Lawsuit Roanoke County Schools

Case 7:20-cv-00663-TTC Document 1 Filed 11/11/20 Page 1 of 18 Pageid#: 1
IN THE UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF VIRGINIA
ROANOKE DIVISION
ERIN LEA BARNETT,
Plaintiff,
Civil Action No: 7:20cv663
v.
ROANOKE COUNTY SCHOOL BOARD,

d/b/a “ROANOKE COUNTY PUBLIC
SCHOOLS”,
JURY TRIAL DEMANDED
Serve:
Mike Wray, Chairman

David M. Linden, Vice Chairman
Donald T. Butzer, Board Member
Tim Greenway, Board Member
Jason Moretz, Board Member
5937 Cove Road

Roanoke, Virginia 24019
Defendant.
COMPLAINT
The above-named Plaintiff, Erin Lea Barnett (hereinafter, “Plaintiff” or “Ms.
Barnett”), by counsel, states as her Complaint against Defendant Roanoke County
School Board, d/b/a “Roanoke County Public Schools” (hereinafter, “Defendant” or
“RCSB”), the following:
I. JURISDICTION AND VENUE
1. This Court has jurisdiction over this matter as it arises from the federal
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questions presented by Title VII of the Civil Rights Act of 1964, the Civil Rights Act of
1991 and the Lilly Ledbetter Fair Pay Act of 2009 (“Fair Pay Act”), as codified under 42
U.S.C. §§ 2000e, et seq. (“Title VII”).
2. Venue is appropriate, as the acts and/or omissions of RCSB from which the
causes of action arise, occurred in Roanoke County, Virginia, which is within the
Western District of Virginia. See 28 U.S.C. § 1391(b)(2).
3. Ms. Barnett timely filed a charge of discrimination with the U.S. Equal
Employment Opportunity Commission on or around January 6, 2020 (Charge No.
438-2020-00457) (hereinafter, “EEOC Charge”), received a Dismissal and Notice of
Rights from the U.S. Equal Employment Opportunity Commission, dated August 14,
2020, and files this action within 90 days of receipt of that notice. A copy of the Notice
of Right to Sue is attached hereto as EXHIBIT A.
II. THE PARTIES
4. Ms. Erin Lea Barnett is a resident of the City of Roanoke, Virginia.
5. RCSB is a school board organized under the laws of the Commonwealth of
Virginia that administers elementary and secondary education in public schools to
citizens of Roanoke County, Virginia.
6. Ms. Barnett was hired by RCSB on or about May of 2006 as a science teacher,
and has worked on a consistent, full time basis for RCSB for more than fourteen years.
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III. FACTUAL BACKGROUND
7. On or about June of 2018, and after a series of excellent work performance
reviews, Ms. Barnett applied for, and was promoted to, the position of Roanoke County
Public Schools Supervisor of Science.
8. The RCSB has divided internal departments into what are referred to as
“Instruction Departments”. These departments are supervised by an Instructional
Supervisor. All Instructional Supervisors report directly to the Director of Secondary
Instruction and Director of Elementary Instruction (as of 2019, referred to as
“Executive Directors”).
9. Above these Directors in the chain of command, is the Superintendent.
10. For purposes of chain of command, all Instructional Supervisor positions are
positioned at the same rung of the institutional ladder. Thus, all Instructional
Supervisors are considered peers such that no Instructional Supervisor is above or
below any other Instructional Supervisor within the chain of command.
11. RCSB initially offered Ms. Barnett an annual salary of $58,108.00 for her new
supervisory role. Ms. Barnett had previously earned a base salary of $48,533. She also
had earned additional compensation for: (1) teaching two online courses in the spring
semester and two online courses in the summer semester ($9,000); (2) a stipend for
serving as department chair ($867); and (3) additional compensation for teaching
summer school ($3,640) for a total of $62,040 in compensation. Accordingly, RCSB’s
offer represented a significant pay cut.
12. When Ms. Barnett requested that RCSB offer her a higher, and more
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comparable, salary, RCSB raised its offer to $60,851.90, but denied Ms. Barnett’s
request to continue teaching virtual courses and receive related stipend pay for this
additional work.
13. During these salary negotiations, current RCSB Human Resources Director Jim
Bradshaw – who, at the time was employed as an Assistant Director – informed Ms.
Barnett that $60,851.90 was “as high as we can go” with regard to her salary, despite
the Instructional Supervisor position’s increased time requirements and responsibility
requirements in contrast to Ms. Barnett’s former position. Ms. Barnett had worked a
200-day teaching contract requiring 7.33 hours of work per day for a total of 1,466
hours per year. As an Instructional Supervisor, Ms. Barnett works a 240-day contract
which requires 8 hours per day, resulting in an increase of 454 working hours per year
in contrast to her teaching position.
14. Ms. Barnett believed Mr. Bradshaw’s representations, ultimately agreed to the
reduced salary, and accepted the Supervisor of Science position.
15. Accordingly, while RCSB paid Ms. Barnett a salary of $69,526.60 in 2018, her
total 2019 salary, following her promotion - - which included a modest percentage raise
offered to other similarly situated RCSB employees - - had been reduced to
approximately $62,029.33.
A. A Similarly Situated Male Employee is Paid More
16. During the same time period when Ms. Barnett accepted her new supervisory
role, in or about July of 2018, Kevin Burcham, a male RCSB health and physical
education teacher, was hired by RCSB for the position of Supervisor of Physical
4
Education.
17. Mr. Burcham’s position of Supervisor of Physical Education was considered an
Instructional Supervisor role.
18. Mr. Burcham’s education level and work experience were either similarly
qualified as those of Ms. Barnett or underqualified in comparison, and Ms. Barnett’s
new supervisory position required her to perform a more demanding role to that of Mr.
Burcham, as evidenced by their supervisory position descriptions, qualifications, skills,
and job responsibilities.
19. Ms. Barnett’s position required a mastery of much more sophisticated technical
