Labor & Employment Law Daily Wrap Up, DISCRIMINATION—SEX—W.D. La.: Principal’s ‘repugnant’ remarks to coach over two years did not create HWE, (Feb 11, 2026)

By Marjorie Johnson, J.D.

While her comments were “explicit and crude,” courts have regularly found similar remarks do not prevent an employee “from succeeding in the workplace.”

A high school principal’s “unquestionably vulgar” and “repugnant” remarks to a male teacher and head coach of the girls’ basketball team, which included, “I can see your little shrimp through your pants” and other comments seemingly disparaging the perceived size of his genitals, were too infrequent and insufficiently severe to create a hostile work environment, a federal district court ruled in dismissing his Title VII sexual harassment claim on summary judgment. His ADA disability bias claim also failed since, while the principal may have regarded him as disabled by accusing him of using cocaine, he failed to show his mandatory referral to an EAP constituted an adverse employment action (Golatt v. Caddo Parish School Board, No. 23-0857 (W.D. La. Feb. 9, 2026)).

The teacher worked at the high school since August 2016, first as a substitute teacher and eventually as a part-time teacher and school disciplinarian. He held those roles when the new principal came on board in late 2019. Soon thereafter, the COVID-19 pandemic forced closure of the school.

Appointed head coach. When in-person classes resumed in August 2020, the principal selected the teacher to be the head coach of the girls’ basketball team and removed his disciplinary responsibilities. As a coach, she allowed him to wear casual clothing, including sweatpants.

Vulgar remarks. In fall 2020, the teacher entered the band director’s office for a meeting while wearing sweatpants, and the principal—who already seated inside—laughed and remarked, “I can see your little shrimp through your pants.” He then tried to pull down his shirt to cover himself. During a meeting with the principal in her office around the same time, she asked if they were referring to each other by their first names or last names since, “inquiring minds want to know how big [his penis] is.” He felt uncomfortable and changed the subject.

During a 2021 summer administrative meeting, staff members discussed who would have disciplinary duties for the following year. The principal remarked that it would not be the teacher since she needed “men with big nuts [and a] strong penis to work in discipline and that’s not [him] according to what I saw on camera.” He claimed she was referring to an incident where a student struck him in his genitals while he was trying to stop a fight, leaving him doubled over and breathless.

During the 2021-2022 school year, the principal made another vulgar comment while he was talking with another male teacher, telling him that there wouldn’t be “any d**k swinging” and “to put [his] d**ck up.” That October, she also confronted four coaches about an alleged rumor that they had a group bet “on who would f**k” the assistant principal first. Each coach denied the accusation.

Accused of drug use. In January 2022, a parent complained about a post the teacher made on social media about an upcoming basketball game. The principal confronted the teacher in a heated meeting and stated that he must be “mentally unstable and doing cocaine.” She then ordered him to visit with the employee assistance program (EAP) or be fired. He complied, and within a few minutes of the visit, the counselor said, “he saw nothing wrong” with him and told him to go back to his school.

Another explicit sexual remark. In the spring 2022 the principal remarked to the teacher that he must “be eating [and] using [his] tongue real [sic] good on women because [he] surely don’t [sic] have anything down there.” Once again, he felt uncomfortable and changed the subject as she laughed.

Complaint leads to reassignment. In August 2022, the principal pressured the teacher to hire a female staff member as his assistant coach. He refused, and the principal removed him as head coach thereby taking away his coaching stipend. He then filed a sexual harassment complaint about her vulgar behavior, and the district responded by reassigning him to a different high school. He viewed this as a punishment and complained, but the district did not change its decision. He eventually resigned on July 31, 2023.

Lawsuit. He sued, alleging claims of hostile work environment (HWE) and retaliation under Title VII and disability bias under the ADA. The school district did not seek summary judgment on the retaliation claim.

Harassment not pervasive. In addressing his HWE claim, the court acknowledged that the principal’s alleged behavior was “unquestionably vulgar, particularly in a school context.” However, her sexual comments occurred only six times in two years, and such “infrequent conduct” was not sufficiently pervasive to sustain a HWE claim.

Nor was it severe. Moreover, while her behavior was “repugnant,” none of her comments were severe enough to alter the conditions of the teacher’s employment. The court noted that he did not allege that she touched or attempted to touch him inappropriately, nor did he claim that she tried to make him touch her. And while her comments were “explicit and crude,” courts have regularly found similar remarks do not prevent an employee “from succeeding in the workplace.”

Regarded as disabled. Turning to his ADA claim, the court found that sufficient evidence suggested the principal regarded his perceived drug use as an impairment. Specifically, she took issue with his decision to approve a social media post involving the high school and, blamed his perceived cocaine use, told him that he had a “mental issue” and had been “acting psycho,” and threatened to fire him if he did not attend the EAP. These “alleged comments and accompanying actions signal that she believed [his] perceived drug use impaired his mental function and ability to perform his job.”

No adverse action. However, his ADA claim failed since his mandatory referral to the EAP did not constitute an adverse employment action. Significantly, he did not allege “any negative consequences accompanied his program referral other than the minor inconvenience of time.” Indeed, he testified that the referral was no more than a trivial annoyance, explaining that the EAP counselor cleared him to return to work after speaking with him for only a few minutes.

The case is No. 23-0857.

Judge: Van Hook, A.

Attorneys: Kendrick Terrell Golatt, Sr., pro se. Brian Ross Carnie (Kean Miller) for School Board of Caddo Parish.

Companies: School Board of Caddo Parish

Cases: SexualHarassment SexDiscrimination DisabilityDiscrimination Discrimination Covid19 LouisianaNews