HR-87-023-JL

                                                       8 -17 00-1 4 2 5 -2

                                                       DHR File Nos.  E12500,

                                                       E12501, E12503 and E12544

 

                               STATE OF MINNESOTA

                        OFFICE OF ADMINISTRATIVE HEARINGS

 

                  FOR THE MINNESOTA DEPARTMENT OF HUMAN RIGHTS

 

 

State of Minnesota, by

Stephen W. Cooper, Commissioner,

Department of  Human  Rights,

 

                               Complainant,

                                                       FINDINGS OF FACT,

V.                                                     CONCLUSIONS AND

                                                           ORDER

Independent School District No. 701,

 

                               Respondent.

 

 

    The above-captioned matter came on for hearing before Administrative Law

Judge Jon L. Lunde on November 15 - 17, 1988 and January 9 - 12, 1989 at the

Courthouse in Hibbing, Minnesota pursuant to a Complaint and a Notice of and

Order for Hearing dated March 17, 1981.

 

    Carl M.  Warren,  Special  Assistant Attorney General, 1100 Bremer lower,

Seventh Place  and  Minnesota  Street, St. Paul, Minnesota 55101, appeared on

behalf of the Complainant.    Paul F. Wojciak, Attorney at Law, Hibbing Business

Center, Suite 201,  522  East  Howard Street, Hibbing, Minnesota 55746, appeared

on behalf of  the  Respondent  (District).  The record closed on June 16, 1989,

when the  Administrative  Law  Judge received notice that the Complainant would

not be submitting a reply brief.

 

                                     NOTICE

 

    Pursuant to Minn.  Stat.  363.071, subd. 2, this Order is the final

decision in this case and under Minn.  Stat.  363.072, the Commissioner of the

Department of Human Rights or any other person aggrieved by this decision may

seek judicial review pursuant to Minn.  Stat.  14.63 through 14.69.

 

                              STATEMENT OF ISSUES

 

    The issues in this case are as follows:

 

    (1)  Did the Respondent refuse to hire four women who applied for teaching

         positions for the 1984-1985 school year because of their age in

         violation of Minn.  Stat.  363.03, subd. 1(2)(a) (1984)?

 

    (2)  If the Respondent engaged in illegal discrimination on the basis of

         age in refusing to hire any of the Charging Parties, what damages and

         other relief should be ordered to correct its actions?

 


    Based upon all of the proceedings herein, the Administrative  Law  Judge

makes the following:

 

                               FINDINGS OF FACT

 

    1.   Joy Ann Smith, Illona K. Jaksha, Susan L. Havercamp and  Laura  Ann

Lignell (Charging Parties) filed charges of age discrimination  against  the

Respondent following the Respondent's failure to hire them to fill four

Chapter I teaching positions for the 1984-85 school year.  Three of the

charges were filed on November 14, 1984; one charge (Havercamp's) was filed  on

December 2, 1984.

 

    2.   The Chapter I program -- previously the Title I  program  (hereinafter

Chapter 1) -- is a federally funded program designed to supplement the  regular

classroom instruction of elementary students whose math and reading skills  are

below the students' grade level.  For over 20 years, and at all  times  material

to this proceeding, the District participated in the Chapter I  program.  Under

its program, the District provided remedial instruction in math and reading  to

each eligible student 20 to 30 minutes daily.  The District's program was

essentially a "pullout" system:  students needing special help left their

regular classrooms to meet with the Chapter I  "tutors."  Historically,  the

Chapter I program has been funded on an annual basis.  The  District  usually

received notice of the availability of federal funds late in August each

year.  Prior to the 1983-84 school year, the Respondent  used  paraprofessionals

to teach remedial math and reading to elementary students under the  Chapter  I

program.  These paraprofessionals were not required to be licensed  teachers  --

although almost all of them were -- and they were generally hired on a

year-to-year basis from the District's substitute teacher list.  During  the

4-year period prior to the 1983-84 school year, the Respondent  employed  eight

such paraprofessionals.  These paraprofessionals did not have tenure as

teachers and earned no seniority rights.  Instead, they were appointed  under  a

"letter of assignment" having a one-year term.  However, once  employed,  the

paraprofessionals were routinely reemployed.  They were not interviewed each

year.  Instead, they simply notified the District by letter  that  they  desired

reemployment.  They all expected reemployment if federal funds were

available.  Smith, Jaksha, and Lignell were all employed as Chapter I

paraprofessionals by the Respondent prior to the 1983-84 school year.

 

   3.   Joy Ann Smith, born June 15, 1933, is a licensed  elementary  school

teacher who resides in Hibbing, Minnesota.  Smith graduated from  Bemidji  State

University with a Bachelor of Science degree in education in the spring of

1955.  At that time she received a Minnesota teaching license having a

kindergarten endorsement.  During the three school years  following  graduation,

Smith was employed as a first grade teacher for the District.  The  next  two

years she was unemployed.  During the 1960-61 school year Smith  returned  to

work as a substitute elementary teacher in Grand Rapids,  Minnesota.  During

the next 19 years, Smith was not employed and her teaching license  expired.

 

   4.   In 1980, Smith obtained a provisional teaching license which

authorized her to work as a substitute teacher, and during the 1980-81 school

year she worked as a substitute elementary teacher for the Respondent on a

weekly basis.  Thereafter, Smith was employed by the Respondent as  a  full-time

paraprofessional in the Chapter I program.  She was initially hired  for  the

1981-82 school year by Laverne Walters.  Walters was an elementary school

 

 

                                    -2-

 


principal and the Respondent's Chapter I director/administrator.  During  the

1981-82 school year Smith worked at the Jefferson Elementary School  and  was

supervised by John Drazenovich, the school's principal.  During  the  1982-83

school year, Smith worked for the District in a local parochial school  and  was

supervised by Walters.  Smith never received any formal performance

evaluations as a Chapter I paraprofessional; however, the principals  of  the

schools where she worked thought very highly of her job performance  and  wrote

letters of recommendation on her behalf.  Both letters have been in her

personnel file since 1983 or before.

 

    5.   Smith's license to teach elementary education (grades 1-6) and

kindergarten was renewed in July 1984 after she completed two  human  relations

courses.  In addition to those courses, Smith attended  weekend  "workshops"

offered by the District while she was a substitute  teacher.  Thereafter,  when

Smith became a Chapter I paraprofessional, she attended four inservice

training sessions and one 2-day workshop each year.

 

    6.   Illona K. Jaksha was born on May 17, 1930.  She graduated from

Wisconsin State College at Eau Claire in June 1951 with a Bachelor  of  Science

degree in elementary education.  Upon graduation she obtained a Wisconsin

teaching license having a kindergarten endorsement.  Between 1951  and  1959

Jaksha was employed as an elementary teacher in Barron and Wauwatosa,

Wisconsin.  Thereafter, she moved to Minnesota.  From  1959  through  1963  she

was employed as an elementary teacher in Robbinsdale, Minnesota, and for the

1963-64 school year she was employed as a second grade teacher in  Hibbing.

She worked until December, 1963 when she resigned because she  was  pregnant.

 

    7.   Jaksha returned to work as a substitute teacher for the Hibbing

school district for the 1978-79 and 1979-80 school years.  During  this  time

she worked as a substitute elementary teacher at all of the District's

elementary schools.  In October 1980, Walters asked Jaksha to teach  in  the

Title I program.  Jaksha was employed in the Chapter I program for the

remainder of the 1980-81 school year and the following two school years

(1981-83).  During the 1980-81 school year Jaksha was assigned to the

Jefferson Elementary School and was supervised by Drazenovich and the  lead

teacher in the Chapter I program, Carol Cicmil.  During the  next  two  years,

Jaksha worked at the Cobb Cook Elementary School and was supervised  by  Walters

and Cicmil.  Although Jaksha did not receive any formal written job

evaluations while employed as a Chapter I paraprofessional,  Drazenovich  and

Cicmil were pleased with her performance and told her that she was doing  a

good job.

 

    B.   Between 1980 and 1981 Jaksha took an extension course relating  to

exceptional children.  In addition, between 1980 and 1983 she  attended  two

2-day Chapter I workshops.  Prior to the 1984-85  school  year  paraprofessionals

in the Chapter I program had four days of inservice training and at  least  one

2-day workshop each year.  The inservice training was given by Cicmil.

 

    9.   Laura Ann Lignell was born November 4, 1948.  In  June  1971  Lignell

graduated from St. Cloud State College with a Bachelor of Arts degree in

elementary education.  While in college she concentrated in mathematics.

Later, during the 1981-82 school year Lignell earned 15 credits in  special

education from the University of Minnesota at Duluth, taking courses in

reading, math and assessing children with special needs.  In  1975  Lignell  took

a 3-credit course at Bemidji State University pertaining the diagnosis  and

 

 

                                     -3-

 


correction of reading difficulties.  In 1983 Lignell also took a course on the

operation of computers and she attended several workshops pertaining to

Chapter I teaching methods.

 

    10.  Upon graduation from St. Cloud State College in 1971, Lignell was

licensed to teach in elementary school, grades I through 6.  During the

1971-72 school year and the subsequent two school years Lignell taught first

grade in Moose Lake, Minnesota.  At the end of the 1973-74 school year Lignell

moved to Hibbing and she worked as a Chapter I paraprofessional for the

Respondent on a part-time basis during the 1974-75 school year (from November

through June).  During the 1976-77 school year, Lignell worked as a substitute

elementary school teacher for the Respondent and, from February through June

of 1977, she worked as Chapter I teacher for the Respondent at the Greenhaven

Elementary School.  During the 1977-78 school year, Lignell again worked as a

substitute elementary teacher for the District.  After taking a year off work

(1978-79), Lignell returned to her employment as a Chapter I paraprofessional

for the District.  She worked in that program for four school years -- from

the fall of 1979 through June 1983.  During that 4-year period Lignell worked

at three elementary schools operated by the District and was supervised by

three different principals:  Drazenovich, Walters and Dan Molesky.

 

   11.  Throughout the course of her employment as a Chapter I

paraprofessional Lignell did not receive any formal written job evaluations.

However, she did receive positive verbal praise from elementary school

principals.  Drazenovich told her that she had good rapport with students and

was doing a good job at the Greenhaven School, and Drazenovich actually

requested that Lignell help a classroom teacher establish control in a

classroom.  Walters and Molesky also made postive remarks concerning her job

performance.  In fact, both of them wrote letters of recommendation commending

her performance.  Walters wrote a letter on her behalf in 1981 and Molesky

wrote a letter in May 1982.  In those letters they commented on Lignell's

cheerful personality and good relations with students and classroom teachers.

 

   12.  Susan Lucy Havercamp, a Hibbing resident, was born on September 8,

1940.  On July 17, 1962 she graduated from Bemidji State College with a

Bachelor of Science degree in elementary education.  At that time she received

a Minnesota teaching certificate with a kindergarten endorsement.  During the

two school years following graduation Havercamp taught kindergarten classes in

Duluth.  For the next 14 years, Havercamp did not work and her Minnesota

teaching license expired.

 

   13.  In 1977 Havercamp and her recently retired husband moved to Hibbing.

At that time Havercamp took the steps necessary to be relicensed as an

elementary teacher:  she took two human relations courses required of all

teachers, took one course on learning and motivation, and spent 20 hours

observing kindergarten and first grade classes as the District's Jefferson

Elementary School.  In addition, after she was relicensed, she took a course

on audio-visual materials.