knowledge than the position of Supervisor of Physical Education.
20.However, RCSB offered Mr. Burcham a salary of $62,601.84 for this role, which
was 20 days shorter annually than Ms. Barnett’s position, and permitted him to
continue to receive an additional $3,900.00 coaching stipend for the 2018-2019 school
year, thus creating a significant pay disparity between Mr. Burcham’s salary and Ms.
Barnett’s salary.
21. Of note, for the majority of the time at issue in this matter, the former RCSB
Supervisor of Physical Education remained on staff and shared certain supervisory
duties with Mr. Burcham. In contrast, Ms. Barnett maintains sole responsibility for her
Supervisor of Science duties, and Ms. Barnett is contracted for a 240-day work year,
while Mr. Burcham is contracted to work 220 days per year for RCSB. Thus, Mr.
Burcham’s pay per day is $284.55 while Ms. Barnett’s per day pay is $258.45.
22. Furthermore, RCSB’s failure to pay Ms. Barnett an equivalent salary to that
5
offered to her male colleague in 2018 – which caused an immediate eleven percent
(11%) salary gap between them – would consequently result in continued and increased
sex-based pay disparity during each subsequent year of their continued employment
with RCSB when accounting for percentage-based annual pay raises.
23. RCSB does not employ a specific “formula” or “bona fide seniority system” for
determining supervisory employee pay, which has led to inequity and discriminatory
subjectivity, including the disparate pay offered to Ms. Barnett.
24.Ms. Barnett disputes RCSB’s position to date that RCSB legitimately considered
differences in experience for educational, extracurricular, and after school activities
when making its salary decisions.
25. Ms. Barnett and Mr. Burcham possess nearly equivalent educational
backgrounds. Additionally, Ms. Barnett has significantly more teaching experience
than Mr. Burcham. Ms. Barnett taught summer school at Roanoke County Public
Schools for six years, as well as “homebound” and Saturday classes, served as a
Department Chair for five years, coached a tennis team and cheerleading squad,
worked as a Freshman Class and Green Club Sponsor, and created an online
curriculum for two separate courses for which she provided instruction from 2013 to
2018. Mr. Burcham, upon information and belief, lacks this significant and relevant
additional teaching experience.
26.However, RCSB chose to consider and incorporate into Mr. Burcham’s salary
his coaching stipends.
27. Simultaneously, RCSB chose to ignore and not incorporate into Ms. Barnett’s
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salary, her prior stipends.
28.Similarly, RCSB chose to scale Mr. Burcham’s (1) one additional year of teaching
and coaching experience to place Mr. Burcham five pay steps above Ms. Barnett.
29.RCSB also chose to ignore Ms. Barnett’s considerable contributions to RCSB.
In addition to the contributions noted supra, Ms. Barnett also works with RCSB faculty
during the summer months to prepare curriculum guides by holding in person and
online meetings, corresponding through email, updating curriculums on an online
platform, working with the printshop to format and print new curriculum guides, and
attending recurring meetings with RCPS supervisory employees. In addition, Ms.
Barnett works certain weekend days during the school year without additional
compensation.
30.Mr. Burcham and Ms. Barnett also work throughout the summer months, but
Ms. Barnett works many more days than Mr. Burcham. Both Ms. Barnett and Mr.
Burcham are responsible for hiring faculty for summer instruction, attend teacher
workdays, and manage the initial week of summer classes for RCPS.
31. Further, Ms. Barnett was required to seek initial negotiation of her lower salary
while Mr. Burcham merely accepted RCSB’s initial offer of salary.
B. Ms. Barnett Highlights Disparate Pay and Attempts to Re-Negotiate
32. On or about April 1, 2019, Ms. Barnett spoke with Mr. Bradshaw. During this
meeting, Ms. Barnett discussed with Mr. Bradshaw the fact that, although Ms. Barnett
and Mr. Burcham were both promoted to their supervisory positions prior to the 2018-
2019 academic year, Mr. Burcham was placed approximately five “pay steps” above Ms.
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Barnett, despite their similar educational background and teaching experience, and
Ms. Barnett’s additional six years of experience as a Department Chairperson, a
summer school instructor, and five years teaching virtual coursework. Ms. Barnett told
Mr. Bradshaw in no uncertain terms that this pay disparity was inequitable.
33. During the April 1, 2019 meeting, Mr. Bradshaw advised Ms. Barnett that he
would take her concerns under consideration and discuss the matter with other Human
Resources personnel, including his direct supervisor. A mere two days later, on or
about April 3, 2019, Mr. Bradshaw emailed Ms. Barnett to inform her that RCSB would
not adjust her salary.
34. As a result, although Ms. Barnett’s 2019-2020 salary was raised to $63,206.78,
in accordance with RCSB policy and along with similar percentage raises for other
RCSB supervisory employees, Mr. Burcham continues to earn a disproportionately
higher salary than Ms. Barnett, despite the fact that Ms. Barnett maintains, at the very
least, equal responsibilities to those of her male counterpart.
35. Indeed, Ms. Barnett assumed significantly increased and elevated supervisory
responsibilities, and has excelled in her duties as Supervisor of Science. She maintains
a more rigorous schedule than that of Mr. Burcham, performs a substantially similar
role to other male RCSB supervisors, and provides similar value to RCSB. However,
Mr. Burcham currently makes an hourly wage of $36.94, while Ms. Barnett earns only
$32.92 per hour for her work for RCSB, per the terms of her 2019-2020 RCSB contract
– thus earning only approximately eighty-nine percent (89%) of the salary paid to Mr.
Burcham.
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C. Despite Differences in Subject Area, Ms. Barnett Shares Dozens of

