Mike Miles

Superintendent of Schools
Educating All Students For Success

Administrative Statement
State of Texas
County of Dallas
Before me, the undersigned authority, personally appeared Young, Richard, who is employed by Dallas
ISD as AC Intern with employee ID number 72625, and who, being by me duly sworn that the facts herein
stated are true and correct to the best of his/her knowledge, deposed as follows:
I have been with the District since November 14, 2012, serving as a teaching assistant,
permanent substitute teacher, and a full-time educator. On March 6, 2015, I was notified that I
would no longer have a job after March 31, 2015 due to my school principal, Zachary Hall, not
recommending me for certification to the AC program that I am currently enrolled in.
Mr. Hall has been harassing me with reprimands and letters of concern throughout the entire
school year. Each and every time I have been in Mr. Halls office, it has been only to sign
reprimands, letters of concern, and growth plans. Mr. Hall is a brand new principal, not ever
serving as Assistant Principal. Since his placement at Stephen C. Foster Elementary, I have
been informed by other staff members that the assistant principal, guidance counselor, and the
academic coordinator have filled his head with verbal propaganda that negatively impacted me.
One of those statements were that I was not ESL certified and that I didnt need to be on the
campus. I actually passed the state ESL certification exam in November, and will continue to add
to my teaching certificate. I have recently graduated with a Masters in Education with a graduate
minor in ESL. I was also informed by a former teacher that the guidance counselor was at a bar,
more than once, making negative remarks about me to other faculty and staff members while
consuming alcoholic beverages. Mr. Hall has given me letters of reprimand and concern every
month since October 2014. I have never been disciplined in away way since I began with the
district.
On October 20, 2014 a teaching assistant was directed by Mr. Hall to leave his/her duty and walk
to my classroom to inform me that I needed to report to his office after school to sign a reprimand.
This was my very first reprimand ever since I began my employment with the district in 2012. I
was reprimanded for being one day tardy for submitting Common Assessment goals, in which
those goals are not even required by the district. Two other kindergarten teachers were also tardy
submitting their Common Assessment goals. Both of those teachers, whom are of a different race
than I, admitted to me face-to-face that they were tardy submitting their documents and did not
receive reprimands.
On October 22, 2014, the assistant principal was directed by Mr. Hall to leave his duty and go to
my classroom and interrupt my class, while I am preparing my students for the district-wide
common assessment testing, to remove posters off of my wall without my permission, that
displayed the Pledge of Allegiance and the Texas State Pledge so he can remount my lesson
objectives (LOs) and demonstrations of learning (DOLs). Neither administrator explained to me
how the pledges to the flags were a violation or disruption, considering the fact that the LOs and
DOLs were properly mounted for my kindergarten students to read, and were updated and
relevant. The unplanned disruption caused me to lose control of my kindergarten class, forcing
me to take my students on an early restroom and water break. I did contact DISD HCM and
notified them immediately of what was happening. The HCM member informed me to file a
grievance and begin at the lowest level.
Page 1 of 8