 

   14.  Havercamp's teaching license was renewed effective July 1978.  Under

her license she is authorized to teach kindergarten through sixth grade.

Beginning with the 1979-80 school year Havercamp worked as a casual substitute

teacher for the District.  She taught kindergarten through sixth grade,

including classes in the early childhood and special education program.

Havercamp continued working as a substitute teacher for the District through

 

 

                                    -4-

 


the 1986-87 school year when she found part-time employment as a  kindergarten

teacher in a parochial school.  She last worked for the District on October 1,

1986.

 

    15.  Havercamp never received any negative comments or criticisms

regarding her work for the District.  On the contrary, all the feedback she

received was positive.  Teachers and principals alike told her she  was  doing

an excellent job.

 

    16.  During the 1982-83 school year the District employed 8

paraprofessionals to teach in its Chapter I program.  In addition  to  Lignell,

Smith and Jaksha, the District employed Cherye Carlstrom, Marcia  Draskovich,

Timothy Johnson, Orpha Prince, and Linda Sibell.  All except Prince were

certified elementary school teachers.

 

    17.  During the 1982-83 school year, the Hibbing Federation of Teachers

(HFT)1 filed a petition with the Bureau of Mediation Services to designate  a

separate bargaining unit for the Chapter I paraprofessionals employed by  the

District.  The Hibbing Education Association (HEA) appeared to oppose the

separate certification contending that the paraprofessional should be included

within the teacher bargaining unit it represented.  The paraprofessionals

adopted HEA's position.  Following several hearings, the Director of the

Bureau of Mediation Services (BMS) issued a unit determination establishing  a

separate bargaining unit for the paraprofessionals.  HEA appealed the unit

determination to the Public Employment Relations Board (PERB).  On  September

15, 1983, PERB affirmed the BMS determination.  HEA subsequently appealed that

determination to the Minnesota Court of Appeals.2

 

In a decision issued on April 4, 1984, the Court of Appeals reversed the  unit

determination made by the Public Employment Relations Board and PERB

appealed.  The Minnesota Supreme Court reversed the Court of Appeals in a

decision issued on June 21, 1985.3

 

 

 

 

 

 

 

 

IIt is not cl ear if the HFT was an associate on of the pa rap rof essiona Is only

or if it also represented other District employees.

 

2See, Hibbinq Education Association v. Public Employment Relations Board,

342 N.W.2d 355 (Minn.App. 1984) and Hibbing Education Association v. Public

Employment_Relations Board, 346 N.W.2d 389 (Minn.App. 1984).

 

3Hibbinq Education Association v. Public Emplovment Relations Board, 369

N.W.2d 527 (Minn. 1985).

 

 

 

 

 

 

 

                                    -5-

 


    18.  After the petition for unit determination was filed, District

officials, including the superintendent, Edward Eggers, were concerned about

the effects a decision including the Chapter I paraprofessionals in the

teachers bargaining unit would have upon the District's budget.      At that  time,

teacher salaries were two to three times higher than the salaries paid to

paraprofessionals.    Therefore, if the District was ordered to provide

paraprofessionals with the same salary and other benefits available to

teachers, the District's budget would be adversely affected and it would be

required to reduce the number of paraprofessionals due to the limited amount

of Chapter I funds.    In addition, Eggers was concerned that if the

paraprofessionals were added to the teacher's bargaining unit, they would

acquire tenure and seniority rights which were previously unavailable to

them.   If they obtained seniority, their salaries would be increased further,

and they could "bump" regular classroom teachers; if they acquired tenure,

they would also have a right to continued employment regardless of the

availability of Chapter I funds.  Because  of  the  uncertainties  surrounding  the

outcome of the BMS proceedings, the District decided not  to  resume  the  Chapter

I program at the start of the 1983-84 school year.

 

    19.  Although none of the paraprofessionals employed during the 1982-83

school year received notice that they would be rehired for the 1983-84 school

year, their union representative advised them to report to work.

Consequently, they went to Walters' office as a group during  the  first  week  of

September 1983.   Walters told them that there was no work at that time and

they left.   Although the Chapter I program did not  commence  in  September,  most

of the paraprofessionals were hopeful that it would  be  resumed  sometime  during

the school year.

 

   20.    The status of the Chapter I program and the unit determination

petition were a big news item in Hibbing and the paraprofessionals (known by

then as the "Hibbing 8") were vocal participants in public discussions

regarding those matters.

 

   21.  Parents, teachers, school officials, and school board members were

all in favor of resuming the Chapter I program as soon as possible, and

ongoing negotiations between the Respondent and HEA occurred.     In December

1983, Eggers advised the Hibbing school board (Board)  that  the  District  should

call a moratorium on the Chapter I program for the 1983-84 school year or

reinstate it using four Chapter I paraprofessionals and some aides.     At that

time HEA was advocating the use of licensed teachers in the Chapter I

program.   Eggers was concerned about that proposal because of its cost.     In

addition, if teachers were to be employed, Eggers told the Board that the

District should advertise for the best-qualified people to get the "most

up-to-date trained teachers" available, referring specifically to computer

training.   However, he noted that December is not the best time to look for

teachers.  (Ex. 35).

 

   22.  Although PERB had determined that the paraprofessionals were not

"teachers" on September 15, 1983, an appeal had been taken to the Minnesota

Court of Appeals.  Due to Eggers' concerns about the financial effects of a

court decision reaching a contrary conclusion, a decision was  made  not  to  have

a Chapter I program for the 1983-84 school year.    On April 4, 1984 the

Minnesota Court of Appeals reversed PERB's decision and remanded the matter

back to PERB for a determination of the paraprofessionals' appropriate

bargaining unit considering the paraprofessionals actual job duties.     The

 

 

                                      -6-

 


District did not appeal that decision and apparently  decided  that  teachers

should be hired for the Chapter I program.

 

    23.   At a school board (Board) meeting on May 23, 1984, the Board adopted

a resolution authorizing the District's participation in the Chapter I program

for the 1984-85 school year and approved an application for Chapter I funds.

(Ex. 42).  In addition, the District's administration proceeded with ongoing

negotiations with the HEA concerning the seniority, tenure, and salary that

would be paid to the Chapter I teachers hired for the  1984-85  school  year.

 

    24.  After the Board decided to resume the Chapter I program for the

1984-85 school year, Eggers went ahead with his decision to consider persons

other than former paraprofessionals for those positions even  though  he  was

satisfied with the paraprofessionals' prior job performance.  Eggers announced

that since the individuals hired were required to be teachers and could end up

teaching in a regular classroom, the positions should be filled like all other

teaching positions.  That is, by statewide recruitment.  Consequently, notice

of the new Chapter I teaching positions was published and the vacancies were

listed in several placement offices.

 

    25.  In July and August 1984, Robert Parker, the director of elementary

education, interviewed approximately 28 teachers who had submitted employment

applications.  Most of them had applied for a Chapter I position but some of

them had not.  Two of the eight paraprofessionals in  the  Chapter  I  program

during the 1982-83 school year did not apply for the new Chapter I teaching

positions: Marcia Draskovich and Timothy  Johnson.  Orpha  Prince,  a  former

Paraprofessional, applied for a position but she was ineligible because she

was not a licensed teacher.  The other five previously employed

paraprofessionals all applied and were interviewed by Parker.  Parker notified

each person who applied to telephone him for an interview, and except for the

former paraprofessionals, advised most of the applicants by  letter  to  have

their colleges send him copies of their credentials.  (Ex. 38).  Notice of the

Chapter I elementary teaching positions was posted at the District's schools

on or about June 27, 1984.  (Ex. 37).

 

    26. At the time of their interviews, Carlstrom was  27,  Sibell  was  34,

Lignell was 35, Smith was 51, Jaksha was 54 and Havercamp was 43.    Most of the

applicants for the Chapter I positions were in their twenties (15)  or thirties

(9); two were in their forties and two were in their fifties.

 

    27.  Parker interviewed most of the 28 applicants between July  17 and

August 13, 1984.  (Dist.  Ex.  A).  His interviews with Linda Sibell  and   the

Charging Parties were informal and lasted 20 minutes or less.  They were given

a chance to review the new Chapter I job description, ask questions about the

position, and ask any other questions or make any other  comments  they  felt

were appropriate.   None of them were asked to supplement their applications or

submit recommendations from persons they had listed as references.  During the

interviews Parker had a note pad, but he took few notes, and he did not have

their personnel files available or use any forms or checklists.

 

    28.  Eggers decided that the process previously followed in hiring

elementary teachers should be altered in hiring the Chapter  I  teachers.  In

the past, Eggers had always relied on Parker's recommendations in filling

elementary teaching positions and Chapter I positions because Parker was the

director of elementary education.  Although he had always been satisfied with

 

 

                                      -7-

 


Parker's selections, Eggers concluded, sometime after the Chapter I interviews

were completed, that the process should be "formalized" by scoring the

applicants on the basis of 16 criteria and selecting the four persons with the

highest scores.  He felt that formalization was needed to  select  the  best

qualified persons -- especially because there were fewer vacancies than former

paraprofessionals.

 

    29.  Eggers gave Parker the evaluation forms and asked Parker to complete

one for each of the applicants he had previously interviewed.  The evaluation

form lists 16 criteria and contains a matrix on which each of  those  criteria

can be scored from one to five.  However, a numerical score  was  not  required

for each criterion.  Any criterion could be scored as "inapplicable" or

"N/A".   The 16 criteria are as follows:

 

    1.   Academic preparation (basic & current)

    2.   Scholarship (GPA)

    3.   Educational Experience (recommendations)

    4.   Extra-curricular strengths

    5.   Special interests

    6.   Oral & written skills

    7.   Instructional competencies (methods, planning, knowledge of

         materials)

    8.   Community involvement

    9.   Poise, culture, speech

    10.  Personality

    11,  Personal appearance

    12.   Cooperation & professional spirit

    13.  Sympathetic understanding of children

    14.  Ability to instruct & control

    15.  Ability to accept supervision

    16.  Professional growth.

 

    30.  After Parker received the evaluation forms from Eggers, he rated each

of the applicants by placing a check mark in one of the six boxes for each  of

the 16 criteria.  His determinations were based on his interviews, the notes

he took, his memory, the applications and credentials submitted, and  other

information in the school's personnel file, as well as his own knowledge about

the applicants.  After Parker completed the evaluation forms,  he  submitted

them to Eggers.  Eggers calculated a composite score for each  applicant  using

weightings he had devised for each criterion and an adjustment factor.

Parker's score for each criterion was multiplied by the weight assigned  to

it.  The weighted scores of each applicant were totaled and the sum was

divided by the number of criteria that were given a score.  The totals were

then multiplied by an adjustment factor to get the final scores (weighted

average scores).  The adjustment factor was based on the  applicant's  teaching

experience.  If the applicant had no prior teaching experience, the

applicant's score was multiplied by a factor of .9. If the teacher  had  prior

experience, but not experience in the Chapter I area, the applicant's score

was not adjusted.  If the applicant had prior Chapter I experience, the

applicant's score was multiplied by a factor of 1.1. Based upon  the  final

scores computed by Eggers, a priority sheet was established.

