Thomas v. Washington County School Board

915 F.2d 922 (1990)

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Thomas v. Washington County School Board

United States Court of Appeals for the Fourth Circuit
915 F.2d 922 (1990)

EL

Facts

The Washington County School Board (the school board) (defendant) had a long-standing practice of filling teaching positions by hiring relatives of current staff members and posting available positions in local school offices and buildings. The school board rarely advertised its vacancies. The school board’s hiring practices included 46 cases of nepotism, in situations in which jobs were filled internally by family members of existing school staff. Between 1963 and 1990, the school system consistently had six Black elementary school teachers and one Black high school coach. For example, when the coach retired, the principal asked the coach to find another Black teacher to replace him. Patricia Thomas (plaintiff), a Black woman with outstanding grades who graduated cum laude, applied for a teaching position in Washington County. Thomas kept her application current with the school system for two years but was passed over three times for various positions. Thomas had erroneously indicated in her cover letter that she had not yet obtained her teaching license. The school board maintained that it never offered Thomas a job because her cover letter indicated she did not yet have a license. Although Thomas’s application was current with the school, the school board hired three separate White teachers who learned about the open positions through word of mouth or through their family members who worked for the school system. Thomas was unaware of the job openings. Thomas filed suit in federal district court claiming the hiring practices were discriminatory. Thomas sought an injunction requiring the board to eliminate its practices of hiring through nepotism and word of mouth. Thomas provided evidence from other Black teachers who testified they were similarly unaware of available teaching positions due to the board’s hiring practices. The district court did not grant Thomas’s request for an injunction to require the board to change its discriminatory hiring practices. Thomas appealed to the United States Court of Appeals for the Fourth Circuit.

Rule of Law

Issue

Holding and Reasoning (Butzner, J.)

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