IN THE UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF VIRGINIA

BIG STONE GAP DIVISION

JAMES ADAMS, )
)
Plaintiff, )
) Civil Action No. 2:19cv33
v. )
)
SCHOOL BOARD FOR THE CITY OF )
NORTON, VIRGINIA )
)
Defendant. )

RESPONSE IN OPPOSITION TO MOTION FOR TEMPORARY INJUNCTION

Defendant, School Board for the City of Norton, Virginia, by counsel, submits its

response in opposition to the plaintiff’s motion for temporary injunction.

STATEMENT OF THE CASE

Plaintiff, James Adams, filed suit against the School Board for the City of Norton,

Virginia (“School Board”), asserting that the School Board deprived him of his Fourteenth

Amendment procedural and substantive due process rights in his employment and violated

Virginia Code § 22.1-315 by suspending him from his employment as a teacher and football

coach with the School Board during the pendency of an ongoing investigation into complaints

about Mr. Adams’ conduct toward students. The plaintiff filed a combined Complaint and

Motion for Temporary Injunction, seeking both temporary and permanent injunctions, enjoining

the School Board from suspending him from his employment, and an award of his attorney’s

fees.

The plaintiff filed suit in the Circuit Court for the County of Wise on or about July 30,

2019, and the School Board was served on or about August 5, 2019. Because the plaintiff states

claims under the Fourteenth Amendment, for which this Court has original jurisdiction, the case

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was removed to this Court on August 19, 2019. The School Board has not filed a response to the

Complaint as of the date of this filing.

STATEMENT OF FACTS

Mr. Adams is employed as a licensed teacher under continuing contract status with the

School Board for the City of Norton and is also under separate contract to serve as the head

coach of the football team. Compl. ¶¶ 4-5. On June 5, 2019, Superintendent Gina Wohlford

recommended that the School Board not renew Mr. Adams’ coaching contract. Id. ¶ 8. The

School Board considered this recommendation on June 10, 2019. Id. ¶ 10. At this meeting, two

former high school students spoke during the public comments section of the meeting to voice

opposition to the renewal of Mr. Adams’ coaching contract and to complain of his conduct

toward them. Id. ¶ 11. Nonetheless, the School Board voted 5-0 to renew his coaching contract.

Id. ¶ 12.

The comments of the two former students during public comment opened a wellspring of

complaints. After the June 10, 2019, School Board meeting, one former student filed a formal

complaint against Mr. Adams with the Administration, alleging that Mr. Adams harassed that

student. At least one parent communicated a complaint of harassment by Mr. Adams. Former

students also alleged on social media that Mr. Adams sexually harassed them. Administration

received a report from the Executive Director of the Family Crisis Support Services Center, a

community advocacy center in Norton, that numerous students and parents contacted the center

to complain about sexual harassment by Mr. Adams. The Executive Director of the Center

reported that she anticipated that some of those students would file formal complaints of sexual

harassment with the Division. The Administration was contacted by local law enforcement to

report that a similar complaint against Mr. Adams had been filed with the Norton Police

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Department, and the Administration confirmed that the Virginia State Police (VSP) received

multiple complaints, prompting an active investigation by the VSP. Declaration of Dr. Gina

Wohlford (hereinafter “Wohlford Decl.”), ¶ 10, attached as Exhibit A.

Because of the multitude of complaints against Mr. Adams, the School Board retained the

services of Chief Timothy Longo – a former police chief and a third party neutral investigator –

to conduct an investigation into the complaints and prepare a formal report of his findings and

recommendations to the School Board in order to comply with the Division’s Title IX

obligations. Mr. Adams was advised of the nature of the investigation and the multitude of

complaints by letter dated June 24, 2019. At that time, Mr. Adams was placed on administrative

suspension with pay pursuant to Virginia Code § 22.1-315 because the allegations of misconduct

raised concerns of threats to the safety and welfare of the school division and its students.

Wohlford Decl. ¶ 11.

