The United States Court of Appeals for the Fourth Circuit recently affirmed an order from the United States District Court for the District of Maryland granting summary judgment for a director of human resources for a Maryland board of education.  The director of human resources was sued by a former teacher who was non-renewed after being involved in a physical altercation with a student.  The former teacher alleged that the defendants discriminated against him because of his race and also falsified various details about the altercation with potential employers which prevented him from finding subsequent employment.

The District Court granted summary judgment to all defendants, noting that the Plaintiff had “failed to produce any evidence suggesting that . . . he was treated more harshly” than any similarly situated teachers and even if he had produced such evidence there was nothing in the record that remotely suggested that his treatment by the defendants was motivated by his race.  The District Court also held that there was nothing in the record that demonstrated that any of the defendants had shared any false information regarding the Plaintiff's physical altercation with a student.  The Court noted that the record was clear that only one of the defendants had ever spoken with a prospective employer about the Plaintiff and that conversation was limited to the “fact” that the Plaintiff was involved in an altercation and was ineligible for rehire by the board of education.  Accordingly, the Court granted the defendants' motion for summary judgment and closed the case.  On appeal, the Fourth Circuit found no error and affirmed the grant of summary judgment for the reasons stated by the District Court.