In Tyler v. Muscogee County School District, Edward Tyler was a white male bus driver for the Muscogee County School District who ended up being passed over twice for promotions that were instead given to a black female and a white female, respectively. Tyler believed that he was not given a promotion due to his race and gender, and he eventually filed a lawsuit pursuant to Title VII of the Civil Rights Act of 1964. The School District filed a motion for summary judgment, claiming that Tyler had not produced enough evidence to show that its decision was based on discrimination.
The court looked at the facts to see if Tyler had established a dispute of fact as to whether his employer discriminated against him. Tyler had been employed as a bus driver for the School District since 1976 and had a flawless driving record, with no reported accidents throughout his 38-year career. Tyler had a bachelors degree in business management from an online institution and had trained other School District drivers prior to the requirement that trainers be certified. In January and October 2012, Tyler applied for two positions that would have promoted him. The School District claimed that it chose other candidates for those positions based purely on their qualifications. To evaluate candidates for promotion, the School District would appoint a panel to interview the candidates, which then completed a written evaluation form that included assigning points in different categories relating to the position’s job duties. Although points were figured into the final decision, they were not the only important factor. The panel claimed to look at the totality of circumstances. Based on that, the panel made a recommendation to the Transportation Director, who might then affirm the panel’s decision and forward it to the School District’s Chief Operations Officer, the Superintendent, and the Human Resources Department. Finally, the recommendation would be sent to the School Board for final approval.