May 26, 2026|Franchise Frontlines
May 26, 2026 | United States District Court for the Southern District of Ohio | Slip Copy
Executive Summary
In a slip-copy decision, Judge Edmund A. Sargus, Jr. of the United States District Court for the Southern District of Ohio granted summary judgment for Groveport Madison Local School District in a discrimination and retaliation case brought by a substitute teacher who was formally employed by a public Educational Service Center but assigned to work at Groveport schools. The plaintiff alleged that Groveport discriminated against her based on sex, race, and age, and retaliated against her after she complained about allegedly unequal treatment. Groveport argued that the plaintiff could not establish the elements of her claims, that she lacked required qualifications for certain positions, that she had not identified similarly situated comparators, and that the district had legitimate, nondiscriminatory reasons for not returning her to the building-substitute role. The court found sufficient evidence, at the threshold stage, to treat Groveport as a joint employer for purposes of employment discrimination laws, but it still entered judgment for Groveport because the plaintiff could not establish discrimination, causation, or pretext.
Relevant Background
Vanessa Hayes-Williams worked as a substitute teacher through the Educational Service Center of Central Ohio, which contracted with Groveport Madison Local School District to provide substitute teaching services. During the 2022–2023 academic year, Hayes-Williams served as a building substitute, meaning she reported to the same Groveport school each day. She also held two limited assignments directly with Groveport: summer school teacher in 2022 and assistant volleyball coach in fall 2022.
Hayes-Williams alleged that Groveport treated her differently from younger Caucasian coworkers and denied her opportunities because of her sex, race, and age. Her complaint identified several alleged incidents, including denial of a test-administrator opportunity, lack of grading access, lack of compensation for Black History Month production work, exclusion from student-activity roles, nonselection for permanent positions, issues involving the head volleyball coach, and the district’s decision not to return her to the building-substitute list for the following academic year.
The parties focused on three incidents at summary judgment. First, Hayes-Williams asserted that the head volleyball coach excluded her from coaching activities, made derogatory comments, and ultimately relieved her of coaching duties, although Groveport maintained that Hayes-Williams received the full amount due under her limited-assignment contract. Second, she alleged that staff members were hostile to her and students during preparations for the school’s Black History Month production, and that another employee received payment for work on the event while she did not. Third, Groveport pointed to a stay-put incident during which Hayes-Williams allegedly directed a student to come to her classroom despite a schoolwide safety directive requiring students and staff to remain in place.
After the stay-put incident, Groveport sent Hayes-Williams home early but paid her through the end of the academic year. In August 2023, Groveport informed her that she would not be on the building-substitute list or return to the high school as a building substitute for the 2023–2024 academic year because the school had decided to move in a different direction. Groveport later explained that the decision reflected concerns about the stay-put violation, difficulty getting along with administrators and teachers, and conduct it viewed as exceeding the proper role of a substitute teacher.
Decision
The court first addressed Hayes-Williams’s discrimination claims under Title VII, the ADEA, and Ohio law. Because the plaintiff relied on indirect evidence, the court applied the familiar McDonnell Douglas burden-shifting framework. To establish a prima facie discrimination case, Hayes-Williams had to show that she belonged to a protected class, was qualified for the job, suffered an adverse employment decision, and was replaced by someone outside her protected class or treated differently than similarly situated non-protected employees.
The court found that Hayes-Williams abandoned her discrimination claims by failing to respond to Groveport’s arguments on those claims. Still, the court reviewed Groveport’s record submission and concluded that Groveport had shown the absence of a triable issue. The court credited Groveport’s evidence that Hayes-Williams lacked the required credentials for full-time teacher or principal positions, that Ohio law required certain extracurricular positions to be offered first to qualified district employees, and that the employee who received payment for audiovisual work on the Black History Month production was paid under an existing limited-assignment contract as auditorium manager. On that record, the court held that Hayes-Williams could not establish a prima facie case of sex, race, or age discrimination.
The retaliation claim required more analysis because it raised the joint-employer issue. Groveport argued that it did not terminate Hayes-Williams because she was not a Groveport employee and remained eligible to work as a substitute through the Educational Service Center. The court rejected that threshold argument. Although neither party framed the issue under the joint-employer doctrine, the court found that the doctrine supplied the appropriate framework. The court explained that, when determining whether an entity acts as a joint employer, the major factors include the entity’s ability to hire, fire, or discipline employees, affect compensation and benefits, and direct and supervise performance.