Affiant Initials: ______

3700 Ross Ave.

Dallas, TX 75204
(972) 925-3700
www.dallasisd.org

Professional Standards Office

2419 Cockrell Ave.
Dallas, TX 75215
(972) 925-5340

Mike Miles
Superintendent of Schools
Educating All Students For Success

Administrative Statement
On October 23, 2014, Mr. Hall called me into the assistant principals office, with the assistant
principal and academic coordinator present, to speak with them about improperly notifying them
about my early departure the day before due to a medical emergency. Since that was my very
first time ever to leave early from work, I was unsure of the proper protocols in reference to
leaving the campus early, despite the fact that I informed the Office Manager and the CRC
secretary. At the close of that meeting, Mr. Hall directed me to come to his office the very next
morning on October 24, 2014 at 7:25am to sign a letter of reprimand. I did obey Mr. Halls
directive to wait for him outside his office the next morning, but he was tardy for work without
notice, so I proceeded to the cafeteria for morning duty so that I would not be tardy and leave the
students unattended. So then, Mr. Hall decided to have me sign the reprimand on Monday,
October 27, 2014. I refused to sign the reprimand since Mr. Hall allowed too much time to elapse
and I did not feel comfortable signing the reprimand without my attorney being present.
I was placed on my very first growth plan ever with the district in October of 2014. This was a
result of me receiving poor scores on my spot observation, because Mr. Hall did not like the way
the learning centers were set up for my kindergarten students. A teaching assistant, whom spoke
very little English, was immediately directed by Mr. Hall to leave his/her duty and cover my
classroom while I was in the middle of preparing my students for the district-wide common
assessment testing, so that I may report to Mr. Halls office and sign the growth plan. I was so
upset, I left Mr. Halls office and went crying to another teacher, whom then walked me into an
empty classroom to calm me down and ask what was wrong. As a part of the growth plan, one of
the provisions was for the assistant principal to video tape me teaching against my will, distracting
my students, eventually leading them to miss their library time. I was very nervous and
uncomfortable, and could not perform my teaching duties with confidence. This directive was by
Mr. Hall, causing the assistant principal to leave his duty just to videotape me and the students.
(exact date unknown)
At the end of the growth plan period, the assistant principal was directed by Mr. Hall to leave his
duty and interrupt my class once again to sign the results of my growth plan right in front of my
students. Again, my students were distracted and I had to regain control of my kindergarten
students again. I felt very embarrassed and humiliated.
On November 12, 2014, I emailed the Executive Director for my feeder pattern, regarding all of
the disparate treatment I endured from Mr. Hall. The ED responded to my email stating that I did
not properly file a grievance, therefore he/she did not take any action. I was unaware of how to
properly file a grievance since I have never had to file any type of complaint since I started with
the district.
On November 14, 2014, I was threatened with termination by Mr. Hall via email at 6:34pm on a
Friday night due to the absence of a submitted lesson plan and data analysis/action plan, in
which those are items are not required by the district. That was the very first time I was ever
threatened with termination since I have been with the district.
I emailed a DISD HCM Employee Relations member, notifying him/her of all of the disparate
treatment I have endured from Mr. Hall. Days later on November 20, 2014, The Employee
Relations member did come to my campus to speak with Mr. Hall regarding my complaints.
Coincidentally, the ED for my feeder pattern was present on campus. I am unsure of what took

Page 2 of 8

Affiant Initials: ______

3700 Ross Ave.

Dallas, TX 75204
(972) 925-3700
www.dallasisd.org

Professional Standards Office

2419 Cockrell Ave.
Dallas, TX 75215
(972) 925-5340

Mike Miles
Superintendent of Schools
Educating All Students For Success

Administrative Statement
place in the meeting, as I never received any correspondence from Mr. Hall nor the Employee
Relations member.
Another teaching assistant was directed by Mr. Hall to leave his/her after school duty to escort me
from my classroom to his office after school to sign another letter of reprimand. I cannot recall
exactly what that particular reprimand was for. I was once again embarrassed and humiliated.
(exact date unknown)
On January 8, 2015, the CRC secretary was directed by Mr. Hall to leave her office to inform me
that I needed to report to his office to sign a letter of concern regarding inputting students grades
online in GradeSpeed. I explained to Mr. Hall that I input students final grades for report cards
into GradeSpeed before the deadline. Although individual weekly grades were not input into
GradeSpeed, I did however make photocopies of my manual grade book and signed and
submitted those grade book pages to the CRC secretary before the deadline. The manual grade
book pages did display all students grades for individual assignments, final averages for the 6weeks, and district-wide test scores for the 6-weeks grading period.
On January 29, 2015, I was evaluated by the APlus Texas Teachers Alternative Certification
Program. I was observed for my teaching practices and procedures for forty-five minutes. I
received a one-hundred percent on my evaluation from the AC program as well as
recommendation for five year standard teacher certification. My evaluator from the AC program
emailed the same results to Mr. Hall. That same day, Mr. Hall emailed me at 11:42am notifying
me of a ten day window in which he will come to my classroom unexpectedly and evaluate me.
Mr. Hall arrived the very next morning to my class on January 30, 2015, less than twenty-four
hours later from the email warning to evaluate me. Fortunately and coincidentally, I was prepared
for the evaluation.
On January 30, 2015, Mr. Hall gave me all zeroes on my mid-year evaluation during the forty-five
minutes he was observing me, despite the fact that I was closely monitoring the students, keeping
them academically engaged, adhering to the lesson plan, and following the new TEI rubric to the
fullest extent. Mr. Hall actually lied by stating on the evaluation that I made an alleged comment
that read, I do not care about (students name omitted). I assert that comment was not true.
Both evaluations from the AC Program and Principal Hall, took place twenty-four hours apart. I
went from a one-hundred percent rating to all zeroes from that Thursday (1/29) to Friday (1/30). I
respectfully argue and disagree that the quality of an effective educators teaching practices and
procedures are not diminished or hindered in such a short time frame; in my case: overnight.
On February 7, 2015, I received a disciplinary email from Mr. Hall on a Saturday morning which
stated that I need to clock in each morning by 7:25am, in which that directive is not required by
the district. Another kindergarten teacher, whom is of a different race than I, received the same
email. I was placed on a growth plan, with one of those provisions being that I clock in each
morning by 7:25am. The other kindergarten teacher whom received that same email was not
placed on a growth plan (this was the same teacher whom was one of two that was not
reprimanded for submitting common assessment goals tardy back in October). I have personally
witnessed for myself, alongside with another staff member, a large quantity of staff members
clocking in way passed 7:25am each morning; staff members of different races and skin color
than myself. Mr. Hall himself has been observed arriving to the campus after 7:25am more than
Page 3 of 8

