A managerial decision to “clean house” in order to eliminate workplace disruptions is a legitimate, nondiscriminatory reason for terminating an employee under Title VII. Holmes v. Jefferson County Pub. Sch. Dist., No. 15-15198, 2016 WL 4056029 (11th Cir. 2016). Holmes arose from the Information Technology department of the Jefferson County School District. That department hired a black female, April Holmes, in 2009 and a black male, Kenneth Mitchell in 2011. A white male, Kenneth Stubbs, had worked in the department for roughly 30 years. In 2011, substantial conflicts arose between Ms. Holmes and Mr. Stubbs, leading to two meetings with the District’s Superintendent.
In 2012, a new Superintendent, Albert Cooksey, was elected. Mr. Cooksey was aware of the conflicts in the IT department and decided, in his words, to “clean house.” He terminated Ms. Holmes and Mr. Mitchell. Mr. Cooksey retained Mr. Stubbs because of his greater level of experience and because Cooksey believed Stubbs was not a part of the conflicts. Ms. Holmes sued and claimed that her termination was based upon her race in violation of Title VII of the Civil Rights Act of 1964.
The Eleventh Circuit found that Mr. Cooksey’s desire to “clean house” was a legitimate, nondiscriminatory reason for terminating Ms. Holmes. The court also found that Ms. Holmes failed to meet that reason “head on” and rebut it. Indeed, the court found “Ms. Holmes does not dispute that there was conflict within the department. Nor does she dispute that Mr. Stubbs had more experience than she did.”
The court recognized that termination of the department’s two black employees, while retaining the lone white employee, was a potential issue. Nevertheless, the court found that “the sample size is too small to conclude without more that this shows causation rather than coincidence. Further, the record demonstrates that the first person Mr. Cooksey recommended to fill one of the recently vacant IT technician positions was African-American.”
Holmes recognizes that an employer’s desire to limit workplace disruptions is a valid defense to Title VII claims. Obviously, that defense is rebuttable by the employee, so employers should not generically rely upon a desire to “clean house” as a defense in all Title VII claims. Instead, if an employer possesses adequate documentation of the workplace disruptions, it will possess a good starting point for obtaining dismissal of the Title VII claims.