Mr. Adams was provided with written notice of the reasons for his suspension and the

Superintendent’s belief that the suspension would extend beyond five days. Wohlford Decl. ¶

12. He was also provided with written notice of his right to a hearing before the School Board

on his suspension and copies of the School Board’s policies that were implicated by the

complaints of sexual harassment. Id. ¶ 13.

On July 22, 2019, the School Board held a hearing on Mr. Adams’ suspension, at which

Mr. Adams and his counsel attended and presented his reasons in opposition to his suspension to

the Board. Id. ¶ 14. During this hearing, Dr. Wohlford informed Mr. Adams and the School

Board that in the days following the June 10, 2019, School Board meeting, Administration was

made aware of additional allegations of conduct that may constitute sexual harassment by Mr.

Adams directed at female students, including a formal complaint by a former student, complaints

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communicated by two parents, and specific complaints by several students made on social

media. She reported that the allegations generally describe conduct by Mr. Adams of singling out

female students in the presence of peers and making comments about the female students’

physical characteristics. Additionally, Dr. Wohlford reported that she had spoken to the

Executive Director of Family Crisis Support Services Center in Norton, who reported the Center

had received complaints from numerous current and former students complaining of conduct by

Mr. Adams. Dr. Wohlford also informed the School Board and Mr. Adams of the active police

investigations and of recent additional complaints made with the Virginia Board of Education.

Wohlford Decl. ¶ 16.

During Mr. Adams’ hearing before the School Board, Dr. Wohlford reported to the

School Board and to Mr. Adams that because of the need to perform a full investigation, to

prevent any actual or perceived acts of retaliation against interviewees or interference with the

investigation, and to take measures to protect our students, the best interests of all parties would

be served if Mr. Adams remains suspended with pay and relieved of assigned duties pending the

final outcome of the investigation, which she anticipated taking longer than 60 days. Wohlford

Decl. ¶¶ 17, 18.

Under Virginia Code § 22.1-315, the Superintendent can only suspend a teacher for up to

60 days; however, the School Board has the authority to suspend a teacher beyond 60 days. Dr.

Wohlford recommended to the School Board that it continue Mr. Adams' suspension beyond 60

days if necessary to permit the investigation to be completed and its findings and conclusions

reported to her. Wohlford Decl. ¶ 18. The School Board voted to continue Mr. Adams’

suspension with pay for the duration of the current ongoing investigation, and Mr. Adams

received written notice of the School Board’s decision. Id. ¶ 19.

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 The decision to suspend Mr. Adams with pay is based on good and just cause pursuant to

Virginia Code § 22.1-315 because the safety or welfare of the school division and its students is

threatened by Mr. Adams’ continued presence at the schools during the ongoing investigations.

The allegations involve sexual misconduct directed at female students, which, if substantiated,

may create a hostile educational environment for the Division’s students. Id. ¶ 20.

The decision to suspend Mr. Adams was also made, in part, with knowledge of Mr.

Adams’ employment history with the School Board, which included multiple investigations for

misconduct, including allegations of sexually harassing/bullying/abusing students (see Wohlford

Decl. ¶¶ 3-5, 7) and Mr. Adams’ history of interfering with an active child abuse investigation

(id. ¶ 6).

Chief Longo’s investigation into the complaints against Mr. Adams continues. Thus far,

the investigator has interviewed 27 people, including students, parents, current and former staff

members, and Mr. Adams. Administration has not participated in those interviews, and the

investigator has not yet shared his findings with Dr. Wohlford. Wohlford Decl. ¶ 21.

Dr. Wohlford’s decisions to suspend Mr. Adams and to recommend that the Board

continue his suspension until the investigation is concluded were based solely on her concerns

for the safety and welfare of the students that Mr. Adams has been contracted to teach, Mr.

Adams’ past history of attempting to manipulate witnesses to interfere in an active child abuse

investigation, and concerns of retaliation for students, teachers, and staff that participate in the

active investigation. Wohlford Decl. ¶ 22.