Duties with her Comparator
36. Although Ms. Barnett and Mr. Burcham work in different subject areas, given
their positions within the administration, the similarities in their day-to-day work
performance renders Mr. Burcham as “similarly situated” to Ms. Barnett pursuant to
Title VII of the Civil Rights Act.
37. The following is a non-exhaustive list of identical tasks and job-related duties
shared by both Ms. Barnett and Mr. Burcham:
1. Attend supervisor meetings (monthly);
2. Attend elementary principal meetings (monthly);
3. Attend secondary principal meetings (monthly);
4. Host elementary representative meetings (monthly);
5. Host secondary department chair meetings (monthly);
6. Determine elementary content allotment money for 16 schools (yearly);
7. Determine secondary content allotment money for 10 schools (yearly);
8. Manage elementary instruction budget for content area;
9. Manage secondary instruction budget for content area;
10. Manage inventory for a section of the county warehouse;
11. Determine which equipment/supplies will be turned over to surplus
and set the bidding restrictions for those items;
12. Manage deliveries/pickups of items from warehouse to schools and vice
versa;
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13. Host elementary new teacher professional development (yearly);
14. Host secondary new teacher professional development (yearly);
15. Observe and mentor new teachers (at least one meeting per new teacher
per nine weeks);
16. Visit a required number of schools on the first day of school and report
back to the superintendent at a supervisor meeting;
17. Write a weekly report of department progress to turn in to
supervisors (same immediate supervisors) – the Executive Director of
Elementary Education and the Executive Director of Secondary
Instruction;
18. Achieve the satisfaction of Smart Goals each year with identical
parameters;
19. Meet with supervisors at the beginning of the year to review and discuss
smart goals;
20.Meet with supervisors at the end of the year to review and discuss smart
goals and work performance evaluation;
21. Review of work performance evaluation documentation that is identical
between Ms. Barnett and Mr. Burcham;
22. Meet with supervisors in the fall to go over previous year’s content area
budget;
23. Approve and monitor any teacher work performed outside of contract
hours for extra pay (sign and process timesheets);
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24.Work with the Director of Operations to resolve issues with classrooms
and equipment that is not content related (examples: tables, chairs,
lights, windows, etc.);
25. Field parent questions about course selections;
26.Field parent concerns/complaints about instruction, curriculum,
teachers, textbooks, projects, etc.;
27. Set up and run outside of school events that are content related – for
example, safe driving nights for parents and students, astronomy night
for students and parents, science fair nights, County Science fair, etc.;
28.Attend any school board meetings that discuss matters related to a
specific content area;
29.Read and stay abreast of school board meetings and decisions;
30.Work with local organizations to set up field trips;
31. Work with local individuals and organizations to set up guest speakers;
32. Plan professional development for Roanoke County teachers;
33. Provide teachers with professional development opportunities
throughout the year;
34. Meet with content specific state leaders and other supervisors (twice
per year);
35. Attend science/PE teacher conference (once per year);
36. Work with HR on staffing to determine which teachers will travel,
move, teach an extra class, etc.;
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37. Log into TalentEd on a regular basis to check for teacher applications
for content area;
38.Determine which candidates to bring in for screening interviews;
39. Perform screening interviews;
40.Set up second interviews with principals;
41. Attend second (sometimes third) interview with principals;
42.Work with Human Resources on any licensure issues with potential
hires;
43. Attend job fairs to recruit new teachers;
44.Help find long-term substitutes when needed;
45. Visit the same twenty-six schools to check on teachers, monitor
progress, help with trouble-shooting, mentor new teachers, build
relationships, observe instruction, etc.;
46.Administer multiple AP tests;
47. Administer state bilingual testing (yearly);
48.Chaperone field trips;
49.Work with finance department on any audit questions;
50.Check teacher schedules and class numbers on Synergy database;
51. Work with textbook manager to run a textbook adoption;
52. Meet with sales reps to learn about new education products, textbooks,
equipment, etc.;
53. Complete numerous books studies – including reading the same book,
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participation in the same meetings, required responses in the same
discussion board;
54. Attend the same professional development meetings during the year;
55. Attend a two-day administrative retreat in the summer;
56. Review all summer school applications;
57. Hire the required number of teachers for summer school based on
enrollment;
58.Train new summer school teachers;
59. Attend summer school meetings;
60.Attend the first few days of summer school to work out any problems
that arise;
61. Manage the Learning Resource Zone content for content area;
62.Work with teachers to update curriculum guides, suggested pacing
guides, and resources for instruction;
63. Work with teachers to create and update Deeper Learning Experiences;
64.Work with teachers to create and update performance assessments;
65. Work with teachers to create hybrid and online lessons for COVID-
related instructional changes;
66.Evaluate curriculum guides;
67. Supervise online classes;
68.Support teachers to improve teacher retention;
69.Work with struggling teachers as requested by principals on
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classroom management, relationships with parents, Blackboard
organization, Synergy grade system, grading, and student engagement;
70. Attend multiple COVID-related meetings about the instructional plan;
71. Provide data and feedback on the strategic plan annually;
72. Work with the print shop to update/edit/format/print content specific
documents that get distributed district wide – for example, safety
contracts, curriculum guides;
73. Stay updated on state requirements and changes to the requirements;
74. Complete the same series of beginning of the year Human Resources
training (yearly);
75. Spend five hours per week helping a particular school on COVID-
related tasks to support teachers and staff;
76. Attend multiple graduation ceremonies per year;
77. Run Little Feet Meet Event (special Olympics – one day per year);
78. Update course descriptions in course offering guide (annually); and
79. Work with school counselors on student scheduling, prerequisites,
course changes, etc.
D. State and National Salary Comparisons Show that Science Educators