Affiant Initials: ______

3700 Ross Ave.

Dallas, TX 75204
(972) 925-3700
www.dallasisd.org

Professional Standards Office

2419 Cockrell Ave.
Dallas, TX 75215
(972) 925-5340

Mike Miles
Superintendent of Schools
Educating All Students For Success

Administrative Statement
once; again I am one of those witnesses. If Mr. Hall cannot arrive to work on time himself, I do not
see how he can lead by example for me or others who are arriving after 7:25am, despite the fact
that I am still on time for morning duty in the cafeteria each day.
On February 9, 2015, Mr. Hall arrived to my classroom after school and was accompanied by the
assistant principal and the academic coordinator. Mr. Hall notified me that he was placing me on a
second growth plan. Although I was intentionally given all zeroes on my mid-year evaluation, Mr.
Hall, the assistant principal, nor the academic coordinator presented any concrete evidence that
supported myself being issued all zeroes on the evaluation or why I was being placed on a
second growth plan. The provisions of the growth plan were more of an inconvenience and
punishment rather than a way to improve my teaching strategies or benefit my students. The
second growth plan, much like the first growth plan, took place during the same week of the
district-wide common assessment testing. Some of those provisions included observing two
bilingual teachers, both of whom have never taught kindergarten before. I was also to be
accompanied by another bilingual teacher during the class observations, whom that teacher also
had no kindergarten experience either. One of the bilingual teachers that I observed was to coteach a mini-lesson with me as a provision of the second growth plan. That teacher did arrive to
my classroom for the mini-lesson co-teach, but I was not prepared as I was still administering a
district-wide common assessment test to my students. That same teacher and Mr. Hall are
Facebook friends and I feel that their friendship can and will create a conflict of interest,
compromising the outcome of my complaint and my teaching job. I sat down and spoke with the
kindergarten department head/CILT member regarding the provisions of the second growth plan
verbatim, and he/she too disagreed with the provisions of the growth plan as the provisions would
not benefit me or my kindergarten students. The kindergarten department head did raise this
concern to the academic coordinator, but no action was taken. I was never offered professional
development or real teaching strategies that would be beneficial to me or my students. I have
never been placed on any type of growth plan by my previous school principals or assistant
principals.
On February 25, 2015, a staff member (general education teacher) informed me that there is a
great possibility that him/herself and another general education teacher would be reassigned to
kindergarten general education homeroom sections next school year (2015-2016). There are
only two general education kindergarten homeroom sections this school year, since the other
teacher and myself are not bilingual certified. This information left me wondering what would
happen to me and my teaching career for next school year. I was informed of the homeroom
change two school days (with respect given to the inclement weather days) after I emailed the
academic coordinator, informing her that I filed a grievance regarding my mid-year evaluation
scores.
On March 6, 2015, I was in an after school meeting with Mr. Hall, along with the assistant
principal, and the academic coordinator. I was verbally notified by Mr. Hall that I would be
involuntarily relieved of my teaching duties after March 31, 2015, the same day my teaching
certificate expired. I never received anything in writing. This took place eight school days (with
respect to the inclement weather days) after I notified the academic coordinator via email that I
filed a grievance against Mr. Hall regarding the unfair evaluation which resulted in the second
growth plan. The email was solely meant for the academic coordinator and somehow, Mr. Hall
retrieved that email. Because of the eight day temporal proximity (close time lapse), it appears
that Mr. Hall retaliated against me by not allowing me to return to my teaching duties when my
Page 4 of 8