Mr. Adams asserts that his suspension cost him the opportunity to perform his coaching

contract for which he claims irreparable harm in that he will be deprived of the pre-season and

season with the football players he coaches. Compl. ¶¶ 31-32.

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 ARGUMENT
I. STANDARD

Under Rule 65 of the Federal Rules of Civil Procedure, a court may issue a preliminary

injunction after notice has been provided to an adverse party. Fed. R. Civ. P. 65. “The standard

for granting either a [temporary restraining order] or a preliminary injunction is the same.”

Sarsour v. Trump, 245 F.Supp.3d 719, 728 (E.D. Va. 2017). Like a preliminary injunction, a

temporary restraining order is an ‘extraordinary remed[y] involving the exercise of a very far-

reaching power to be granted only sparingly and in limited circumstances.” Id.; Georgia

Vocational Rehab. Agency Bus. Enter. Program v. United States, 354 F. Supp. 3d 690, 693 (E.D.

Va. 2018).

A plaintiff seeking a preliminary injunction must establish that he is likely to succeed on

the merits, that he is likely to suffer irreparable harm in the absence of preliminary relief, that the

balance of equities tips in his favor, and that an injunction is in the public interest. Winter v. Nat.

Res. Def. Council, Inc., 555 U.S. 7, 20, 129 S. Ct. 365, 374, 172 L. Ed. 2d 249 (2008); see Munaf

v. Geren, 553 U.S. 674, 689 – 690, 128 S.Ct. 2207, 2218–2219, 171 L.Ed.2d 1 (2008). A party's

failure on any element precludes injunctive relief from issuing. See Cantley v. W. Va. Reg'l Jail

& Corr. Facility Auth., 771 F.3d 201, 207 (4th Cir. 2014); Pashby v. Delia, 709 F.3d 307, 320-

21 (4th Cir. 2013) (each element of the test must be satisfied); Holbrook v. Univ. of Virginia, 706

F. Supp. 2d 652, 655 (W.D. Va. 2010) (same).

Because a preliminary injunction affords, on a temporary basis, the relief that can be

granted permanently after trial, the party seeking the preliminary injunction must demonstrate his

entitlement to relief by “a clear showing.” Real Truth, 575 F.3d at 345; Winter, 555 U.S. at 22.

The plaintiff cannot meet this burden.

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II. PLAINTIFF IS NOT LIKELY TO SUCCEED ON THE MERITS.

The plaintiff cannot show a likelihood of success on the merits because the plaintiff’s

suspension with pay does not violate the Fourteenth Amendment, Virginia Code § 22.1-315 does

not apply to supplemental contracts, and Virginia Code § 22.1-315 does not apply unless a

teacher is suspended for more than five days without pay.

As stated on the face of the Complaint, the plaintiff’s primary concern is that his

suspension prevents him from coaching football, not from performing his duties in the classroom

as a teacher. (Compl. ¶¶ 31-32.) Moreover, the plaintiff acknowledges on the face of the

Complaint that he has been suspended with pay pending the results of the investigation. (Id. ¶

14.)

Courts considering the issues raised by the plaintiff have held that the Fourteenth

Amendment is not implicated by an employee’s suspension. Payment in full under a contract of

employment satisfies any constitutionally protected property interest in employment, even if the

employee has been discharged without notice or hearing. Royster v. Bd. of Trustees of Anderson

Co. School Dist. No. 5, 774 F.2d 618, 621 (4th Cir.1985), cert. denied, 475 U.S. 1121, 106 S.Ct.

1638, 90 L.Ed.2d 184 (1985) (holding that “any constitutionally protected property interest

plaintiff had as a result of his employment contract has been satisfied by payment of the full

compensation due under the contract”); see also Fields v. Durham, 909 F.2d 94, 98 (4th

Cir.1990), cert. denied, 498 U.S. 1068, 111 S.Ct. 786, 112 L.Ed.2d 849 (1991); Huang v. Bd. of

Governors of the Univ. of North Carolina, 902 F.2d 1134, 1141–42 (4th Cir.1990).

