Gates v. Gadsden County School Board

In this Title VII anti-retaliation case, the circuit court granted summary judgment, holding Appellant’s status as a volunteer disqualified her from raising a Title VII claim and that she would be unable to establish that material adverse action had been taken against her. We reverse, finding Appellant’s status as a former employee qualifies her for Title VII protection from her former employer’s allegedly retaliatory postemployment actions.

Facts

Martha Gates (Appellant) was a schoolteacher in the Gadsden County School District. In 2004, she filed a Title VII discrimination suit against the…