John Wilson, Jr. worked as the head coach of the men’s
basketball team at Lock Haven University of Pennsylvania from 1999
Beginning in 2002, he received several poor performance
evaluations from LHU Athletics Director Sharon Taylor. The evaluations
documented great concern for Wilson’s fundraising, his players’ low
grades, and his team’s poor win-loss record. On two occasions, the NCAA
suspended him after discovering he allowed students to play even though
they weren’t eligible under league rules. Wilson was told in April 2009
his employment contract wouldn’t be renewed when it expired in 2011. He
filed a complaint in December 2009, alleging LHU and Taylor
discriminated against him on the basis of race (black) and created a
hostile work environment.
Wilson claimed his race played a role in his poor
performance evaluations (making him ineligible for merit-based pay
increases) and the nonrenewal of his employment contract.
Wilson alleged LHU athletes with white coaches received
better treatment than his players with respect to rule violations. He
claimed that because of his race, LHU failed to adequately defend him
when it was determined he received different treatment regarding
Wilson alleged his assistant coach received a lower
salary than another assistant coach. He also pointed to an email he sent
to Taylor in which he referred to Taylor’s comment that the
presidential search committee consisted of three retired white men and
Taylor’s question to him about whether he thought she was racist.
After the District Court granted summary judgment for the defendants, Wilson appealed.
Wilson, Jr. v. Lock Haven University, et al., No. 11-2221 (3d Cir. 04/05/12).
Did the appellate court uphold the judgment for the defendants?
A. Yes. The appeals court agreed with the trial
judge in that the coach failed to demonstrate all the elements of a race
B. Yes. Although the coach introduced anecdotal
evidence of possible race discrimination, it didn’t rise to the level of
race discrimination under the law.
C. No. The appellate court held that employees
can’t expect a perfect workplace where jokes or funny comments are
categorically prohibited by the administration.
D. No. The appeals court held that the coach
introduced sufficient evidence to preclude summary judgment and remanded
the case for trial.
Correct answer: A
Wilson argued he was fired from his position due to
racial discrimination. He had to show that: (1) he belonged to a
protected class; (2) he was qualified for the position; (3) he was
subjected to an adverse employment action despite being qualified; and
(4) the adverse employment action was made under circumstances raising
an inference of discriminatory action. The defendant had to articulate
some legitimate, nondiscriminatory reason for the adverse employment
action. Then Wilson had to show the employer’s stated reason was
pretextual — that is, an excuse to cover the real unlawful reason for
The appeals court agreed with the District Court that
the defendants asserted several nondiscriminatory reasons for the
adverse employment actions against Wilson, and Wilson didn’t offer
sufficient evidence to show their reasoning was a pretext for
discrimination. The judgment was affirmed.
You Make the Call
This regular feature details a recent court case. Review
the facts. Think about how you would have handled the situation. Then
test your legal knowledge by trying to determine how the court ruled.