The property interest at stake is the right to be paid under a contract of employment. The

right does not “extend to the right to possess and retain a particular job or to perform particular

services.” Hibbitts v. Buchanan Cty. Sch. Bd., 685 F. Supp. 2d 599, 602 (W.D. Va. 2010)

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(quoting Fields, 909 F.2d at 98). The protected right is embodied in the employee's continued

employment and “no deprivation exists so long as the employee receives ‘payment of the full

compensation due under the contract.’” Id. Therefore, suspending a public school employee with

pay does not interfere with the teacher's protected property right of a continuing contract.

Hibbitts, 685 F.Supp.2d at 603; Bowers v. Rector & Visitors of the Univ. of Va., 478 F.Supp.2d

874, 888 (W.D.Va.2007); Williams v. Charlottesville Sch. Bd., 940 F.Supp. 143, 146

(W.D.Va.1996); Earley v. Marion, 540 F. Supp. 2d 680, 688 (W.D. Va. 2008), aff'd, 340 F.

App'x 169 (4th Cir. 2009).

The plaintiff’s complaint is similar to the circumstances faced by the district court in

Schneeweis v. Jacobs. 771 F. Supp. 733, 737 (E.D. Va. 1991), aff'd, 966 F.2d 1444 (4th Cir.

1992). The plaintiff, Traci A. Schneeweis (“Schneeweis”), was employed by the Fairfax County

School Board as a health and physical education teacher. Separate and apart from her teaching

contract, Ms. Schneeweis entered into Supplemental Assignment to serve as head coach of the

girls varsity basketball team. Her employment as coach was renewed under successive contracts

each year. Under her Supplemental Assignment, Ms. Schneeweis was paid a stipend separate and

apart from the salary she earned as a physical education teacher. Id. at 735. Ms. Schneeweis

was temporarily suspended from her position as girls’ basketball coach, pending an investigation

by the Office of Human Relations into complaints that had been made about Ms. Schneeweis.

Ms. Schneeweis was paid the full stipend due under her Supplemental Assignment for the

season. Id. at 735–36. Following her suspension, Ms. Schneeweis brought suit for declarative,

injunctive, and monetary relief, claiming that her suspension violated her Fourteenth

Amendment rights. Id. at 736. She also made a pendant state law claim under Virginia Code §

22.1-315 and sought an injunction against her suspension. Id.

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 Ms. Schneeweis alleged that the School Board violated her rights to notice and a hearing

prior to her suspension. In dismissing her claim, the district court found that the plaintiff did not

have a right to notice and a hearing prior to her suspension because she did not have a property

interest implicated by the Fourteenth Amendment. Id. The district court held that a suspension

does not rise to an impairment of an employment interest. 1 Id. at 738.; see Johnson v. Morris,

903 F.2d 996, 999–1000 (4th Cir.1990) (holding that where an employee was suspended and not

discharged, that individual did not suffer an injury to an employment interest because he

remained employed). Because Ms. Schneeweis received the compensation owed to her under her

contract, she did not sustain any injury to an employment interest sufficient to implicate a

protected property interest. Her purported property interest in her Supplemental Assignment was

extinguished by the school board's payment of the full stipend due for the coaching season. Id.

Notably, the Court also found that the plaintiff’s claim did not invoke a substantive due

process violation because there is no fundamental right to coach basketball. Id. at 738.

The Court also disposed of her claim under Virginia Code § 22.1-315, finding that

Virginia Code § 22.1–315 governs the suspension of teachers and does not apply to supplemental

salary employees who have undertaken extra duties pursuant to supplemental assignments

separate and apart from their teaching contracts. Id. at 737.

