaching ability, verbal threats of violence and physical acts, such as throwing a plastic container of pencils and markers at her.

To make the school district liable for this classroom environment, Ms. Youngblood would have to prove that the district 1) knew what was happening; and 2) “failed to take prompt remedial action.”  The district certainly knew what was happening—Ms. Youngblood filed over 100 student discipline referrals in that rocky first semester.  But the court recited numerous steps that the district took to address the situation. The school disciplined kids who were causing disruption; made more frequent visits to the classroom; and brought in a consultant who offered “helpful and constructive feedback” to the teacher. The court tossed the case out, noting that Ms. Youngblood could not possibly establish that Fort Bend “failed to take prompt remedial action.”

Getting back to our original question: can a teacher establish that she is working in a “hostile environment” based on how the students treat her?  The court noted that our 5th Circuit has not specifically addressed that question.  However, based on the elements of proof required in this type of lawsuit, it seems clear that something beyond unruly students would be necessary. No matter how ugly it gets in the classroom, the teacher has a winning case only if the teacher can also show administrative neglect—the failure to “take prompt remedial action.”

Notice that Ms. Youngblood was an experienced teacher, but she must have been on a probationary contract—it was her first year in the district after a 25-year career in Houston ISD.  Thus this case is yet another illustration of the fact that probationary teachers can seek legal recourse.  Fort Bend won this case because it did a good job of documenting, and then proving in court, its efforts to assist a teacher who was having difficulty.  Probationary status had nothing to do with it.

The case of Youngblood v. Fort Bend ISD was decided by the federal court for the Southern District of Texas on November 13, 2014.  The 5th Circuit later affirmed the ruling and the Supreme Court denied the writ of certiorari on April 19, 2016.  Case closed.


File this one under: TITLE VII