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Eleventh Circuit Affirms Dismissal of Pay Discrimination Claims by Athletic Director

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Eleventh Circuit Affirms Dismissal of Pay Discrimination Claims by Athletic Director

A three-judge panel of the U.S. Court of Appeals for the Eleventh Circuit affirmed the dismissal of a pay discrimination and retaliation suit filed against an Alabama public school by its athletic director. Connie L. Morris claimed that the Bessemer City School District underpaid her following her promotion from P.E. teacher to athletic director and retaliated against her. The summary decision found no reversible error in the jury’s decision in favor of the school district, stating that the appeal merely asked it to reweigh the evidence and second-guess the jury’s decision. The case is Morris v. Bessemer City Board of Education et al., Case Number 24-11534, U.S. Court of Appeals for the Eleventh Circuit.

Morris was a long-time P.E. teacher and basketball coach who became the school district’s athletic director in 2015. Morris sued the school district multiple times over the years, including Title IX complaints about use of school resources, gendered pay disparity related to her athletic director role, and illegal football practices that endangered students and led to program sanctions. Morris alleged that in 2019, the school district superintendent stated that he would choose the next football coach, which amounted to a demotion by taking away her job duties. Accordingly, Morris again sued the school district that year, alleging violations of Title VII, Sections 1981 and 1983 of the Civil Rights Act, and the Equal Pay Act, as well as retaliation. Two claims proceeded to trial, where a jury found in favor of the school district in 2024, concluding that the school district’s decision to eliminate Morris’ position was based on valid, non-retaliatory reasons. 

On appeal, Morris claimed that the jury was defective as it contained only one female juror. She also complained that the judge improperly instructed the jury on state laws about public school employees. Finally, she claimed that the school district engaged in evidentiary misconduct and that the weight of the evidence presented at trial could not support a verdict in the school district’s favor. 

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