Firing of Only Black Georgia Military College HR Employee Ruled A Proper Termination

The court ruled that Sheila Gray failed to provide sufficient evidence to support her claims of race discrimination.

The 11th U.S. Circuit Court of Appeals has ruled that Shelia Gray’s layoff was a proper termination following Georgia Military College’s campus-wide reduction in force.

Gray was the only African American working in the college’s human resources department, which consisted of seven full-time employees, six of whom were white. After the vice president of human resources terminated her administrative assistant position, she sued the college’s Board of Trustees for alleged race discrimination in violation of Title VII of the Civil Rights Act.

According to court documents, Georgia Military College’s campus-wide reduction in force came amid budgeting issues due to a decline in the college’s revenues partially due to the 2020 COVID pandemic. The school’s president ordered each department to eliminate one position.

Gray alleged that her termination came four weeks after she complained about a former employee in another department who commented on social media regarding George Floyd’s death, “Bring back the hoses and release the dogs.”

However, the plans for a reduction in force had already begun around two months prior to her complaint.

“We simply cannot say that the temporal relationship between [the worker’s] protected activity and her termination is enough to allow a reasonable jury to infer that she was terminated in retaliation [for that activity],” the court upheld.

Gray was hired at Georgia Military College in 2015. The college promoted her to HR administrative assistant in 2018 to fulfill day-to-day duties that included answering phones, greeting visitors, scanning personnel records for new hires and terminated employees, processing purchase orders, and completing employment verification forms.

To support her claims, Gray referenced a co-worker’s concern that eliminating her position would result in an increased workload for the remaining employees in the HR department. However, the HR department’s vice president said Gray’s position was selected for termination because other department employees were already familiar with the position’s duties.

“Gray failed to show that the Board fired her because of her race,” court documents read. “The Board thus was entitled to summary judgment on her discrimination claim.”

The court concluded that Gray “failed to come forward with sufficient evidence to allow a reasonable jury to conclude that she was terminated because of her race.”

According to the 11th Circuit, her race discrimination claim “does not establish pretext,” and the school’s reasoning for her termination was legitimate.

Gray is one of 10 employees from across different departments at Georgia Military College who were laid off due to the reduction in force. She applied for an admissions assistant and academic success coach position but was not selected to fill either role, one of which the school said was filled by another African American candidate.