John Wilson, Jr. worked as the head coach of the men’s basketball team at Lock Haven University of Pennsylvania from 1999 through 2011.

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 financial aid.

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 discrimination case.

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 his firing.

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.