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Williams v. Board of Education of the City of Chicago

January 21, 2009

KATHLEEN WILLIAMS, PLAINTIFF,
v.
BOARD OF EDUCATION OF THE CITY OF CHICAGO AND CHRISTINE MUNNS, INDIVIDUALLY AND AS AN AGENT OF THE DEFENDANT BOARD, DEFENDANTS.



The opinion of the court was delivered by: Judge George W. Lindberg

MEMORANDUM OPINION AND ORDER

Plaintiff Kathleen Williams' complaint alleges claims of pregnancy discrimination, retaliation, violations of equal protection and the Family and Medical Leave Act ("FMLA"), and a state law claim of tortious interference with a contract. Before the Court is defendants' motion for summary judgment. For the reasons stated below, the motion is granted in part and denied in part.

I. Motions to Strike

As an initial matter, the Court examines the parties' motions to strike. Defendants have moved to strike portions of plaintiff's statement of additional facts, on the basis that these facts are argumentative, immaterial, and overly long. The Court agrees that many of plaintiff's facts are not "short numbered paragraphs," as required by Local Rule 56.1(b)(3)(C); indeed, a number of plaintiff's paragraphs extend over a page in length. However, the Court does not rely on any of the excessively lengthy facts in ruling on defendants' motion for summary judgment, and therefore defendants' motion to strike these facts is denied as moot.

Defendants also move to strike plaintiff's amended affidavit, on the basis that it attempts to contradict matters about which plaintiff testified in her deposition. However, defendants do not identify the portions of plaintiff's 63-paragraph affidavit or her deposition to which they refer. Accordingly, defendants' motion to strike plaintiff's affidavit is denied.

Plaintiff has moved to strike portions of defendants' statement of facts, citing certain evidentiary objections. With the exception of paragraph 43, the Court did not rely on any of the paragraphs plaintiff moves to strike. The Court overrules plaintiff's objections to paragraph 43. Plaintiff's motion to strike is denied.

II. Factual Background

Unless otherwise noted, the following facts are undisputed. Plaintiff was hired as a probationary appointed teacher at Sauganash Elementary School ("Sauganash") in Chicago for the 2004-2005 school year. Sauganash is part of the Chicago Public School system, and is administered by defendant Board of Education ("Board"). Defendant Munns is Sauganash's principal.

According to plaintiff, on February 23, 2006, she advised Munns that she was pregnant. According to defendants, plaintiff advised Munns of the pregnancy on March 20, 2006.

On March 17, 2006, Munns entered a decision into the Board's central database that plaintiff's employment was not going to be renewed for the 2006-2007 school year. On the non-renewal form, Munns identified "DEFICIENCIES WITH COMMUNICATION (PARENT CONFERENCE SKILLS; RELATIONS WITH STAFF)" as the reason for plaintiff's non-renewal. The Board approved this decision on April 26, 2006. Pursuant to the Board's directive that the non-renewal status of probationary teachers be kept confidential, Munns did not inform plaintiff of the decision until April 28, 2006. According to defendants, they made their decision not to renew plaintiff's employment in early January 2006.

On May 16, 2006, plaintiff was placed on bed rest for the remainder of her pregnancy. She requested and received a medical leave from her employment.

III. Analysis

Summary judgment shall be granted "if the pleadings, the discovery and disclosure materials on file, and any affidavits show that there is no genuine issue as to any material fact and that the movant is entitled to judgment as a matter of law." Fed. R. Civ. P. 56(c). The Court must draw all reasonable inferences in favor of the nonmoving party. Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133, 150 (2000). The moving party bears the initial burden of demonstrating that no material issue exists for trial. Celotex Corp. v. Catrett, 477 U.S. 317, 323 (1986). Once the moving party has properly supported its motion, the nonmoving party must offer specific facts ...


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