1
The plaintiff erroneously cites Wilkinson v. Sch. Bd. of Henrico Cty., 566 F. Supp. 766 (E.D. Va. 1983) for the
proposition that an employee has a property interest in not being suspended from his job under Virginia law. See
Compl. ¶ 25. In Wilkinson, which involved the suspension of an employee without pay, the district court found that
it could not state, “that, standing alone, the failure to provide a pre-suspension hearing violated plaintiff's due
process rights.” Wilkinson, 566 F.Supp. at 770. Notably, even if Wilkinson had stood for the proposition stated by
the plaintiff, Wilkinson is not controlling precedent in either this district or in the Eastern District, which would have
overruled such a holding by implication in concluding that suspension with pay does not implicate a property
interest in the Schneeweis case eight years later. Furthermore, the Fourth Circuit’s holding in Johnson v. Morris
disposes of the issue, holding that a suspension does not impair an employment interest because the employee
remains employed during the suspension.

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 The plaintiff’s claims in this case are analogous to those of Ms. Schneeweis in that both

alleged property interest violations under the Fourteenth Amendment, both alleged violations of

Virginia Code § 22.1-315, and both asserted that they had a constitutional right to perform the

obligations under their contracts. For Ms. Schneeweis, it was to coach basketball; for Mr.

Adams, it is to coach football. Under the district court’s holding in Schneeweis, neither had a

fundamental right to coach athletic teams, and just like Ms. Schneeweis, Mr. Adams has failed to

state a claim for a Fourteenth Amendment constitutional violation or a violation of Virginia Code

§ 22.1-315.

Moreover, the Supreme Court of Virginia has addressed whether a school board

employee is entitled to a pre-suspension hearing under Virginia Code § 22.1-315. See Payne v.

Fairfax County School Board, 288 Va. 432, 764 S.E.2d 40 (2014). In Payne, the Court held that

a School Board is only required to provide a hearing to a school board employee if that employee

will be suspended more than five days without pay. In this case, Mr. Adams was suspended for

more than five days, but his suspension was with pay, and he was provided with a hearing before

the School Board on his suspension. He appeared with counsel at that hearing, and the School

Board decided that suspending Mr. Adams for a period of time in excess of 60 days to enable a

full and complete investigation of the complaints against him was appropriate. Any due process

rights to which Mr. Adams is entitled under Virginia Code § 22.1-315 were provided as required

by statute. Moreover, as Mr. Adams continues to receive his salary, he has not been deprived of

any property interest under the statute.

Because Mr. Adams cannot state a claim for a constitutional violation or a violation of

Virginia Code § 22.1-315 under the facts alleged, he is not likely to succeed on the merits.

Accordingly, his request for a temporary injunction should be denied.

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 III. PLAINTIFF WILL NOT SUFFER IRREPARABLE HARM IF A PRELIMINARY
INJUNCTION IS NOT GRANTED.

While deprivation of a constitutional right, even for a short period of time, constitutes

irreparable harm, the plaintiff has not made out a claim of a constitutional violation as stated

above. See Elrod v. Burns, 427 U.S. 347, 373, 96 S.Ct. 2673, 49 L.Ed.2d 547 (1976).

Moreover, Mr. Adams’ only stated claim of irreparable harm is his inability to perform

his coaching contract if his suspension continues indefinitely. Because football practice started

on August 1, 2019, and the first football game is on August 30, 2019, Mr. Adams asserts that he

will be irreparably harmed in that he will have lost the remainder of the football pre-season and

much of the football season with his football players. Compl. ¶¶ 30-32. Mr. Adams does not,

however, have the right to perform the obligations under his contract with the School Board. See

Hibbitts v. Buchanan Cty. Sch. Bd., 685 F. Supp. 2d 599, 602 (W.D. Va. 2010). Such “loss,”

therefore, does not constitute irreparable harm.

IV. BALANCE OF EQUITIES DOES NOT TIP IN PLAINTIFF’S FAVOR.

The plaintiff’s desire to coach football is not on par with the School Board’s decision to

conduct a comprehensive and fair investigation of serious allegations of sexual harassment by a

teacher and a coach against female students. Mr. Adams does not have a constitutional right to

coach football, but the Norton City students do have a constitutional right to bodily integrity that

is further protected by other federal and state laws. The balance of equities in this case tips

heavily in favor of permitting the School Board to perform its obligation under federal law to

conduct a thorough investigation of claims of sexual harassment against students.