are Paid More than Physical Education Educators in Contradiction
to Roanoke County School Board’s Pay Scheme
38.A national jobs marketplace conducted a state-by-state survey of educators by
subject area. School employees in the subject of Science earned an average hourly rate
and yearly salary higher than school employees in the subject of physical education
14
within the Commonwealth of Virginia. Moreover, the trend of paying science
educators a higher rate than physical education educators exists state by state on a
national scale. RCSB’s pay scheme contradicts the state and national salary trends
without valid support or evidence to justify the deviation.
39. There exists no legitimate reason for RCSB to pay Ms. Barnett less than her
similarly situated co-worker, Mr. Burcham, particularly when the sole differentiating
factor between the positions is that Ms. Barnett’s position requires the application of
advanced scientific knowledge.
40.Ms. Barnett is female and protected from sex discrimination by Title VII of the
Civil Rights Act, as amended, and which prohibits sex-based wage discrimination
between men and women in the same establishment who perform jobs that require
similar skill, effort, and responsibility under similar working conditions. Upon
information and belief, RCSB has unlawfully instituted discriminatory pay practices
whereby male employees are treated preferably and paid more than female employees
in an equivalent position, discriminated against Ms. Barnett based upon her sex, and
failed to appropriately act when Ms. Barnett complained about RCSB’s disparate pay
practices, all in violation of Title VII of the Civil Rights Act.
41. Ms. Barnett has performed her duties faithfully, diligently, and with competence
during the entire length of her employment with RCSB and her work performance has
met RCSB’s legitimate expectations of her.
42.The pay differential between Ms. Barnett and Mr. Burcham was not due to
seniority, merit, or a factor other than sex, but was due to Ms. Barnett’s sex, and RCSB
15
would not have subjected Ms. Barnett to discriminatory pay, but for Ms. Barnett’s sex.
Alternatively, Ms. Barnett’s sex was a motivating factor in RCSB’s actions.
43. RCSB has discriminated against Ms. Barnett by treating her differently from,
and less preferably than, a similarly situated male employee, and subjecting her to
discriminatory pay on the basis of her sex. RCSB’s policies, practices, and/or
procedures have created a discriminatory work environment and have resulted in a
disparate impact on Ms. Barnett with respect to the terms and conditions of her
employment, and have caused and/or contributed to wage rate discrimination based
upon gender, in violation of federal law. RCSB has violated Title VII of the Civil Rights
Act of 1964, as amended by the Civil Rights Act of 1991, as codified under 42 U.S.C. §§
2000e, et seq. (“Title VII”).
IV. CLAIMS
COUNT I: SEX DISCRIMINATION/SEX-BASED WAGE

