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White Indiana Coach Fails to Establish Race Discrimination

William Groves worked as an athletic director for Adams High School in the South Bend Community School Corporation (District). He applied for a new district-wide position as the Corporation Director of Athletics. The District offered the job to Seabe Gavin, who interviewed well and was a good candidate to repair some strained relationships at issue for the District. According to the Superintendent, Groves interviewed poorly, seemingly boasting about firing 24 coaches during his tenure. There had also been some compliance issues during Grove's tenure at Adams. Groves sued the District, alleging a theory of reverse race discrimination in violation of Title VII. Groves asserted he was more qualified for the position. When the District merged the Corporation Director position into a Dean of Students/Athletics position at each of the four district high schools, Groves and Gavin each applied again. The District selected Gavin for one of the positions but did not select Groves. Groves added it to his complaint as well as a retaliation claim for eliminating his former athletic director position.

The Seventh Circuit Court of Appeals considered Groves’s claims and affirmed their dismissal. The court focused its inquiry on whether Groves showed the District lied about its reason for not hiring him and whether race discrimination was the true reason. Groves failed to persuade the court he was far more qualified than Gavin. On paper, Groves did seem to have more experience. However, the District explained that the applicants' performance during the interview process mattered greatly. The record showed Gavin outperformed Groves by a substantial amount in that process. There was no evidence that consideration of race impacted the District's decision to hire Gavin. Similarly, Groves interviewed poorly for the second position as reflected in rankings produced by the district; he ranked last among all nine applicants. Gavin, at that point, had an additional two years of experience and continued to interview well.