Case Briefing
1. Issue: What brought about the suit.
2. Facts: Explain the essential facts of the case. Tell the story of the case.
3. Decision in administrative hearings and the lower courts: State the decision in administrative hearings and in the lower court(s).
4. Rationale: This is a very important part of the case brief. You must explain the gist of the court ruling (i.e., why the court arrived at its holding).
5 Holding/Rationale: The ruling of the court.
6. Scope of the holding: Identify the jurisdiction of the court and the population addressed by the court.
7. Implications and Unresolved issues and further questions: Identify and discuss issues and questions regarding this case.
Mitchell v. Board of Trustees of Pickens County School District 599 F.2d 582 (1979)
ISSUE: Can a teacher's contract not be renewed when required to report pregnancy immediately to school board upon its discovery and then use disclosed pregnancy as the sole basis not to renew contract for the succeeding school year? Can the school board justify such policy on the ground of "business policy?"
FACTS: Teacher was certified for school year 1971-72. Full agreement that her work was of the highest quality was substantiated. In February, 1972, she signed a contract for the 1972-73 school year.
In April, she discovered she was pregnant and anticipated needing six weeks leave. Plan was disapproved by the superintendent and the board and her contract was not renewed on the basis of "unwritten policy" against renewing the contract of any teacher who could not commit a full year's service.
Teacher brought suit against school officials under the Civil Rights Act of 1871, 42 U.S.C. § 1871, alleging violation of her federal constitutional rights. The school district moved for summary judgment and dismissal, which was granted. The teacher appealed to the Circuit Court of Appeals and filed a second action under Title VII.
HOLDING: Court of Appeals reversed the district court's decision and remanded the matter back to the district court for consideration consistent with the Circuit's decision.
RATIONALE: A "prima facie" violation of Title VII of the Civil Rights Act of 1964 occurred by reason of the school board's policy.
IMPLICATIONS: Discriminatory treatment by school officials of a protected class of citizens, in this case a pregnant female employee, is expressly prohibited by Title VII of the Civil Rights Act.
The U.S. Constitution and acts of congress, when such acts are within the authority of congress, are supreme law, and any state or local policy or practice to the contrary, whether written or unwritten, will be struck down. School officials are responsible for being both knowledgeable and in compliance with federal policy. There is no defense for not knowing the law and corresponding regulations.
Attachment:- Doev-Withers.rar