Applying those factors, the court found enough evidence to treat Groveport as Hayes-Williams’s joint employer for purposes of employment discrimination laws. Groveport reviewed her placement, required her to follow its rules, policies, and procedures, trained her, received her hours, evaluated her, and controlled whether she could continue working at its schools. The court also held that Groveport’s decision to end her placement at the high school could qualify as an adverse employment action in the retaliation context, even if Hayes-Williams remained eligible for assignments through the Educational Service Center.
That threshold finding did not change the outcome. The court held that Hayes-Williams failed to establish a causal connection between protected activity and the adverse action. Her last complaint occurred in April 2023, and Groveport did not notify her that she would not return to the building-substitute role until August 8, 2023. The court found that this roughly three-and-a-half-month gap was not sufficiently close, standing alone, to establish causation. The court also rejected her reliance on testimony suggesting that Groveport gathered documentation after she complained. In the court’s view, the testimony was too speculative to show retaliation, and Groveport could have collected documentation for nonretaliatory reasons, including to investigate her allegations.
The court further held that, even if Hayes-Williams could establish a prima facie retaliation case, she could not overcome Groveport’s legitimate, nondiscriminatory reasons for its decision. Groveport cited interpersonal conflicts, communication and collaboration issues, and the stay-put incident. The court recognized interpersonal conflicts, failure to follow policies, insubordination, and unprofessional behavior as legitimate, nondiscriminatory reasons for ending an employment relationship. Because Hayes-Williams did not show that the stay-put rationale lacked a factual basis, did not actually motivate the decision, or was insufficient to warrant the decision, the court found no triable issue of pretext and entered summary judgment for Groveport.
Looking Forward
This decision offers a useful but carefully cabined reminder for employers and franchisors that a joint-employer finding does not decide the merits of a discrimination or retaliation case. The court found enough control to treat Groveport as a joint employer in a staffing arrangement, but it still required the plaintiff to prove the elements of her claims. That distinction matters. Employer-side defendants should continue to press causation, qualification, comparator, adverse-action, and pretext arguments even where a plaintiff attempts to expand the employment relationship.
For franchisors, the decision should not be read as a franchise-control case. Groveport did not merely maintain brand standards or quality-control requirements. The court focused on a public-school staffing arrangement where the district reviewed placement, directed daily worksite rules, trained the substitute, received hours, evaluated performance, and controlled whether the individual could continue working at the school. Those facts are materially different from a franchisor’s ordinary efforts to protect trademarks, preserve brand consistency, audit system standards, or require compliance with a franchise agreement. The better franchise lesson is not that system standards create joint employment, but that direct, individualized control over a worker’s daily assignment, discipline, evaluation, and continued access to the worksite may draw closer judicial scrutiny.
The defense win also illustrates the value of contemporaneous, concrete, and policy-based decision-making. Groveport prevailed because the court credited its stated reasons for the decision and found that the plaintiff did not rebut them. The stay-put incident gave the district a specific safety-policy rationale, and Groveport tied its decision to workplace conduct, communication concerns, and compliance with school procedures. Franchisors and employers can draw a practical lesson from that part of the opinion: when operational concerns arise, decision-makers should document the conduct, connect the decision to legitimate business or safety reasons, and avoid loose explanations that invite a retaliation theory.
The case also reinforces the importance of separating complaint intake from employment decision-making. The court rejected the plaintiff’s argument that document gathering after a complaint proved retaliation, recognizing that an employer may collect information for legitimate reasons, including investigating allegations. Even so, employers and franchisors with multi-unit systems should structure investigations carefully. A clear record showing who investigated, why documents were collected, what decision-makers reviewed, and how the final decision related to established policies may help prevent ordinary complaint response activity from being recast as retaliatory conduct.
For franchise systems, this opinion belongs in the broader category of cases that reward disciplined operational boundaries. Franchisors should maintain the ability to protect the System without assuming unnecessary control over franchisee employees. Employers and staffing clients should likewise understand that worksite control can create employment-law exposure, but that exposure remains defensible when the record shows legitimate reasons, consistent treatment, and an absence of causation or pretext.
This article is based solely on the opinion of the Court in this matter. The author has not conducted any independent investigation into the facts. For the avoidance of doubt, each statement related to the law and facts in this article is drawn from the Court’s opinion in this case.
Thomas O’Connell is a Partner at Buchalter LLP and Chair of the firm’s Franchise Practice Group. For questions about this article or media inquiries, you can contact Tom at toconnell@buchalter.com.
This communication is not intended to create, and does not create, an attorney-client relationship or any other legal relationship. No statement herein constitutes legal advice, nor should it be relied upon or interpreted as such. This communication is for general informational purposes only and is not a substitute for legal counsel. Readers should not act or refrain from acting based on any information provided without seeking appropriate legal advice specific to their situation. For more information, visit www.buchalter.com.
