Taylor-Travis v. Jackson State University, No. 17-60856 (5th Cir. 2021)Annotate this Case
After the University terminated her employment as the head coach of the women's basketball team, plaintiff filed suit alleging violations of Title VII of the Civil Rights Act of 1964 and Title IX of the Education Amendments of 1972, as well as state-law claims for breach of contract, breach of the implied covenant of good faith and fair dealing, and invasion of privacy.
The Fifth Circuit affirmed the district court's judgment as to the breach of contract and Title IX claims. The court concluded that judgment in favor of plaintiff on the breach of contract claim was proper where a reasonable jury could have concluded that plaintiff's management of funds did not give the University cause to terminate her employment. Furthermore, the University was not entitled to a new trial on plaintiff's breach of contract claim. In this case, the district court did not abuse its discretion in refusing to provide the requested jury instruction and any error on the district court's part was harmless. In regard to the Title IX claim, the court concluded that denial of plaintiff's jury instruction was not an abuse of discretion or grounds for a new trial. However, the court reversed the district court's judgment as to the privacy claim and concluded that it failed as a matter of law. The court explained that the facts disclosed by the University were of legitimate concern to the public and the district court clearly erred in concluding otherwise.