In today’s ruling in Maccagnan v. Cherry Creek School District No. 5, (No. 25-1335 (D.C. No. 1:22-CV-00503-CMA-KAS), the 10th Circuit Court of Appeals affirmed the Colorado District Court’s ruling in favor of Cherry Creek Schools. In the case, Plaintiff Linda Maccagnan sued Cherry Creek School District No. 5 and others for demoting her from principal to assistant principal. She alleged various federal constitutional and statutory violations. The district court granted partial summary judgment against her. The remaining claims proceeded to trial.
After Ms. Maccagnan rested her case, the court granted the Defendants’ motion for judgment as a matter of law (“JMOL”) under Federal Rule of Civil Procedure 50(a). Ms. Maccagnan appealed the partial summary judgment, evidence rulings at trial, and the JMOL.
The 10th Circuit found that the district court correctly determined “that a reasonable jury would not have a legally sufficient basis to find for” Ms. Maccagnan on her sex stereotyping theory. Fed. R. Civ. P. 50(a). Defendants were thus entitled to JMOL. As the Supreme Court said in Reeves v. Sanderson Plumbing Products, Inc., 530 U.S. 133 (2000), “An employer would be entitled to judgment as a matter of law if the record conclusively revealed some other, nondiscriminatory reason for the employer’s decision, or if the plaintiff created only a weak issue of fact as to whether the employer’s reason was untrue and there was abundant and uncontroverted independent evidence that no discrimination had occurred.” 530 U.S. at 148. The court affirmed the district court’s judgment. Read the opinion.