 

 

 

 

 

 

                                     -8-

 


     31.  Based on Parker's evaluations, the applicants' scores were as

   follows:

 

          NAME               AVERAGE SCORE         AGE

 

          Meisner, W.        4.625                 24

          Meisner, J.        4.533                 26

          Koefod             4.333                 22

          Jeseritz           4.266                 32

          Thill              4.066                 23

          Nordlund           4.066                 23

          Zubich             3.875                 22

          Hilton             3.8b6                 23

          Brandstrom         3.857                 34

          Ridge              3.800                 26

          Katonias           3.687                 28

          O'Neil             3.666                 21

          Bordwell           3.666                 22

          Proctor            3.625                 37

          Adam               3.563                 32

          Gustafson          3.400                 37

          Ferguson           3.400                 45

          Walters            3.375                 38

          Smith, Joy         3.375                 51

          Sibell             3.267                 34

          Havercamp          3.187                 43

          Lignell            3.125                 35

          Carlstrom          3.063                 27

          Smith,  A.         3.062                 25

          Jaksha             3.000                 54

          Amic               2.875                 36

          Prince              -0-                  50

 

 

After Eggers weighted the    scores and adjusted them for prior teaching

experience, the available    applicants with the highest scores were:

 

 

                NAME                      SCORE

 

                Pamela  Koefod            5.99

                Brenda Nordlund           5.72

                Diane Hilton              5.69

                Linda Sibell              5.64

                Joy Smith                 5.53

                Lois  Ferguson            5.464

 

 

 

 

 

 

 

 

4Actually, Nordlund's score was 5.54 and Sibell's was 5.68.

 

 

                                         -9 -

 


    32. At a Board meeting on September 5, 1984,  the  Board  approved  changes

in the Master Agreement with HEA.  The changes dealt  with  Chapter  I  teachers.

The contractual language approved by the Board limited the  Chapter  I  teachers'

salaries to step zero of the teacher salary range, recognized  that  they  were

tenured, but limited their seniority to the Chapter I area.  Under the

language changes approved, Chapter I teachers would not be able to bump

regular classroom teachers and would not be paid at  the  same  rate.  However,

they would receive the same fringe  benefits  teachers  received.  After  these

language changes were approved by the Board, Eggers  made  his  recommendations

for the Chapter I teaching positions for the 1984-85 school year.  He

recommended Pamela Koefod, Brenda Nordlund,  Diane  Hilton  and  Linda  Sibell.

These were the available applicants with the highest  scores.  The  Chairman  of

the Board, Vernon Wenberg, was suprised  by  Eggers'  recommendations.  He  had

heard that Laura Lignell would be recommended.  The  Board  meeting  was  recessed

while Board members reviewed the credentials of the  finalists  recommended  by

Eggers.  When the meeting resumed, the Board voted to approve Eggers'

recommendations.  Wenberg was the lone dissenter.  He  stated  he  was  not  sure

the most qualified persons had been selected.

 

    33. The District also hired a kindergarten teacher  for  the  1984-85  school

year.  Eggers recommended Jane Dostal, age 22, for that  position  and  she  was

hired.  Dostal graduated from Bemidji State University  in  May  1984.  Her  major

was elementary education and her minor was early  childhood  education.  She  had

no teaching experience other than that required for her degree (student

teaching).  Havercamp had notified the District of her interest in a

kindergarten position for the 1984-85 school year but was never  advised  that  a

kindergarten vacancy existed or specifically  interviewed  for  a  kindergarten

position

 

    34. Linda Sibell was born on February 8, 1950 and in  the  summer  of  1984

was 34 years old.   Sibell graduated from St. Cloud State College  in  1972  with

a Bachelor of Science degree in elementary education with an English

concentration.  Following graduation Sibell,  like  Lignell,  also  completed  15

credits toward a Master's degree in special education by the  summer  of  1984.

In addition, during the 1982-83 school year she took a computer course.

Commencing with the 1972-73 school year, Sibell worked for  the  Respondent  for

three years as a substitute elementary teacher.  During the 1976-77 and

1978-79 school years Sibell worked as a long-term substitute  teacher  for  the

Respondent.  Thereafter beginning with the 1979-80  school  year  Sibell  worked

for the District as a Chapter I paraprofessional for  four  consecutive  school

years.

 

    35.  Hilton, Nordlund and Koefod were younger and had less teaching

experienced than Sibell or any of the Charging  Parties.  Hilton  was  born  on

May 3, 1961 and was 23 years old in the summer  of  1984.  She  graduated  from

the University of Minnesota Duluth on May 21, 1983 with a  degree  in  elementary

education.  Following graduation she worked two months as a substitute

elementary teacher in California and worked one month as a kindergarten

teacher in a private school.

 

   36. Nordlund was born on February 10, 1961 and  was  23  years  old  in  the

summer of 1984.  She graduated from Concordia  College  in  Moorhead,  Minnesota

in May 1983 with a degree in elementary  education.  Following  graduation  she

worked as a substitute elementary school teacher for seven months and she

worked two months as a teacher in a Chapter I and  a  gifted  student  program.

 

 

                                     -10-

 


At the time of her application she was working as a  playground  supervisor  and

was licensed to teach first through sixth grades.

 

    37. Koefod was born on July 10, 1962 and was 22 years old  in  the  summer

of 1984.  She graduated from Concordia College in Moorhead,  Minnesota  with  a

degree in elementary education in May 1984 and, apart from  her  college  course

work, she had no teaching experience.  (Ex. 9).  At the time of her

application Koefod was licensed to teach kindergarten  through  sixth  grades.

Koefod, like Nordlund, had very good college grades; Koefod's grade point

average was 3.7b, Nordlund's was 3.41.

 

    38.  On Thursday, September 6, 1984 Lignell, Sibell and union

representative Ron Carlstrom met with Parker to discuss the  manner  in  which

the District had decided which candidates to recommend for the Chapter I

teaching positions.  At that time Parker showed them a sample of the

evaluation form he had completed for each candidate following  the  interviews

and told them that each candidate was scored using the criteria on  the  form.

They asked Parker how he obtained the information necessary to rate the

candidates with respect to the 16 criteria when he did not ask  questions  about

those criteria during the interviews.  Parker did not explain how he had

obtained the information necessary to evaluate the candidates for  all  criteria

on the evaluation form.  He told them he "just knew."

 

    39.  On Friday, September 7 the Charging Parties, Sibell and two other

former Chapter I paraprofessionals obtained copies of their completed

evaluation forms from the District's attorney.  The following Monday,

September 10, Lignell and Sibell spoke to Parker again about their

evaluations.  They wanted to find out if the District had any documents

relating to their performance as Chapter I paraprofessionals that  could  have

been used to rank them.  At that time, Parker told them that he  did  not  have

any files regarding them and suggested that Walters might have  some.  The  same

day Lignell and Sibell went to see Walters and asked him if he had  any  files

that reflected their performance as Chapter I  paraprofessionals.  Walters  told

them that he had no such files.  Walters also told them that he and

Drazenovich had developed the evaluation form after  Parker's  interviews.  When

they asked him how they could be scored on criteria that were unknown  when  the

interviews were conducted, he told them that he knew it didn't look  good  but

if the District changed its mind now "we will look  like  incompetent  asses."

 

    40. On September 14 Jaksha's husband spoke to Dr. Peter  Lucia,  a  school

board member, about the Board's hiring decision.  When Jaksha asked  Lucia  why

the Board had hired new people instead of individuals who had  worked  in  the

Chapter I program before, Lucia told him that the administration  wanted  some

"fresh blood" in the system.

 

   41. Sibell and Lignell also talked to school board  member  Stephen  Raukar

about the Board's decision.  They told Raukar that the criteria  on  which  the

candidates were evaluated were developed after the  interviews.  In  addition,

Lignell and Sibell developed a written summary  of  their relative

qualifications and experience and delivered  those  to most of the Board

members.  At the Board meeting held  on  Wednesday,  September 19,  1984,  Director

Raukar asked that the minutes of the September  5,  1984 meeting be  amended  to

change his vote on the motion to appoint the  four  Chapter I teachers

recommended by Eggers from a "yes" to a  "no".  He  did not explain the  reasons

for his decision and Raukar's motion that the Board reconsider its prior

 

 

                                    -11 -

 


approval of Eggers' recommendations was voted down.

 

    42.  The District historically had a policy of considering the age of

teacher applicants, but not Chapter I paraprofessionals, in making its hiring

decisions in order to have an age "flow".    Also, since the District considered

recent teaching experience in determining a newly hired  teacher's  starting

salary, the District attempted to hire teachers with less experience to reduce

its salary costs.   Its salary costs were high because it had a mature,

experienced teaching staff.

 

    43.  In the summer of 1979, Havercamp applied to the District for a

kindergarten position.  Following an interview, Parker noted on her interview

summary that Havercamp "appears to be a strong candidate."   (Dept. ex. 14, p.

15).  Nonetheless, Havercamp was not selected for either of two kindergarten

positions the District filled for the 1979-80 school year.  After she learned

that she was not one of the successful applicants she telephoned one of  the

references she had included on her application form and learned that he  had

not been contacted by the District.  Consequently, she  contacted  Eggers  to

find out why her references had not been checked.  At that time  Eggers  told

her: "[M]aybe Mr. Parker was looking for fresh  graduates."  When  Havercamp

asked why she hadn't been told that before she went to the trouble of

applying, Eggers told her that it was always possible that no fresh graduates

were available.  When Havercamp told Eggers that she did not  think  she  was

treated fairly, Eggers promised to ask Parker what criteria had been used and

get back in touch with her.  A few days later, when Havercamp  called  Eggers

about the matter, Eggers told her that Parker had been looking for recent

graduates to fill the kindergarten positions and that the District was looking

for an age "flow" in the school system.   Havercamp still believed  that  her

references should have been checked and after talking to her husband they

decided to speak to Parker about the matter because Parker's comments during

her interview led Havercamp to believe his refusal to hire her might have

something to do with her husband.   Parker denied that his hiring decision had

anything to do with her age or her husband.   Since her references had not been

checked, Havercamp felt the District did not have the best interests of  its

students in mind.  Consequently, after speaking with Parker, Havercamp and her

husband met with Eggers and discussed the matter further.  During the meeting,

Eggers told Havercamp and her husband that Parker uses three criteria in

selecting teachers:  cost, age and qualifications.  Eggers said that the

District tries to balance the age of its staff and if a candidate  qualifies

with respect to age and salary costs (experience), the candidates

qualifications are checked.  Eggers also said that the District likes to get

"young blood" in the school system to add more life to its meetings and other

functions.

 

   44.  Following a Board meeting in the summer of 1984, while discussing the

District's Chapter I program, Vernon Wenberg, a school board member, told

Lignell that the District was concerned with the age of its Chapter I teachers

and that it did not want the children to have a "grandma" figure for a teacher

and needed, instead, a wide range of ages.

 

   45. The duties of the Chapter I paraprofessionals prior  to  the  1983-84

school year were substantially equivalent to the duties of Chapter I teachers

from and after the 1984-85 school year.  Commencing with the  1984-85  school

year, Chapter I teachers have been paid the following salaries in the

following school years:

 

 

                                    -12-

 


                     SCHOOL YEAR            AMOUNT

 

                     1984-85                $14,630

                     1985-86                $15,632

                     1986-87                $16,438

                     1987-88                $16,930

                     1988-89                $16,930

 

    46.  During the 1984-85 school year,    Smith worked as a substitute

elementary teacher (K-6) for the Respondent and a private elementary school

earning $891.