DISCRIMINATION PURSUANT TO TITLE VII
44.Ms. Barnett incorporates by reference herein the preceding paragraphs of this
Complaint.
45. Ms. Barnett is a female and is protected from sex discrimination by Title VII.
46.RCSB has discriminated against Ms. Barnett by treating her differently from and
less preferably than similarly situated male employees and subjecting her to
discriminatory pay, discriminatory denials of pay raises, and other differential
treatment on the basis of her sex.
47. Ms. Barnett was not paid compensation equal to the compensation paid to male
employees of equal skill, effort, and responsibility.

16
48.RCSB’s policies, practices, and/or procedures have had a disparate impact on
Ms. Barnett with respect to the terms and conditions of her employment.
49.RCSB violated federal law by permitting a work environment to exist that was
discriminatory to Ms. Barnett.
50.RCSB would not have subjected Ms. Barnett to discriminatory pay,
discriminatory denials of pay raises, or taken the other discriminatory actions against
Ms. Barnett but for Ms. Barnett’s sex. Alternatively, Ms. Barnett’s sex was a motivating
factor in RCSB’s actions.
51. Because the actions of RCSB supervisory employees were taken within the scope
of their employment, RCSB is responsible for their actions based upon the doctrine of
respondeat superior.
52. As a direct and proximate result of the actions of RCSB, Ms. Barnett has suffered
and will continue to suffer pecuniary loss, emotional pain, suffering, inconvenience,
mental anguish, loss of enjoyment of life and other non-pecuniary loss.
53. At all times material hereto, RCSB engaged in a discriminatory practice or
practices with malice or reckless indifference to the federally protected rights of Ms.
Barnett.
54. The above-described acts by RCSB constitute discrimination in violation of Title
VII of the Civil Rights Act of 1964, as amended by the Civil Rights Act of 1991, as
codified under 42 U.S.C. §§ 2000e, et seq. (“Title VII”).
17
WHEREFORE, Plaintiff Erin Lea Barnett prays for judgment against Defendant
Roanoke County School Board, d/b/a “Roanoke County Public Schools” and for
equitable relief, compensatory damages, back pay, front pay, together with
prejudgment interest from the date Ms. Barnett began working as the Roanoke County
Public Schools Supervisor of Science, and for costs and attorneys’ fees, and for such
other and further relief as may be just and equitable.
TRIAL BY JURY IS DEMANDED.
Respectfully submitted,
/s/ Thomas E. Strelka______________

