Labor & Employment Law Daily Wrap Up, DISCRIMINATION—W.D. Wis.: High school principal failed to link discipline to bias, (Jul 13, 2026)

By George Basharis, J.D.

An independent investigation gave the school district an honest, nondiscriminatory basis for suspending the high school administrator and recommending her termination.

Sun Prairie Area School District did not violate Title VII by suspending a high school principal and recommending her termination because district officials honestly believed she had mocked students, disparaged employees, and repeatedly disregarded a coworker’s chosen name and pronouns. Although the principal denied the accusations and challenged the investigation, she offered no evidence that her race, color, or sex influenced the district’s decisions, a federal court in Wisconsin concluded (Coleman v. Sun Prairie School District, No. 25-cv-457-jdp (W.D. Wis. July 9, 2026)).

Misconduct investigation. The principal, an African American woman, had led Sun Prairie East High School since 2021. In 2024, the school district received a complaint that she had made inappropriate comments during an August staff convocation. The reported conduct included calling students derogatory names, raising her middle finger, and insulting an employee.

Sun Prairie Area School District retained an attorney to investigate the accusations. While that inquiry was pending, the district received a second complaint alleging that the principal had intentionally and repeatedly misgendered an employee. The district asked the attorney to investigate that allegation as well.

After interviewing several witnesses, including the principal, the investigator issued separate reports addressing the two complaints. The first concluded that the principal had mocked students performing a dance routine and referred to them using offensive terms. It also stated that she had participated in an inappropriate discussion about an employee’s body and personal hygiene, raised her middle finger to mock the need for sign language interpreters, and called another employee a “fat ass.”

The investigator determined that the conduct violated district policies requiring employees to treat students and staff with dignity and respect, create a welcoming environment, and demonstrate leadership. The report emphasized the principal’s responsibility to set an example for the school community.

The second report concluded that the principal had repeatedly used he/him pronouns for an employee who preferred they/them pronouns, despite knowing that preference. It also found that she had not used the employee’s chosen name. The investigator determined that this conduct also violated district policies requiring respectful treatment of staff.

Disciplinary decision. After reviewing the reports and consulting with legal counsel, the district superintendent suspended the principal without pay pending the school board’s decision on her employment. The suspension letter cited the investigator’s findings. The principal later learned that the district planned to recommend her termination. Because only the school board could terminate her employment, she could contest the recommendation at a board hearing or enter into a resignation agreement with the district. She chose to resign in exchange for severance pay and other benefits.

The principal subsequently asserted that Sun Prairie Area School District discriminated against her based on race, color, and sex by suspending her and forcing her to resign. She also maintained that supervisors and human resources failed to address her reports of discriminatory treatment. In evaluating the discrimination claims, the court assumed that the suspension and resignation adversely affected the terms or conditions of her employment. The remaining question was whether her race, color, or sex motivated either action. Because she lacked evidence directly connected to a protected characteristic, the principal relied on her denials of misconduct, alleged flaws in the investigation, comparisons with other employees, and positive employment history.

Honest belief. The principal denied making derogatory comments about students or employees or intentionally misgendering her coworker. Although those denials created a factual dispute over whether the conduct occurred, they did not raise a material question of discrimination. Title VII does not permit federal courts to reconsider the wisdom, fairness, or accuracy of an employer’s personnel decisions. The relevant question was whether Sun Prairie Area School District honestly believed its stated reasons for disciplining her, not whether she committed the reported misconduct.

Because the district officials who made the disciplinary decisions did not witness the conduct, they relied on the outside investigator’s findings. Title VII did not require them to repeat the investigation, independently assess each witness’s credibility, or prove the accusations. The principal offered no evidence that the district initiated the investigation in bad faith, viewed it as a sham, or did not genuinely rely on the reports. Consequently, her disagreement with their conclusions did not show that the district’s stated reasons concealed unlawful discrimination.

Investigation challenged. The principal challenged the investigation on three grounds: the investigator improperly credited witnesses who supported the accusations, the district lacked video evidence of the reported conduct, and a district official encouraged a witness to reconsider prior statements.

The investigator explained that four witnesses who corroborated the accusations were forthcoming and responsive, did not speculate, and had no apparent reason to fabricate their accounts. By contrast, the investigator found that the principal and four witnesses who supported her had limited recollections, gave terse or evasive answers, or had possible motives to take her side because some of the conduct had been attributed to them. The principal offered no evidence connecting those credibility assessments to her race, color, or sex. The lack of a recording also did not support an inference of discrimination because neither Title VII nor any identified district policy required video or audio evidence before discipline could be imposed.

Likewise, the witness-interference accusation lacked admissible support. The principal relied on an employee’s email stating that a district official had suggested disclosing anything the employee remembered differently from an earlier statement. But the principal lacked personal knowledge of the conversation, and the email was hearsay. She also failed to establish the official’s role, connect the email to the investigation, or show that the employee changed any statement. Moreover, the conversation occurred four days after the reports were issued and could not have influenced their findings.

Employee comparison. The principal also cited an email in which another employee complained about disruptive students and described one as “screeching like a monkey or something.” She contended that the district did not impose comparable discipline on that employee. Although more favorable treatment of a similarly situated employee outside a worker’s protected class can support a discrimination claim, the principal did not identify the employee’s race or sex or establish what discipline, if any, the employee received.

The conduct also differed in seriousness. A staff member’s complaint about disruptive students was not comparable to accusations that a principal publicly mocked students and employees, used derogatory terms, and disregarded a coworker’s chosen name and pronouns. The investigator also emphasized the principal’s leadership role and responsibility to model appropriate conduct. Moreover, the principal did not show that any official involved in disciplining her knew about the email. Therefore, the comparison did not support an inference of discriminatory intent.

Past performance. The principal further relied on her favorable employment history, arguing that the district acted unfairly because she had no prior misconduct. But she identified no progressive discipline policy that the district violated. Although positive performance may support a finding of pretext in some circumstances, the relevant inquiry focuses on an employee’s performance when the challenged action occurred. The principal offered no evidence that Sun Prairie Area School District retained employees accused of similar conduct because of their past performance. Consequently, her employment history did not suggest that the district’s stated reasons concealed discrimination.

The principal also cited an earlier complaint that the athletic director had made her feel targeted and uncomfortable during a meeting. However, she did not identify the remarks, connect them to her race, color, or sex, or show that the officials who disciplined her knew about the incident. Nor did the incident support a hostile work environment claim because she failed to identify conduct based on a protected characteristic that was sufficiently severe or pervasive to violate Title VII.

The case is No. 25-cv-457-jdp.

Judge: Peterson, J.

Attorneys: Renee Coleman, pro se. Lori Marie Lubinsky (Axley) for Sun Prairie Area School District.

Companies: Sun Prairie Area School District

Cases: Discrimination SexDiscrimination PublicEmployees RaceDiscrimination WisconsinNews