V. AN INJUNCTION IS NOT IN THE PUBLIC’S INTEREST.

When evaluating whether to issue an injunction, a court “should pay particular regard for

the public consequences in employing the extraordinary remedy of injunction.” Winter, 555 U.S.

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 at 24, 129 S.Ct. 365; Georgia Vocational Rehab. Agency Bus. Enter. Program v. United States,

354 F. Supp. 3d 690, 693 (E.D. Va. 2018). Under the facts of this case, the public interest is

served by permitting the School Board to conduct a comprehensive and impartial investigation of

very serious allegations of sexual harassment by a teacher and coach against students. The

nature of the allegations of misconduct are such that they give rise to the very real possibility that

Mr. Adams, through his conduct, has created and will continue to create a hostile educational

environment. Mr. Adams’ exclusion from the classroom and the field during the pendency of the

investigation is necessary to protect the well-being of the students and the division, to protect

students and staff from concerns of retaliation, and to protect the impartiality and legitimacy of

the investigation from concerns of interference.

VI. NO AMOUNT OF BOND CAN PROTECT THE SCHOOL BOARD’S INTERESTS.

An injunction bond is effectively “the moving party's warranty that the law will uphold

the issuance of the injunction.” Edgar v. MITE Corp., 457 U.S. 624, 649, 102 S.Ct. 2629, 73

L.Ed.2d 269 (1982) (Stevens, J., concurring). The burden of establishing the bond amount rests

with the party to be restrained, who is in the best position to determine the harm it will suffer

from a wrongful restraint. Philips Electronics N. Am. Corp. v. Hope, 631 F.Supp.2d 705, 724 n.

14 (M.D.N.C.2009); Int'l Equity Investments, Inc. v. Opportunity Equity Partners Ltd., 441

F.Supp.2d 552, 566 (S.D.N.Y.2006) ( “[T]he burden is on the party seeking security to establish

a rational basis for the amount of the proposed bond.”), aff'd, 246 Fed.Appx. 73 (2d Cir.2007).

Given the nature of the allegations against Mr. Adams, returning him to the classroom

and the field where he will have access to students and staff without first receiving confirmation

that the allegations against him are unfounded or unsubstantiated after a fair and comprehensive

investigation opens the School Board to untold potential liability arising under both federal and

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 state laws. Accordingly, the amount of an injunction bond cannot be set high enough to protect

the School Board’s interests in protecting the students in its charge.

CONCLUSION

For the foregoing reasons, defendant School Board for the City of Norton, Virginia,

requests that the motion for preliminary injunctive relief be denied and for such other and further

relief as the nature of this case requires and this court deems appropriate.

SCHOOL BOARD FOR THE CITY OF

NORTON, VIRGINIA

/s/ Jennifer D. Royer

Of Counsel

Jennifer D. Royer, Esq. (VSB #68099)

ROYER LAW FIRM, P.C.
1901 Denniston Ave, SW
PO Box 4525
Roanoke, Virginia 24015
540-788-2982 Telephone
540-675-4093 Facsimile
jroyer@royerlawfirm.com
Counsel for defendant

CERTIFICATE OF SERVICE

I hereby certify that on the 22nd day of August, 2019, I have electronically filed this
document with the Clerk of the Court using the CM/ECF system, which will send notification of
such filing to the following:

Steven R. Minor, Esq.

ELLIOTT LAWSON & MINOR, P.C.
110 Piedmont Ave., Suite 300
Bristol, Virginia 24201

Richard D. Kennedy, Esq.

Kennedy Law Office P.L.L.C.
P.O. Box 357
Wise, Virginia 24293

/s/ Jennifer D. Royer

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 Jennifer D. Royer, Esq. (VSB # 68099)
ROYER LAW FIRM, P.C.
1901 Denniston Avenue, S.W.
P.O. Box 4525
Roanoke, Virginia 24015
Phone: 540-778-2982
Fax: 540-675-4093
jroyer@royerlawfirm.com
Counsel for Defendant

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