Thomas E. Strelka, Esq. (VSB# 75488)
L. Leigh R. Strelka, Esq. (VSB # 73355)
N. Winston West, IV, Esq. (VSB #92598)
Brittany M. Haddox, Esq. (VSB # 86416)
Monica L. Mroz, Esq. (VSB #65766)
STRELKA EMPLOYMENT LAW
119 Norfolk Avenue, S.W., Suite 330
Warehouse Row
Roanoke, VA 24011
Tel: 540-283-0802
thomas@strelkalaw.com
leigh@strelkalaw.com
winston@strelkalaw.com
brittany@strelkalaw.com
monica@strelkalaw.com
Counsel for Plaintiff
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Case 7:20-cv-00663-TTC Document 1 Filed 11/11/20 Page 1 of 18 Pageid#: 1

IN THE UNITED STATES DISTRICT COURT

ERIN LEA BARNETT,

ROANOKE COUNTY SCHOOL BOARD,

Mike Wray, Chairman

5937 Cove Road

The above-named Plaintiff, Erin Lea Barnett (hereinafter, “Plaintiff” or “Ms.

Barnett”), by counsel, states as her Complaint against Defendant Roanoke County

School Board, d/b/a “Roanoke County Public Schools” (hereinafter, “Defendant” or

“RCSB”), the following:

I. JURISDICTION AND VENUE

U.S.C. §§ 2000e, et seq. (“Title VII”).

Western District of Virginia. See 28 U.S.C. § 1391(b)(2).

Employment Opportunity Commission on or around January 6, 2020 (Charge No.

438-2020-00457) (hereinafter, “EEOC Charge”), received a Dismissal and Notice of

of Right to Sue is attached hereto as EXHIBIT A.

II. THE PARTIES

4. Ms. Erin Lea Barnett is a resident of the City of Roanoke, Virginia.

5. RCSB is a school board organized under the laws of the Commonwealth of

Virginia that administers elementary and secondary education in public schools to

citizens of Roanoke County, Virginia.

III. FACTUAL BACKGROUND

7. On or about June of 2018, and after a series of excellent work performance

Public Schools Supervisor of Science.

“Instruction Departments”. These departments are supervised by an Instructional

Supervisor. All Instructional Supervisors report directly to the Director of Secondary

Instruction and Director of Elementary Instruction (as of 2019, referred to as

9. Above these Directors in the chain of command, is the Superintendent.

Supervisors are considered peers such that no Instructional Supervisor is above or

below any other Instructional Supervisor within the chain of command.

summer school ($3,640) for a total of $62,040 in compensation. Accordingly, RCSB’s

offer represented a significant pay cut.

the Instructional Supervisor position’s increased time requirements and responsibility

in contrast to her teaching position.

reduced salary, and accepted the Supervisor of Science position.

offered to other similarly situated RCSB employees - - had been reduced to

A. A Similarly Situated Male Employee is Paid More

17. Mr. Burcham’s position of Supervisor of Physical Education was considered an

Instructional Supervisor role.

qualified as those of Ms. Barnett or underqualified in comparison, and Ms. Barnett’s

Burcham, as evidenced by their supervisory position descriptions, qualifications, skills,

and job responsibilities.

knowledge than the position of Supervisor of Physical Education.

Supervisor of Physical Education remained on staff and shared certain supervisory

with RCSB when accounting for percentage-based annual pay raises.

subjectivity, including the disparate pay offered to Ms. Barnett.

differences in experience for educational, extracurricular, and after school activities

when making its salary decisions.

backgrounds. Additionally, Ms. Barnett has significantly more teaching experience

additional teaching experience.

his coaching stipends.

salary, her prior stipends.

29.RCSB also chose to ignore Ms. Barnett’s considerable contributions to RCSB.

online meetings, corresponding through email, updating curriculums on an online

attending recurring meetings with RCPS supervisory employees. In addition, Ms.

while Mr. Burcham merely accepted RCSB’s initial offer of salary.

B. Ms. Barnett Highlights Disparate Pay and Attempts to Re-Negotiate

Ms. Barnett’s additional six years of experience as a Department Chairperson, a

not adjust her salary.

RCSB supervisory employees, Mr. Burcham continues to earn a disproportionately

least, equal responsibilities to those of her male counterpart.

C. Despite Differences in Subject Area, Ms. Barnett Shares Dozens of

performance renders Mr. Burcham as “similarly situated” to Ms. Barnett pursuant to

Title VII of the Civil Rights Act.