 

    47.  In the spring of 1985 Smith again applied for a Chapter I teaching

position.  After an interview by a panel of seven administrators, Smith was

hired for the vacancy.  She began  working  for  the  District  at  the  commencement

of the 1985-86 school year and has worked  for  them  since  that  time.  Since  she

returned to work Smith has earned at least as much  as  she  would  have  earned  if

she had been hired for the 1984-85 school year  in  the  Chapter  I  program.

 

    48.  The interview process for hiring Chapter I teachers for the 1985-8b

school year was changed after Parker and Eggers retired on January 1, 1985.

The new superintendent implemented  a  scientifically  tested  interview  and

evaluation procedure developed by the University of Nebraska.  The evaluation

forms previously used by Eggers were never used again.

 

    49.  During the 1984-85 school year, Lignell worked as a substitute

teacher for the Respondent in another public school district earning

$4,292.50.  Commencing with the 1985-86 school year, Lignell obtained

full-time employment as a special education teacher for a special education

cooperative.  Since that time, she has earned more than she would have earned

as a Chapter I teacher for the District.

 

    50. During the 1984-85 school  year,  Jaksha  worked  as  a  substitute  teacher

for the District and earned $1,738.  Jaksha applied to the District for a

Chapter I teaching position in the spring of 1985; however, the position was

given to Smith.  Thereafter, Jaksha stopped  looking  for  work  and  let  her

teaching license expire.

 

    51.  During the 1984-85 school year, Havercamp worked for the District as

a substitute elementary school teacher earning $2,762.  She was an

unsuccessful applicant for a full-time position  for  the  District  for  the

1985-86 school year.  Consequently, she  continued  to  work  as  a  substitute  that

year.  During the 1986-87 and 1987-88 school years, Havercamp worked as a

part-time kindergarten teacher at a private school earning $4,895 (1986-87)

and $6,935 (1987-88) respectively.  Commencing with the 1988-89 school year,

Havercamp became a full-time kindergarten teacher at a private school.  Her

salary for the year was $5,624.

 

    52.  All the Charging Parties were emotionally traumatized by the

District's failure to hire them as Chapter I teachers for the 1984-85 school

year.  Ms. Smith was temporarily depressed.  She had feelings of

worthlessness, lost most of her interests, and "tuned everyone out."  Her

rejection became a focus of  most  family  discussions.  Jaksha  had  similar

feelings of worthlessness.  She was embarrassed about her rejection and felt

 

 

                                      -13-

 


like her self-esteem had been completely wiped out.  Following her

unsuccessful attempt for a Chapter I  teaching  position  for  the  1985-86  school

year, Jaksha was devastated.  She did  not  believe  the  District  would  hire  her

and felt like no one would give her  a  recommendation  for  other  work.  She  did

not seek other work and she permitted her teaching license to expire.

Havercamp felt like there was something wrong with her and had feelings of

diminished self-worth.  Lignell felt like someone had died.  None of the

Charging Parties sought medical attention for their depression, but their

rejection adversely affected their family life and their self-esteem.

 

    Based on the foregoing Findings of Fact, and  for  the  reasons  set  forth  in

the attached Memorandum, the Administrative Law Judge makes the following:

 

                                    CONCLUSIONS

 

    1.   The Administrative Law Judge has jurisdiction herein and authority to

take the action ordered pursuant to Minn.  Stat.    3b3.071  and  14.50  (1988).

 

    2.   The notice of hearing was proper and all relevant substantive and

procedural requirements of law and rule have been fulfilled.

 

    3.   That the Respondent is an employer for purposes of Minn.  Stat.

  363.01, subd. 15 (1984).

 

    4.   That the Respondent refused to  hire  the  Charging  Parties  for  Chapter

I teaching vacancies in the 1984-85 school year because of their age in

violation of Minn.  Stat.  363.03, subd. 1(2)(a) (1984).

 

    5.   The Charging Parties experienced mental anguish and suffering as a

result of the Respondent's discriminatory conduct, and under Minn.  Stat.

 363.071, subd. 2 (1984), they are entitled  to  compensation  for  that  mental

anguish and suffering in the following amounts:

 

         Smith            $3,000.00

         Lignell          $3,000.00

         Havercamp        $5,000.00

         Jaksha          $10,000.00

 

    6.   Minn.  Stat. sec.  363.071, subd. 2 requires an award  of  a  civil  penalty

to the State when an employer violates the provisions of the Human Rights

Act.  Taking into account the seriousness and extent of the violation, the

public harm occasioned by it, the financial  resources  of  the  Respondent,  and

whether the violation was intentional, the Respondent should pay a civil

penalty to the State in the amount of $10,000.00.

 

    7.   Under Minn.  Stat.  363.071, subd. 2 and  the  standards  in  Minn.  Stat.

 549.20, punitive damages may be awarded where there is clear and convincing

evidence of the acts of the employer's agents  show  a  willful  indifference  to

the rights of others.  Each of the  Charging  Parties  except  Jaksha  are  entitled

to an award of punitive damages in the amount  of  $2,000.00;  Jaksha  is  entitled

to $3,000.00.

 

    8.   Minn.  Stat.  363.071, subd. 2 permits an award of back pay to

compensate victims of discrimination for the compensation they would have

earned had they been hired.  In this case  the  Charging  Parties  are  entitled  to

 

 

                                      -14

 


compensatory damages in the following amounts:

 

         Smith              $13,739.00

         Lignell            $10,337.00

         Jaksha             $28,524.00

         Havercamp          $53,948.00

 

    9.   Minn.  Stat. sec. 3b3.071 authorizes an award of compensatory damages up

to three  times the amount of the compensatory damage actually incurred but in

this case, compensatory damages should be limited to those actually sustained

and should not include interest.

 

 

    10.  The Respondent has failed to establish a bona fide occupational

qualification for refusing to hire the Charging Parties because of their age.

 

    11.  The Respondent should be ordered to cease and desist from considering

the age of job applicants and rejecting those that are older.

 

    12.  The Complainant's prima facie case of discrimination was established

by a preponderance of the evidence.

 

    13.  The Respondent articulated a legitimate, nondiscriminatory reason for

rejecting the Charging Parties' applications for employment.

 

    14.  The Complainant established by a preponderance of the evidence that

the employer's articulated reasons for rejecting the Charging Parties was a

pretext and that it is not worthy of belief.

 

    15.  The Respondent failed to meet its burden of showing that any of the

Charging Parties but Jaksha failed to mitigate their damages.

 

    16.  The Respondent should not be ordered to hire an unlicensed person in

a teaching position.

 

    Based upon the foregoing Conclusions, the Administrative Law Judge makes

the following:

 

                                      ORDER

 

    IT IS HEREBY ORDERED:

 

    (1)  The Respondent shall cease and desist from considering the age of job

         applicants for teaching positions and rejecting older applicants

         because they are older.

 

    (2)  The Respondent shall pay a civil penalty of $10,000.00 to the general

         fund of the State of Minnesota.  The payment shall be delivered to

         the Chief Administrative Law Judge for submission to the general

         fund .

 

    (3)  The Respondent shall pay Joy Smith $18,739.00, being $3,000.00 for

         mental anguish and suffering; $2,000.00 for punitive damages; and

         $13,739.00 for compensatory damages.

 

 

 

                                      -1 5 -

 


      (4)  The Respondent shall pay Laura Lignell $15,337.00 being $3,000.00 for

          mental anguish and suffering; $2,000.00 for punitive damages; and

          $10,337.00 for compensatory damages.

 

      (5)  The Respondent shall pay Susan Havercamp $60,948.00, being $5,000.00

          for mental anguish and suffering; $2,000.00 for punitive damages; and

          $53,948.00 for compensatory damages.

 

      (6)  The Respondent shall pay Ilona Jaksha $41,524.00, being $10,000.00

          for mental anguish and suffering; $3,000.00 for punitive damages; and

          $28,524.00 for compensatory damages.

 

      (7)  All payments ordered shall be made with thirty (30) calendar days of

          the date of this Order.

 

 

Dated  this           day of August, 1989.

 

 

 

 

                                        JON L. LUNDE

                                        Administrative Law Judge

 

 

                                     NOTICE

 

    Pursuant to Minn.  Stat. sec. 363.071, subd. 2, this Order is the final

decision in this case and under Minn.  Stat.  363.072, the Commissioner of the

Department of Human Rights or any other person aggrieved by this decision may

seek judicial review pursuant to Minn.  Stat.  14.63 through 14.69.

 

 

Reported:  Tape Recorded, Transcript Prepared.

 

 

                                   MEMORANDUM

 

    The Complaint in this matter charges the Respondent with a violation of

Minn.  Stat.  363.03, subd. 1(2)(a) (1984).  In pertinent part, the statute

states that except when based on a bona fide occupational qualification it is

an unfair employment practice:

 

          For an employer, because of       age

 

          (a)  to refuse to hire or to maintain a system of

          employment which unreasonably excludes a person seeking

          employment * * *

 

For purposes of the statute, the word "age" protects all individuals over the

age of majority when unfair employment or educational practices are involved.

Minn.  Stat.  363.01, subd. 28 (1984).

 

    As noted by the Complainant, in analyzing evidence in a disparate

treatment case under the Minnesota Human Rights Act (HRA), the three-step

 

 

                                     -16-

 


process articulated by the United States Supreme Court  in  McDonnell  Douglas

Corp. v. Green, 411 U.S. 792, 93 S.Ct. 1817, 36 L.Ed.2d 668 (1973) must be

followed when a Complainant's case consists of circumstantial evidence.  See,

Danz v. Jones, 263 N.W.2d 395, 399-400 (Minn. 1978; Rademacher v.  FMC  Corp.,

431 N.W.2d 879 (Minn.Ct.App. 1988).  Under McDonnell Douglas      a complainant

must first present a prima facie case of discrimination.  If a prima facie

case is established the burden of producing evidence shifts to the respondent

to articulate a legitimate nondiscriminatory reason for the  action  it  took.

If the respondent meets its burden of articulating a legitimate

nondiscriminatory reason for its action, the complainant may present evidence

showing that the proffered reason for the action are a mere pretext for

discrimination.  At all times, the ultimate burden  of  persuasion  rests  with

the complainant.  See, Lamb v. Villaqe of Bagley, 310 N.W.2d  508,  510  (Minn.

1981).

 

    When a complainant can establish direct rather than circumstantial

evidence of discrimination, the McDonnell Douglas format is not followed.

Instead, once direct evidence of a discriminatory motive is  established,  the

burden of proof shifts to the employer to show that its action was not

discriminatory.  Lee v. Russell County Board of Education, 684 F.2d 769,

774-775 and n.6 (1lth Cir. 1982); Castle v. Sanqamo Weston,  Inc.,  41  F.E.P.

962, 975-976 (D.Fla. 1986); McDermott v. Lehman, 36 F.E.P. 531 (D.Maine

1984).

 

    Statements of an employer's officers and employees may  be  sufficient  to

establish direct evidence of discrimination shifting the burden  of  proof  --

not merely the burden of going forward with an explanation -- to the

employer.  Sigurdson v. Isanti County, 386 N.W.2d 715, 721 (Minn. 1986);

State,_by_Cooper V. Hennepin County,     N.W.2d ___ (Minn. 1989),  filed  June

2, 1989, C9-87-2434.  However, to constitute direct evidence of

discrimination, the discriminatory remarks must be sufficiently "direct."

Hence, they must be connected with the adverse action taken and must come from

someone directly responsible for the employment action.  Castle v. Sangamo

Weston, Inc., supra, 41 F.E.P. at 978; EEOC v. United States Steel, 42  F.E.P.

