Fired teacher sues district, claims violation of Civil Rights Act

A school district fired a teacher after six students complained that he made racially insensitive remarks in the classroom. The teacher sued, alleging that the district discriminated against him based on his Mexican American ancestry, violating Title VII of the Civil Rights Act. 

The school district requested that the lawsuit be dismissed, and the district court granted that request, reasoning that the teacher failed to produce sufficient evidence to show that the district had discriminated against him. The teacher appealed that decision to the court of appeals.

The court of appeals noted that Title VII prohibits employment discrimination on the basis of race, ethnicity, or national origin. Direct evidence of discriminatory intent is rare, so an employee usually proves that discrimination occurred through circumstantial evidence. 

If an employee wants to rely on circumstantial evidence to prove discrimination, the caselaw says that an employee must first offer sufficient evidence that they 

1. are a member of a protected class,
2. were qualified for their position,
3. suffered an adverse employment action, and
4. were treated less favorably than other similarly situated employees who were not members of the protected class, under nearly identical circumstances.

In this case, there was no dispute that the first three criteria had been met. The question before the court was whether the teacher had presented any evidence to show that he had been treated less favorably than other teachers who did not have Mexican American ancestry who had made racially insensitive remarks in the classroom. 

The court of appeals determined that he did not produce any evidence to show that this was the case and therefore, upheld the lower court's decision to dismiss his lawsuit.