Question: Jett v. Dallas Independent School District 491 U.S. 701 (1989)

Plaintiff, a white high school coach and teacher, brought suit under section 1983 against his employing school district and a black principal, alleging they were responsible for a racially discriminatory diminution in his employment status. A jury held for the coach and awarded compensatory and punitive damages. The U.S. Supreme Court upheld the verdict in part.

O'Connor, J.

Norman Jett, a white male, was employed by Dallas Independent School District (DISD) as a teacher, athletic director, and head football coach at South Oak Cliff High School (South Oak) until his reassignment to another DISD school in 1983. Jett was hired by the DISD in 1957, was assigned to assistant coaching duties at South Oak in 1962, and was promoted to athletic director and head football coach of South Oak in 1970. During Jett's lengthy tenure at South Oak, the racial composition of the school changed from predominantly white to predominantly black. In 1975, the DISD assigned Dr. Fredrick Todd, a black, as principal of South Oak. Jett and Todd clashed repeatedly over school policies and in particular over Jett's handling of the school's football program.

These conflicts came to a head following a football game between South Oak and the predominately white Plano High School. Todd objected to Jett's comparison of the South Oak team with professional teams before the match, and to the fact that Jett entered the officials' locker room after South Oak lost the game and told two black officials that he would never allow black officials to work another South Oak game. Todd also objected to Jett's statements, reported in a local newspaper, to the effect that the majority of South Oak players could not meet proposed National Collegiate Athletic Association academic requirements for collegiate athletes. Todd informed Jett that he intended to recommend that Jett be relieved of his duties as athletic director and head football coach at South Oak.

Jett was reassigned as a teacher at the DISD Business Magnet School, a position that did not include any coaching duties. Jett's attendance and performance at the Business Magnet School were poor, and he [was notified he was being] placed on "unassigned personnel budget" and reassigned to a temporary position in the DISD security department. Jett filed this lawsuit, and the DISD subsequently offered Jett a position as a teacher and freshman football and track coach at Jefferson High School. Jett did not accept this assignment and sent his formal letter of resignation to the DISD. Jett brought this action under 42 U.S.C. §§ 1981 and 1983, alleging due process, First Amendment, and equal protection violations. His equal protection and § 1981 causes of action were based on the allegation that his removal from the athletic director and head coaching positions at South Oak was motivated by the fact that he was white, and that Principal Todd, and through him the DISD, were responsible for the racially discriminatory diminution in his employment status. These claims were tried to a jury, which found for Jett on all counts.

The jury awarded Jett $650,000 against the DISD, $150,000 against Principal Todd and the DISD jointly and severally, and $50,000 in punitive damages against Todd in his personal capacity. The District Court set aside the punitive damages award against Principal Todd as unsupported by the evidence, found the damages award against the DISD excessive and ordered a remittitur of $200,000, but upheld the jury's verdict in all respects. While finding the question "very close," the Court of Appeals concluded that there was sufficient evidence from which a reasonable jury could conclude that Principal Todd's recommendation that Jett be transferred from his coaching duties at South Oak was motivated by impermissible racial animus. The court noted that Todd had replaced Jett with a black coach, that there had been racial overtones in the tension between Todd and Jett before the Plano game, and that Todd's explanation of his unsatisfactory rating of Jett was questionable and was not supported by the testimony of other DISD officials who spoke of Jett's performance in laudatory terms. AFFIRMED in part and REMANDED.

1. Does the decision make sense to you? Explain.

2. What difference do you think it made to the coach's job that the school district's racial composition changed?

3. If you were the principal, what would you have done differently?