1680 (D.Pa. 1986).  If the statements do not have the requisite  nexus  to  the

alleged discriminatory act or not sufficiently direct, they may only be

considered as circumstantial evidence of a discriminatory motive.  Id

 

   Complainant argues that it has presented direct evidence of discrimination

that should shift the burden of proof in this case.  The direct evidence

relied upon apparently consists of the statements Eggers made to Havercamp  in

1979, Eggers' remarks regarding the unit determination litigation,  and  other

"environmental" statements of age bias.  These arguments deserve careful

scrutiny because they could affect the outcome in a close case.

 

   Havercamp was a credible witness.  She  testified  about  her  conversations

with Eggers in 1979 when she was an unsuccessful applicant for a  kindergarten

position.  At that time Eggers told her that she was not hired  because  Parker

wanted a "fresh graduate."  Eggers also told Havercamp that the District

wanted a "flow" in the ages of its teachers to avoid a gap when the older

teachers retire and that they like to get some "young blood" in the school

system to add more life to school functions.  Eggers did not  deny  Havercamp's

testimony.  Moreover, Vernon Wenberg, a school board member, testified  to  the

existence of the same policy Eggers described.  Stephen Rauker, another school

board member, testified that he had discussions with Eggers concerning the

 

 

                                    -17-

 


need to get a balance of teachers across the salary schedule to avoid high

salary costs.

 

    Eggers' 1979 comments to Havercamp are not sufficiently direct to

establish a discriminatory motive with respect to the 1984 hiring decisions.

Although there is evidence of an ongoing policy of considering age, that

policy apparently had not been followed in hiring Chapter I personnel.

Perhaps, that was due to the fact that Chapter I salaries were not adjusted

for seniority.   Under the agreement reached with HEA in 1984, Chapter I

teacher salaries were not seniority-based.   However, since the agreement could

be affected by a final court decision, there was a definite risk that they

would become seniority-based.   Eggers' statements do not address such a

situation directly.   Moreover, Eggers' statements were made in the context of

hiring new personnel, not in the context of the relatively unique situation

District administrators faced in 1984 when dealing with several previously

employed persons.  For these reasons it is concluded that Eggers' statements

to Havercamp do not establish direct evidence of discrimination shifting the

burden of proof.

 

    In addition, Complainant argues that Eggers' explanation for the decision

to terminate the Chapter I program during the 1983-84 school year constitutes

direct evidence of discrimination sufficient to shift the burden of proof.

Eggers testified that the Chapter I program was suspended because he feared

that the courts might ultimately determine that the paraprofessionals were

teachers.   In such a case, the paraprofessionals would be entitled to the same

salaries paid to teachers, acquire tenure, and have retroactive seniority

enabling them to bump regular classroom teachers.   Eggers stated that this was

his "worst case" scenario and that he suspended the Chapter I program because

he didn't want any of the former paraprofessionals in the District's

employment if the courts were to find that they were teachers that should be

included in the teachers' bargaining unit.  In the spring of 1984 it appeared

that Eggers "worst case" might come true because the Court of Appeals had

reversed PERB's determination that the paraprofessionals should be in a

separate bargaining unit.

 

    It would be difficult to characterize Eggers' remarks concerning the

reasons for suspending Chapter I program during the 1983-84 school year as

direct evidence of discrimination with respect to the 1984 hiring decision.

He merely stated that the District could not afford to retain eight tenured

paraprofessionals at a teacher's salary and that none of them, regardless of

age and experience, should be rehired until the District had time to decide

how to proceed.  His comments cannot be translated to directly state that no

paraprofessionals will be reemployed if there is a chance that they will

obtain seniority and be included in the teacher's bargaining unit.  Moreover,

Eggers' remarks regarding the suspension of the program in 1983 do not have

the requisite nexus to the reemployment decisions made in 1984.  The District

was clearly in a different position in the summer of 1984 than it was in the

fall of 1983.   It had succeeded in removing eight paraprofessionals and had

decided to rehire only four persons in that position.   Its Chapter I budget

covered the salaries of those persons at step zero of the teachers' salary

scale .  It did not have to worry about paying the salary of eight persons.

Moreover, an agreement was being negotiated with HEA which dealt with

seniority, tenure and salary issues.   The terms of the agreement that was

ultimately negotiated alleviated Eggers' fears.  Although those "fears" were

not eliminated, the extent to which those fears impacted the hiring decision

 

 

                                    -18-

 


in 1984 is clearly circumstantial rather than direct.

 

    In December 1983, Eggers told the Board that if teachers were to be hired

to fill the Chapter I positions, the District should hire the most qualified

and up-to-date trained teachers available.  His remarks suggest that

up-to-date trained teachers are somehow more qualified than teachers who

received their degrees at various times in the past.  There is an obvious

linkage between the date a person graduates from college and that person's

age.  Recent graduates will, for the most part, be younger than persons who

graduated 10, 15 or 20 years earlier.   Hence, hiring decisions which prefer

recent graduates solely because of notions regarding the quality of their

training have a discriminatory impact and constitute the kind of stereotyping

the Human Rights Act was designed to prevent in the absence of the existence

of a bona fide occupational qualification.  In spite of the remark Eggers  made

regarding up-to-date training, the Administrative Law Judge is not persuaded

that his isolated remark is sufficient to establish direct evidence of

discrimination.

 

   The record shows that there were other "environmental" statements

regarding the age and maturity of the District's staff.  In addition, there  is

evidence that Board member Wenberg expressed concerns about hiring older women

in the Chapter I program because students might have a "grandma" image and

another Board member stated that many of the paraprofessionals were not

rehired because the administration wanted some "fresh blood" in the system.

These remarks do not constitute direct evidence of discrimination.  Statements

regarding the maturity (age) of the District's teaching staff made during

budgetary meetings is not evidence of discrimination.  Those kinds of

statements merely explain high salary costs.  Wenberg's "grandma" statement

while entitled to some weight, is inconclusive and indirect.  Likewise,

statements regarding the administration's desire to get "fresh blood" in the

Chapter I program is also inconclusive.  The words "fresh blood" can refer to

different persons rather than young persons.

 

   For all these reasons, it is concluded that the statements relied upon  the

Complainant are not sufficient to establish a discriminatory motive and shift

the burden of proof to the Respondent.  Consequently, the evidence presented

must be considered along McDonnell Douglas lines.

 

   In McDonnell Douglas the court stated that a prima facie case of a

discriminatory refusal to hire may be met with the following showing:

 

    1.  That the charging party is a protected class member,

    2.  that the charging party applied for and was qualified for a

        job for which the employer was seeking applicants,

    3.  that despite the charging party's qualifications, the

        charging party was rejected, and

    4.  that after the charging party's rejection the position

        remained open and the employer continued to seek applicants

        from persons of the complainant's qualifications.

 

When an employer selects from a pool of applicants rather from applicants

considered in seriatim, the fourth element of the traditional McDonnell

Douglas test cannot be met because the rejection of a charging party occurs

simultaneously with the selection of the successful applicant.  Hence, the

charging party cannot show that the position remained open or that the

 

 

                                   -19-

 


employer continued to seek applicants with the plaintiff's  qualifications.  2

A. Larson and L. Larson, Employment Discrimination  50.31(f) at p.  10-36.

Since the fourth prong of the McDonnell Douglas test does not work when  an

employer is hiring from a "pool" of applicants, the courts have usually  dealt

with this problem by replacing the fourth element of the McDonnell  Douglas

formulation with that articulated in Texas Department of Community Affairs  v.

Burdine, 450 U.S. 248, 101 S.Ct. 1089, 67 L.Ed.2d 207 (1981).  In that case

the Court held that the plaintiff must prove by a preponderance of the

evidence that she applied for an available position for which she was

qualified but was rejected under circumstances which give rise to an  inference

of unlawful discrimination.  Accord:  Lucas v. Dole, 835 F.2d 532, 45 F.E.P.

971 (4th Cir. 1987); Hill v. Seaboard Coastline R.R., 642 F.Supp. 319, 42

F.E.P. 673 (M.D.Fla. 1986).5

 

    The Complainant has clearly established the first three components of a

prima facie case with respect to each of the Charging Parties.  Each of the

Charging Parties belongs to a class of persons over 18 years of age, and  each

of them applied and was interviewed for a Chapter I teaching position for  the

1984-85 school year.  Also, Complainant established that each of  the  Charging

Parties were qualified for that position.  All of them were licensed

elementary school teachers who Parker admitted were qualified for a Chapter  I

position.  Their licensure alone qualified them for the  position.  Even  if

that were not true, Lignell, Smith and Jaksha all had prior Chapter I  teaching

experience and all had performed the duties of a Chapter I teacher in a

satisfactory manner.  Although Havercamp had never worked as a Chapter I

paraprofessional, she was an experienced and licensed elementary school

teacher who had done a satisfactory job as a substitute teacher for the

District.  The fact that the District hired its paraprofessionals  from  the

substitute teaching list, coupled with the fact that Havercamp had more

teaching experience than three of the individuals who were hired as Chapter  I

teachers is persuasive evidence that she also was qualified for the  position.

In fact, in 1979, Parker had evaluated her as a strong candidate for a  regular

teaching position.  Her credentials support his  conclusions.  The  Charging

Parties also established that they were not hired to fill any of the  vacancies

that existed in spite of their qualifications.  Hence, the first three

elements of the Complainant's prima facie case clearly have been  established.

 

 

 

 

 

 

 

 

5However, some courts have held that the fourth element can be satisfied if

the position remained open after a qualified person applied and that another

person (e.g., younger) was ultimately selected.  Williams  v.  Edward  Apeffels

Coffee Co., 41 F.E.P. 396, 398 (9th Cir. 1986); Gelof v. Papineau, 42 F.E.P.

1299, 1303 (D.Del. 1986).

 

 

 

 

 

 

 

 

                                    -20-

 


    Under Burdine the Complainant must also show  that  the  Respondent's

rejection of the Charging Parties was made under  circumstances  which  give  rise

to an inference of unlawful discrimination.  This burden  cannot  be  met  by  only

showing that the charging parties were not hired.  See,  Autrv  v.  North

Carolina Dept of Human Resources, 820 F.2d 1384, 44  F.E.P.  169,  171  (4th  Cir.

1987); Holmes v. Bevilacqua, 774 F.2d 636, 38 F.E.P. 1831 (4th Cir. 1985),

appeal after remand, 794 F.2d 142, 41  F.E.P.  43  (1986).  If  the  fourth  prong

could be met by merely showing that a qualified class  member  was  not  selected,

any of the unsuccessful applicants for  the  Chapter  I  teaching  position  could

establish a primp facie  case  of  discrimination.  That  simply  is  not  enough.

Holmes v. Bevilacqua, supra.  This problem was  recognized  in  Kaster  v.

Independent School District No. 625,  284  N.W.2d  362,  365  (Minn.  1979)  where

the court implicitly used the same test later adopted by the United States

Supreme Court in Burdine.  In Kaster  the  court  considered  a  school  district's

failure to promote a qualified protected class  member  choosing,  instead,  other

qualified persons who were in a pool  of  applicants.  The  court  cautioned  that

mere rejection of a qualified protected class member  should  not,  without  more,

be sufficient to cause the burden of producing evidence to shift to the

employer to explain its employment  decision,  and  it  examined  the  record  for

evidence  supporting  an  inference  of  discrimination.  In  determining  whether

the circumstances of the Charging Parties' rejection raise an inference of

unlawful discrimination requiring explanation by the  Respondent,  it  is

necessary to separately consider the charges of those Charging Parties who

were previously employed as Chapter  I  paraprofessionals  and  the  charge  filed

by Havercamp who had not been so employed.

