A federal jury concluded that the former Superintendent of the East Greenbush Central School District failed meet her burden of proving she was terminated based on her gender and pregnancy status. Accordingly, the District was not liable for the more than $4 million in damages sought.

Angela Nagle became Superintendent of the District in 2008. Nagle and the District amended her employment agreement several times, and the last amendment provided that she was to remain an employee through June 2016. Nagle went on maternity leave in December 2014 and returned to work in March 2015. Shortly after returning, the Board of Education for the District informed Nagle that the District would not renew her contract.

Nagle commenced an action against the District, the Board, and individual Board members. In her Complaint, Nagle asserted a number of claims against them, including claims under Title VII and the Pregnancy Discrimination Act (PDA), 42 U.S.C. § 1983, Title IX, the Americans with Disabilities Act, and the Family and Medical Leave Act.

Central to these claims were allegations that the District terminated Nagle for exercising her right to take maternity leave, and that stereotypes regarding working mothers of young children motivated the Board’s decision and behavior toward Nagle. Among other things, Nagle based her claims on alleged Board member comments questioning Nagle’s ability to work following her pregnancy.

The Board responded that it had legitimate, nondiscriminatory reasons not to renew Nagle’s employment, including Nagle’s communication problems with the Board, opposition to Board directives, and difficult relationships with staff.

The Honorable Brenda K. Sannes, U.S. District Judge for the Northern District of New York, significantly pared down Nagle’s claims on summary judgment. Judge Sannes’s order left only two claims for trial before the jury: Title VII and PDA discrimination claim against the District and the Board, and the 42 U.S.C. § 1983 claim against the individual defendants.

Deliberating after presentation of the evidence at trial, the jury did not get beyond the first question on the special verdict form. It concluded Nagle did not establish by a preponderance of the evidence that her gender was a motivating factor in the District’s decision not to extend her employment. The jury thus concluded the defendants were not liable for gender discrimination, much less for a damages award of $4+ million that Nagle was seeking.

Lesson for employers: Even if remarks of concern made by management and other decision-makers are well-intentioned, employees may construe them as evidence of discrimination. Nagle’s case brings to mind the importance of workplace training.