 

   Smith, Jaksha and Lignell had each taught in the school's Chapter I

program prior to the 1983-84 school year and  performed  their  job  duties  in  a

satisfactory manner.  Following a one-year suspension  in  the  Chapter  I

program, the District didn't simply rehire from the ranks of its former

paraprofessionals as it had done before.  Although  the  new  Chapter  I  positions

were to be filled by teachers,  rather  than  paraprofessionals,  the  duties  and

responsibilities of the new positions were essentially  the  same  as  the  duties

and responsibilities of the  paraprofessionals  had  been.  Moreover,  the  manner

of evaluating the candidates was changed.  Parker's power to make

recommendations based on his interviews was formalized  and  he  was  required  to

evaluate the candidates using 16  subjective  criteria  which  were  weighted  and

adjusted by Eggers.  After Eggers computed the applicant's scores, he

recommended, and the District hired,  four  younger  persons.  Only  one  of  them

had any significant Chapter I teaching experience.  The other three, being

recent graduates, had little or no teaching experience of any kind.  The

record also shows that the Respondent's application  forms  require  each

applicant to list her age and  date  of  birth.  When  teachers  were  interviewed

-- at least in 1979 -- the teacher interview summaries prepared by Parker

prominently listed the applicant's age.  (Dept.  Ex. 14, p. 15).  Employer

documents that refer to an applicant's age can  be  considered  as  circumstantial

evidence of a discriminatory  motive.  Herman  v.  National  Broadcasting  Company

35 F.E.P. 1653 (7th Cir. 1984).  All these facts, coupled with Eggers'

age-related statements, are sufficient to raise  an  inference  of  discrimination

with respect to Lignell, Smith and Jaksha.

 

   The Administrative Law Judge is also persuaded that the Complainant has

established a prima facie showing of  a  discriminatory  motive  with  respect  to

Havercamp.  As is already been noted,  in  1979  Eggers  told  Havercamp  that  she

was not hired as a kindergarten teacher  because  the  District  wanted  a  "fresh

 

 

                                     -21-

 


graduate." He also told her, at that time,  that  the  District  has  a  policy  of

considering an applicant's age in order to maintain a "age flow" in its

teacher corps.  Although these statements were made five years before the

hiring decision in question here, there is ample evidence in the record to

establish that the policy Eggers mentioned  continued  in  effect  in  later  years

due to the age (maturity) of its teaching staff.  Also, there is evidence that

Eggers wanted  "up-to-date  trained"  teachers.  In  addition,  there  is  evidence

that the District did not want to employ  Havercamp,  in  spite  of  her

qualifications, in favor of  younger  persons.  In  1984  Havercamp  had  indicated

an interest in a kindergarten position.  For the 1984-85 school year the

District hired a  kindergarten  teacher.  However,  Havercamp  was  never  informed

of the opening or specifically interviewed  for  it  and  the  position  was  given

to a younger woman.  On the basis of these factors, it is concluded that

Havercamp has also raised  an  inference  of  discrimination  that  the  Respondent

should explain.

 

    Since the Complainant has established a prima  facie  showing  of

discrimination with respect to each of the  Charging  Parties,  it  is  necessary

to consider the  Respondent's  legitimate,  nondiscriminatory  reasons  for its

actions.  The explanation must be  sufficient  to  justify  a  judgment  for the

Defendant.   Burdine, 450 U.S. at 255.  At  this  stage  of  analysis,  it is

necessary to "look for evidence presented by  the  employer  that  its  actions

related to some legitimate  business  purpose."  Sigurdson,  supra  at  720.

 

   Complainant argues that the legitimate nondiscriminatory reason for the

Respondent's failure to hire the Charging Parties was its concern for the

potential effect of the unit determination litigation pending at that time.

Complainant relies on Eggers' testimony to support that argument.  See, T.

p. 991.  However, Complainant's characterization misconstrues Eggers'

testimony.  The thrust of Eggers' testimony  was  that  the  change  in  the  hiring

process had something to do with the litigation.  Clearly it did.  The

litigation caused the suspension of  the  Chapter  I  program  during  the  1983-84

school year, led to a reduction in the number of Chapter  I  employees,  led  to  a

decision to use teachers rather than paraprofessionals in the Chapter I

program and resulted in salary increases,  limited  seniority,  tenure  rights  and

other benefits for Chapter I personnel.  Moreover, it led to a decision to

recruit Chapter I personnel from outside the Hibbing community.

 

   It is clear  from  the  record  that  the  legitimate   nondiscriminatory   reason

articulated by  the  Respondent's  witnesses is that the Charging Parties were

not hired because  they  received  lower  scores  on  the  evaluations:  i.e.,   that

they were determined to  be  less  desirable employees than the four persons

selected.  Respondent   presented  evidence that since teachers were being

recruited, and since  only  four,  rather than eight  Chapter  I  teachers  would  be

employed, Eggers determined that the evaluation process should be

"formalized." To that end,  Respondent  presented  testimony  that  two  elementary

school principals  - Drazenovich and Walters -- prepared an evaluation form

containing 16 criteria at Eggers' direction.  The form was based on some

college course materials and  the  evaluation  form  Parker  previously  used  (see

Ex. 14, p. 15, which was sometimes erroneously referred to as Parker's

"notes").  The Respondent also presented evidence that this evaluation form

was given to Parker before he began  interviewing  candidates  for  the  Chapter  I

teaching positions and that Parker completed  those  forms  and  returned  them  to

Eggers at the conclusion of his interviews.  Respondent also presented

evidence that Eggers then weighted the  various  criteria,  adopted  an  adjustment

 

 

                                     -22-

 


factor for prior teaching experience, and computed a score for each of the

candidates.  After the scores were completed the Respondent's evidence shows

that the candidates were ranked on the basis of those scores and that the

available persons with the highest scores were recommended for hire.  The

Administrative Law Judge is persuaded that the evidence presented by the

Respondent meets its burden of articulating a legitimate, nondiscriminatory

reason for hiring the four persons that were selected for the Chapter I

teaching positions.

 

    Since the Respondent has stated that the Charging Parties were not hired

because they were considered to be less qualified, it is necessary to

determine whether or not this proffered explanation is a mere pretext for

discrimination or is not worthy of belief.  McNeil v. Economics Laboratory,

Inc., 41 F.E.P. 1789, 1791 (7th Cir. 1986).  In order to raise an issue of

pretext, the Complainant is not required to show that age was the only  factor

considered by Parker and Eggers, or that the reasons offered by the Respondent

are false.  Complainant only has to show that the proffered reasons were not

the only reasons for the hiring decision and that age made a difference.

Nobler v. Beth Israel Medical Center, 702 F.Supp. 1023, 1028 (S.D.N.Y. 1988)

Age makes a difference when it is a substantial causative factor entering into

the decision not to hire an employee.  See, Anderson v. Hunter, Keith,

Marshall & Co., 417 N.W.2d 619, 624 (Minn. 1988).  When age is not the sole

reason, it must, however, be a "determining factor."  DeHues v. Western

Electric Co., 32 F.E.P. 387 (8th Cir. 1983).

 

    Complainant argues that the process the Respondent followed in  evaluating

and ranking applicants for the Chapter I teaching positions was a subterfuge

for discrimination.  In support of its arguments that the evaluation process

was a sham, Respondent focuses on Eggers' decision to change the procedure

used to evaluate and hire Chapter I teachers for the 1984-85 school year,  the

procedural irregularities that occured during the evaluation process, the

subjective nature of the criteria used, the ages and qualifications of the

persons selected, and Eggers' concerns regarding the effect of hiring former

paraprofessionals in the event the courts determined that they should be  part

of the teachers' bargaining unit as well as his policy of considering age in

hiring teachers.  Each of those factors must be separately considered.

 

                     STATEWIDE SOLICITATION OF APPLICANTS

 

   Complainant argues that the District's (Eggers) decision to abandon its

prior practice of rehiring its former paraprofessionals when the Chapter I

program was reanimated in 1984 evinces a discriminatory intent because the

paraprofessionals were all doing a good job and the job duties had not

changed.  Since the paraprofessionals were admittedly qualified for the new

positions, and Eggers had always been satisfied with Parker's recommendations,

Complainant suggests that the changes made in the hiring procedures in 1984

were designed to create a false appearance of objectivity to mask its

discriminatory objectives.  In determining whether the new process was a  sham,

it is necessary to carefully consider the entire hiring process in the context

of the pending litigation.

 

   After the decision was made to resume the Chapter I program, Eggers

decided the position should be filled by teachers.  There is little doubt  that

his decision was affected by the Court of Appeals' April decision.  As a

result of that decision it appeared that the paraprofessionals would be made

 

 

                                    -23-

 


part of the teachers bargaining unit absent a successful appeal.

Consequently, negotiations proceeded with the HEA regarding the salary,

seniority and tenure rights of the Chapter I teaching staff.  Eggers also

decided he would not hire only from the ranks of the paraprofessionals but

would seek applications from all qualified teachers to get  the  best  qualified

persons with the most "up-to-date" training.  The new positions were

subsequently advertised as all former teaching positions had been.

 

    Eggers' decision to seek applications for the new Chapter I teaching

positions statewide, and not limit consideration to the former

paraprofessionals, suggests a discriminatory motivation.  The duties of the

Chapter I teachers hired in 1984 were substantially the same as  the  duties  of

the paraprofessionals.  Eggers and Parker  admitted  that  the  paraprofessionals

who were licensed as teachers had been doing a good job and were  qualified  for

the new teaching positions.  Moreover, there is no evidence that  the  Chapter  I

program operated by the District was not successful or that any  of  the  pupils

served by any of the paraprofessionals were not making satisfactory  progress

or getting an appropriate level of assistance in math  and  reading  skills.  If

there had been some problems in the program, some questions regarding the

paraprofessionals' job performance or their qualifications, the decision to

take a closer look at the persons it hired would be understandable.  Since

there is not even a hint of any dissatisfaction, and since one  would  expect  a

degree of loyalty to current employees, Eggers' decision is incongruous.

 

    Eggers' explanation for the decision is that since the new Chapter I

positions were teacher positions, recruitment should follow the same  pattern

that was followed to fill all other teaching positions and that the  District

should seek out the most qualified persons available.    Neither reason  is  very

compelling under the circumstances.  Recruiting on a statewide basis simply

because teachers had always been recruited that way is exceedingly

formalistice given the fact that there were no problems with the Chapter I

program, no doubts about qualifications and job performance of the

paraprofessionals, and no change in the substance of the job duties  they  would

be performing.  The need to seek out more qualified  applicants  is  suspect  for

the same reasons.  Moreover, the record suggests that  the  true  motivation  for

seeking other qualified applicants arose, in part, because of the unit

determination litigation that was pending.  Under Eggers'  worst  case  scenario,

the new Chapter I teachers would acquire seniority and bumping rights in  the

teachers' unit.  If the paraprofessionals were reemployed, the District's

budget could be adversely a f fected becau se the pa raprof es siona 1 s would not be

limited to step zero of the teachers' salary range, could bump regular

classroom teachers, and might have stronger claims for back pay.  It's true

that the paraprofessionals previously employed by the District were not

required to be teachers and only tutored in math and reading.  It  is  also  true

that they were recruited locally from the District's substitute teaching

list.  Hence, when there was a prospect that these  paraprofessionals  might  end

up in a regular classroom setting, there may have been some concern about

their qualifications.  However, these factors were  never  mentioned  to  explain

Eggers' decision to look elsewhere to find "qualified" people and  there  is  no

evidence that their qualifications were checked or that inquiries were  made  at

that time to determine if they were qualified or there was a need  to  look  for

better candidates.  In fact, it appears that Eggers assumed that there were

better people.  In December 1983 he indicated that better people were those

with more up-to-date training.  His statements indicate that the District

wanted to find recent graduates.  Not only does it suggest that Eggers felt

 

 

                                    -24-

 


that recent graduates were more qualified, but having recent graduates also

fit into his general policy of hiring recent graduates to maintain an age flow

in the District's teacher corps.  This raises a strong inference that the

District was seeking recent graduates, if acceptable recent graduates could be

found, and did not want to employ the former paraprofessionals because of

their age and seniority.

 

    In Metz v. Transit Mix, Inc., 828 F.2d 1202 (7th Cir. 1982), the court

held that a 54-year-old employee that was discharged after 27 years of

employment and replaced with a younger employee with less seniority because

the employer wanted to save the higher salary of the older employee

constituted age discrimination because the older employee's salary was related

to his age.  In reaching its decision the court noted that:

 

         Courts have also emphatically rejected business practices

         in which  "  the plain intent and effect  . . .  was to

         eliminate older workers who had built up, through years of

         satisfactory service, higher salaries than their younger

         counterparts."

 

Id. at 1206.

 

    In Dace v. AFC Industries, Inc., 722 F.2d 374 (8th Cir. 1983), the court

held that discrimination on the basis of factors, like seniority that

invariably would have a disparate impact on older employees is improper under

the Federal Age Discrimination in Employment Act (ADEA).  The court went on to

hold that as a result of the close relationship between seniority and age,

displacing a worker with higher seniority in order to save money by hiring an

inexperienced younger employee is prohibited.  In Geller v. Markham, 635 F.2d

1027, 24 F.E.P. 920  (2d Cir. 1980), cert. denied, 451 U.S. 945 (1981), the

court held that a 55-year-old teacher who was replaced by a 25-year-old

teacher to enable the school board to cut its costs constituted age

discrimination.  In that case, the school board had a policy of hiring only

teachers below the sixth step of its salary scale as a cost-cutting measure.

Based on these cases, it is concluded that where economic savings are directly

related to an employee's age, it is unlawful age discrimination to consider

those savings when making employment decisions.

 

    In this case, as is discussed in more detail, infra, the District

deliberately gave its paraprofessionals low scores.  That was done, in part,

to avoid paying them higher salaries in the event the courts determined that

they were entitled to retroactive seniority rights and a higher salary.  Since

the economic savings the District sought are directly related to the

paraprofessional's seniority, it is concluded that the District's purpose was

discriminatory.

 

                           THE EVALUATION PROCESS

 

   In July and August Parker interviewed about 28 job applicants.  The

interviews followed the same informal pattern he had used for years.  He gave

each applicant an opportunity to examine the job description, to ask questions

and to make comments.  Parker used these interviews to evaluate the candidates

and give them an opportunity to sell themselves.  Parker did not have a

standardized set of written questions or subjects that he asked and did not

have any files, records or forms available during the interview.  He had a

 

 

                                    -25-

 


note pad but he took few notes and asked few questions of the  Charging

Parties.

 

    Eggers testified that he gave Parker an evaluation form before  any

interviews were held and told Parker to use it to evaluate the applicants  he

interviewd.  Eggers also testified that the evaluation form was developed

early in June by Walters and Drazenovich.  Although Eggers  testimony  was

supported by Walters and Drazenovich, that testimony cannot be  credited.

First, Eggers testified that Walters and Drazenovich were asked to draft an

evaluation form late in May or early in June because Parker was on  vacation.

Drazenovich and Walters also testified that the form was completed at that

time.  Drazenovich said that the form was drafted before June 15 because he

and Walters were usually on vacation by that date.  T. VI,  1115.  However,  the

record shows that Parker was still at work on June 18 and took his vacation

after that. (Dept.  Ex. 10, p. 1).  Moreover, Drazenovich  admitted  that  some

interviews may have been held before the evaluation forms were completed.  T.

VI, p. 1164.  Finally, and most important, Parker stated that he got  the  forms

after the interviews were completed.  Under the circumstances, the

Administrative Law Judge is persuaded that the evaluation forms were  not

available at the time of the interviews and that the testimony offered by

Lignell and Sibell concerning the statements Walters, Drazenovich and  Parker

made to them in September must be credited.

 

    Other evidence in the record supports a conclusion that the evaluation

forms were given to Parker after the interviews had been completed.  On  August

29, 1984 Eggers prepared a memorandum for a school board meeting  which

described the process followed in selecting the four Chapter I teachers he  was

recommending for hire. (Dept.  Ex. 36).  That memorandum appears  to  be  a

chronological description of the steps taken by the District and suggests  that

Parker's interviews were held before the formal evaluation sheets  were

adopted.  Moreover, the evaluation sheets themselves, while containing  a  space

for "REMARKS", have no interview notes, and with two exceptions, no  statements

concerning the applicants.  Kotonias' form states that she is employed and

Prince's form states that as of July 26, 1984 she did not have a teaching

certificate.  It is unlikely that Kotonias was employed at the time of the

interview.  Hence, the note on her form must have been  added  later.  The

remarks on Prince's form are inconclusive, but the absence of any notations  on

the other evaluation sheets does not make sense.  If Parker had  the  evaluation

forms prior to the interviews, it is likely that he would have used  them

during the interview and made some remarks on the space provided.  Moreover,

if Parker had been aware of the 16 criteria on the evaluation form prior to

the time his interviews were conducted, he certainly would have asked

questions relating to those criteria at the time of the interviews.  However,

he did not do so.

 

   The adoption of criteria for the evaluation of candidates following the

completion of interviews and the collection of data is suspect.  When  criteria

are adopted following interviews an employer can draft criteria to match the

strengths of the persons it wants to hire.  If the District wanted to hire

recent graduates, for example, tailor-made criteria could be drafted after  the

interviews to ensure that they received the highest scores,  In this case,

however, there is no evidence that the criteria were adopted for that

purpose.  The criteria are the kind one would expect a school to look  at.

Nonetheless, the tardy adoption of criteria is inconsistent with  orderly

procedure and raises a reasonable suspicion regarding the District's motive

 

 

                                    -26-

 


for drafting them.   If the District was truly on a quest for excellence, it is

unlikely that it would have drafted the criteria and the methodology for

scoring applicants after interviewing them.  Hence, the tardy adoption of

those criteria, coupled with the inconsistent testimony of District personnel

on the timing of their adoption, suggests that the criteria were designed to

add a facade of legitimacy to a predetermined result.  This is confirmed by

Parker's actions.

 

    Although the applicants scores with respect to some of the criteria could

have been completed after the fact, and although some of them were criteria

that Parker had historically considered, in order to rate candidates with

respect to academic preparation, grade point averages, extracurricular

strengths, special interests, oral and written skills, community involvement,

instructional competencies, and cooperation and professional spirit, some

specific data is needed.  However, Parker took steps to obtain necessary

information from any of the Charging Parties before or after his interviews.

The evidence shows that Parker did not ask any questions with respect to these

criteria.  Moreover, he did not request that any of the Charging Parties

submit their college credentials to assist him in evaluating their

qualifications.  On May 15, 1984, Parker wrote a letter to Susan Proctor

advising her that he had received her application for a teaching position.  In

his letter Parker suggested that Proctor send him a copy of her credentials.

However, between June 18 and July 12, in letters written to the former

paraprofessionals and in letters written to Havercamp and Karen Adam, he did

not make that suggestion, but, after July 13, 1984, Parker routinely made that

request of the applicants.  Parker testified that he did not ask the Charging

Parties for their college credentials because he thought they would be in

their files.  However, Eggers said that credentials are routinely destroyed

after they are received.  If that is true, it is unlikely that Parker would

have been unaware of that fact.

 

   Parker's failure to request that the Charging Parties submit copies of

their college credentials to him is compounded by the fact that it appears

unlikely that Smith's transcript or Lignell's credentials were available to

him when the evaluations were completed.  Nonetheless, Parker proceeded to

score them under the 16 criteria.  If the process was designed to be

objective, one would expect Parker to make some effort to obtain needed

information to evaluate them after he obtained the criteria and realized that

the information he had was inadequate.  However, he did not do so.  In Zahorik

v. Cornell University, 729 F.2d 85, 93 (2d Cir. 1984), the court noted that

the failure to collect available evidence in making an employment decision is

a departure from procedural regularity which can raise a question as to the

good faith of a hiring process.  The adoption of criteria following the

completion of interviews and the ranking of candidates in areas for which no

inquiry was made is evidence of bad faith.

 

   In addition, many of the criteria are highly subjective.  As noted by

Complainant, the courts generally recognize that procedures which depend

almost entirely upon subjective evaluations are ready mechanism for

discrimination.  Nanti v. Barrows_Co., 66 F.2d 1327, 1334 (9th Cir. 1981).

The federal courts generally require close scrutiny of employment decisions

which rely on subjective evaluations challenged as discriminatory.  Crawford

v. Western Electric_Co.,_Inc., 614 F.2d 1300, 1315 (5th Cir. 1980); Davis v.

Califano, 613 F.2d 957, 965-966 (D.C.Cir. 1980).  It may be difficult to

determine whether an applicant possesses all the requisite capabilities for a

 

 

                                   -27-

 


emanate from the subconscious of the decisionmaker without any specific basis"

are not sufficient.   Tye v. Board of Edu., Polaris Joint  Vocational  School

Dist., 81 3 F. 2d 31 5, 43 F E. P. 34, 38 (6th Cir.  cert. denied , 108 S. Ct. 285

(1987).

 

     Parker testified that he did the best job he could in completing the

evaluation forms after he received them from Eggers.     However, he was totally

unable to explain, with any degree of specificity, the factors that he

considered in scoring candidates under the 16 criteria or how he made the

determinations that were made.  In the area of educational experience

(recommendations), which was the most highly weighted criteria getting a

weight of 3, Parker was unsure how he scored that criteria in a general way or

with respect to any specific applicant.  The  Respondent  cannot  be  punished

because Parker has forgotten the details of the scoring process followed.

However, the Administrative Law Judge is persuaded that his "forgetfulness" is

not entirely genuine.  After the school board approved Eggers' recommendations

in September 1984, Lignell and Sibell questioned Parker about the scores they

received.  At that time he was unable to give any meaningful explanation.  If

he could not give an understandable explanation then, it  is  not  surprising

that he cannot do so now.  Moreover, while Parker has been retired for four

years, it is unlikely that he would forget as much as he  said  he  has.  The

Chapter I hiring saga is not the kind of event one would easily forget.  That

is especially true with respect to the former paraprofessionals' scores.     He

worked with them for a number of years, was acquainted with their lawsuit, and

the publicity surrounding the Chapter I situation.  As a director of

elementary education he must have had conversations with teachers,

superintendents and parents concerning the paraprofessionals, and even

Havercamp, and formed some opinions regarding the success of  the  Chapter  I

program and their job performance.  Nonetheless, he presented no explanation

for the relatively low grades he gave them in highly subjective areas.  There

are no known problems with respect to their qualifications or job

performance.  Hence, the low scores he gave to the Charging Parties in many

areas seems totally unjustifiable.  It is unlikely that qualified teachers who

have been employed year after year for the Respondent and whose job

performance was admittedly satisfactory if not superior, would receive scores

so low that even after they were weighted and adjusted by up to 20% for

experience, they would still fall far short of meeting the  scores  given  to

younger, recent graduates.

 

    The overall scores Parker gave to older applicants generally, and the

Charging Parties specifically, also persuade the Administrative Law Judge that

Parker's evaluations were a mere pretext for rejecting them because they were

older.  Parker's scores lumped almost all older applicants and all the

paraprofessionals together at the bottom of the heap.  Given the total lack of

any evidence of problems with respect to the Charging Parties, it is

inconceivable that they were all equally inferior to the younger applicants.

 

    Although there is evidence suggesting that recent graduates were desired,

in part, because they had "up-to-date" training, the Respondent presented no

evidence tending to show what training recent graduates had that the Charging

Parties didn't have.  Although Eggers mentioned that computer training was an

example of the skills recent graduates had, no inquiries were made of the

applicants regarding their training in computers and no specific areas of

special training were listed on the evaluation forms.  Also, the District made

no showing that computer training was needed.  Under these circumstances, the

 

 

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candidates could be hired.  Younger candidates were desired because of the

District's age-flow policy and in order to avoid unnecessary complications in

the event the former paraprofessionals were found to be members of the

teachers' bargaining unit.

 

    The ages of the paraprofessionals are directly related to the seniority

they would have in the event Eggers' worst case scenario came true.  However,

the amount of the additional expenses the District might incur in the event

the paraprofessionals were rehired and found to be members of the bargaining

unit is not known.  Clearly, it was perceived to be substantial enough to make

a difference.  Since seniority is related to age, the Administrative Law Judge

is persuaded that consideration of that factor was discriminatory.  However,

even if that were not true, there is persuasive evidence that age alone made a

difference in the hiring process because the District wanted to employ recent

graduates.  The desire to hire recent graduates not only applied to the

Charging Parties but also applied to Havercamp.  Clearly the concerns the

District had about reemploying the paraprofessionals due to the pending

litigation was only a partial factor in its decision.  Their reemployment was

also inconsistent with its policy of hiring recent graduates to maintain an

age flow.  This policy, which was not denied, not only affected the Charging

Parties but also affected Havercamp.

 

   Although the District did employ one former paraprofessional (Sibell), the

Judge is not persuaded that hiring is inconsistent with the conclusions

reached herein.  Although Sibell's employment was inconsistent with Eggers'

"worst case" scenario, she was younger than all but one of the other former

paraprofessionals who qualified for the position and was apparently more

acceptable to the District and the youngest paraprofessional.  Moreover,

Smith's subsequent employment in the Chapter I program for the 1985-86 school

year does not evince good faith because that hiring occurred after she filed

an age discrimination charge against the District.  Smith was reemployed that

year not because she was next in line on Eggers' ranking, but because she was

the best candidate under a new, scientifically-based interview and evaluation

process.  The fact that Smith was the number one candidate in a

scientifically-based evaluation process in 1985 supports her overall

qualifications and is further evidence of some impropriety in the process

followed in 1984.

 

                                   DAMAGES

 

   Since the Administrative Law Judge is persuaded that age was a substantial

causative factor in the Respondent's evaluation of and failure to hire the

Charging Parties in this case, appropriate relief must be ordered.

 

                                CIVIL PENALTY

 

   Minn.  Stat.  363.071 authorizes the issuance of a cease and desist order

against a respondent who has violated the Human Rights act (HRA).  In

addition, in 1984, it required that a respondent found in violation of the HRA

to pay a civil penalty to the state in addition to compensatory and punitive

damages.  With respect to the amount of the civil penalty to be paid by

respondent, the statute states that the following factors must be considered:

"The seriousness and extent of the violation, the public harm occasioned by

the violation, whether the violation was intentional, and the financial

resources of the respondent."  The violation in this case is

 

 

                                   -31-

 


serious.  It affected all the older applicants who applied for Chapter I

teaching positions  and  the  State's  interest  in  eradicating  age-based

discrimination.  The public interest has also suffered as a result of the

expenses that have been incurred by the State to prosecute this matter.

Moreover,  the  violation  was  intentional.  Parker  knew  that  age-based

discrimination was prohibited.  In 1979, he was required to respond to

Havercamp's charge alleging that she had been discriminated against on the

basis of her age when he hired  a  younger  person  for  a  kindergarten  position.

However, there is no evidence in the record pertaining to the District's

financial resources or the costs the State has incurred in this matter.  Under

these circumstances, a civil penalty of $10,000.00 is appropriate.  Civil

penalties assessed in the past have commonly been in the range of $500 to

$3000 for a violation affecting one person.

 

                           MENTAL ANGUISH AND SUFFERING

 

    All the Charging Parties suffered mental anguish as a result of the

District's failure to hire  them.  However,  it  appears  that  Lignell  and  Smith

were not as severely traumatized as Havercamp and Jaksha and that Jaksha

suffered the most.  Lignell and Smith soon found other full-time work and had

the least loss of income.  The duration of their anguish was shorter and their

ability to find work paying as much as they  would  have  made  if  they  had  been

hired eased the stress that follows income loss.  They should receive

$3,000.00 each.  Havercamp's anguish persisted for a longer period of time due

to her inability to find full-time work.  She is entitled to $5,000.00.

Jaksha, the oldest member of the group, was affected the most and was

devastated by her second rejection in 1985.  Her feelings at that time were

caused, in large part, by  her  rejection  in  1984.  She  is  entitled  to

$10,000.00.

 

                               COMPENSATORY    DAMAGES

 

    Compensatory damages may be awarded  under  Minn.  Stat.    363.071,  subd.  2

(1984).  Under the  statute,  the  compensatory  damages  awarded  should  make  the

victim whole by placing her in the position she would have been in had no

discrimination occurred.  Brotherhood of Railway and Steamship Clerks V.

Balfour, 303 Minn. 178, 229 N.W.2d 3, 13 (1975); Anderson v. Hunter, Keith,

Marshall & Co., Inc., 417 N.W.2d 619, 627 (Minn. 1988).

 

    In awarding compensatory damages in this case, each of the Charging

Parties should be fully compensated for her income loss during the 1984-85

school year.  The amount of income loss should be measured by the amount they

would have received as a Chapter I teacher less the income they earned during

the school year, as follows:

 

         Smith                 $14,630    $   891    or   $13,739.00

         Lignell               $14,630    $4,293     or   $10,337.00

         Havercamp             $14,630    $2,762     or   $11,868.00

         Jaksha                $14,630    $1,738     or   $12,892.00

 

 

   Since Smith  and  Lignell  were  regularly  employed  from and after the 1985 86

school year, their total  compensatory  damages  are  $13,739  and  $10,377

respectively.

 

 

 

                                       -32-

 


    In addition to the wage loss Havercamp sustained during the 1984-85  school

year ($11,868), Havercamp has lost $42,080 through the end of the  1988-89

school year.  During that four-year period Havercamp would have  earned  $65,930

as a Chapter I teacher, but her actual earnings were only $23,850.  Hence,  her

total wage loss has been $53,948.  ($42,080 plus $11,868).

 

    Jaksha has not been employed since 1985.  Consequently, she  has  sustained

wage losses to the present time.  However, her situation is  somewhat  different

because she stopped looking for work in 1985 and let her teaching  license

expire.  Her decision to drop out of the labor market was due, in  large  part,

to the District's failure to hire her in 1984 and 1985.  The  issue,  therefore,

is whether her failure to look for work after 1985 should be considered  in

computing her damages after that time.

 

    Victims of discrimination have a duty to use reasonable diligence in

finding other employment in order to mitigate their damages.  Anderson  v.

Hunter, Keith, Marshall & Co., 417 N.W.2d bl9, 627 (Minn. 1988).  However,  the

burden of proving that a victim's damages could have been mitigated is on  the

respondent.  See, e.g., Sias_v.   citv Demonstration agency

                               588 F.2d 692  (9th

Cir. 1978).  In this case, there is clear evidence that Jaksha failed  to  use

reasonable efforts to mitigate her damages.  Since there is no medical

evidence that she was simply unable to work for emotional reasons, and  since

it is clear that substitute teaching positions are always available, it  is

concluded that Jaksha's wage loss after the 1985-86 school year should not  be

compensated, and for the 1985-86 school year her wage loss should be  reduced

by $2000 -- roughly the earnings she had as a substitute teacher the  year

before.  Hence, she is entitled to compensatory damages of $12,892  for  the

1984-85 school year, and $13,632 for the 1985-86 school year ($28,524).

 

   Under  363.071, subd. 2, compensatory damages up to three times the

damages actually sustained can be awarded.  Due to the absence of  any  evidence

regarding the District's financial position and the adverse effect a  large

award could have on pupils, it is concluded that compensatory damages  should

be limited to the actual wage losses sustained and that interest on those  sums

should not be required.

 

                               PUNITIVE DAMAGES

 

   Under  363.071, subd. 2 (1984), punitive damages of up to $6000 can be

assessed against a respondent only under Section 549.20, which provides:

 

        Subd. 1.  Punitive damages shall be allowed in civil

        actions only upon clear and convincing evidence that the

        acts of the defendant show a willful indifference to the

        rights or safety of others,

 

 

 

        Subd. 3.  Any award for punitive damages shall be measured

        by those factors which justly bear upon the purpose of

        punitive damages, including the seriousness or hazard to

        the public arising from the defendant's misconduct, the

        profitability of the misconduct to defendant, the duration

        of the misconduct and any concealment of it, the degree of

        the defendant's awareness of the hazard and of its

 

 

                                    -33-

 


          excessiveness, the attitude and conduct of the defendant

          upon discovery of the misconduct, the financial condition

          of the defendant, and the total effect of the punishment

          likely to be imposed upon the defendant as a result of the

          misconduct, including compensatory and punitive damage

          awards to the plaintiff and other similarly situated

          persons  . . .

 

     Age discrimination is a serious threat to the public interest and

adversely affects older persons from obtaining gainful employment.  In this

case, the record shows that the District, due in part to a cost-saving motive,

discriminated against older applicants and had apparently done so for a number

of years.  Even though one  discrimination  charge  had  been  filed  against  it  in

1979, no corrective actions were taken.  These factors establish a willful

indifference to the rights of the Charging Parties and justify an award of

punitive damages.

 

    However, the Administrative Law Judge is not persuaded that the maximum

allowable punitive damage award should be  made  to  each  Charging  Party  or  that

all Charging Parties should receive the same amount.  There is no evidence

regarding the District's financial condition and the damages it must pay to

the Charging Parties  are  substantial.  Moreover,  to  the  District's  credit,  it

adopted new hiring policies in 1985 and rehired one of the Charging Parties at

that time.  Under all these circumstances, it is concluded that the Charging

Parties should be awarded the following punitive damages:

 

          Smith          $2,000.00

          Lignell        $2,000.00

          Havercamp      $2,000.00

          Jaksha         $3,000.00

 

                                   REINSTATEMENT

 

    Only Jaksha seeks a  reinstatement  order.  Since  she  is  no  longer  licensed

as a teacher, however, that request should be denied.

 

 

 

                                       J.L.L.

 

 

 

 

 

 

 

 

                                       -34-