Affiant Initials: ______

3700 Ross Ave.

Dallas, TX 75204
(972) 925-3700
www.dallasisd.org

Professional Standards Office

2419 Cockrell Ave.
Dallas, TX 75215
(972) 925-5340

Mike Miles
Superintendent of Schools
Educating All Students For Success

Administrative Statement
teaching certificate expired. Mr. Hall rudely stated to me that We havent seen any
professionalism. We tried to support you, but you wouldnt step up to the plate. Mr. Hall was
never specific of how I was unprofessional nor did he elaborate on the rude comment he made.
Mr. Hall also stated that he wouldnt sign off on my teaching certificate renewal, although the
teaching certificate renewal was paid for before it expired. During the meeting, I inquired about
utilizing my sick leave since I have not ever been absent since I initiated employment with the
district. Mr. Hall stated if I utilized my sick leave, he will remove me from the campus for the
remainder of the time left on my teaching certificate and place someone else in my classroom. I
felt that was unfair because Mr. Hall allowed two former staff members whom were of different
races than I, whom were departing the district, to utilize their sick leave in lieu of terminating their
own employment.
On March 7, 2015, I was notified via email Saturday morning from Mr. Hall, the very first day of
Spring Break, that I was being reassigned effective immediately for the best interest of our kids.
The email did not state where or why I was being reassigned. I felt my students grades were in
jeopardy because I was stuck with a large quantity of ungraded papers and graded papers that
needed to be recorded into GradeSpeed. Because of my dedication and devotion to my
classroom and the district as a whole, I still managed to input my students grades into
GradeSpeed over the Spring Break while I was out of town.
On March 16, 2015, the Monday after returning from Spring Break, I was verbally notified by the
assistant principal that I was being demoted to a Special Education assistant by the orders of Mr.
Hall, despite the fact that my teaching certificate had not yet expired. I was immediately removed
from my current kindergarten classroom, with all of my personal belongings still in the classroom,
and placed in the autism classroom, where I was the teacher of record last school year. This was
indeed a conflict of interest and confusing to the special education students whom I once was in
charge of, and then to become their classroom assistant. Not to mention the confusion of my
kindergarten students, some of whom already left other teachers or came from other schools to
be placed in my homeroom. I was injured by one of the special education students by receiving
severe scratches, causing me to go to the nurses office before going home. This same student
injured me last school year when I was the teacher of record in the autism classroom. I ended up
filing a workers comp claim because of my injury from the special education student. I contacted
my teachers union and DISD HCM Employee Relations regarding my demotion and disparate
treatment. I was notified by both departments and was told by both that it is against the law for
me to be demoted to a special education teaching assistant against my will while my teaching
certificate was still valid. I notified Mr. Hall via email regarding myself contacting my teachers
union and HCM regarding the legality of the demotion. That same day, I received an email from
Mr. Hall, less than two hours later, which read that I will be the new Reading and Math
Intervention teacher for grades K-2. This position has never been on my campus since I started in
2012. I am unsure how Mr. Hall was able to create a new position in such a short length of time.
On March 17, 2015, I emailed Mr. Hall regarding my new reassignment and his poor
communication towards me. In the email, I explained to Mr. Hall that I felt uncomfortable going
into the new position so late in the school year, with very little notice and absolutely no training
and no detailed job description. I also asked in the email how was the swift change going to
improve my teaching strategies, and how will my kindergarten students benefit with a new
inexperienced teacher so late in the year. Mr. Hall never answered my questions raised in the
email.
Page 5 of 8

Affiant Initials: ______

3700 Ross Ave.

Dallas, TX 75204
(972) 925-3700
www.dallasisd.org

Professional Standards Office

2419 Cockrell Ave.
Dallas, TX 75215
(972) 925-5340

Mike Miles
Superintendent of Schools
Educating All Students For Success

Administrative Statement
On March 18, 2015, I was reassigned to an abandoned classroom portable to serve in my new
position as the Intervention teacher. Mr. Hall, the assistant principal, nor the academic coordinator
have ever walked out to my portable classroom to check on me, evaluate me, inquire about my
students, asked if I needed support or anything else. I was moved to the portable classroom
without instructional materials, classroom supplies (other than the supplies I purchased with my
own monies), professional development and training, etc. I was never issued a roster of students
to give remediation and intervention to. I took it upon myself to randomly ask various kindergarten
and first grade teachers to give me low-performing students to give remediation and intervention
to.
On March 31, 2015, I was approached by the academic coordinator to sign an Oath for the Texas
state mandated STAAR test. I refused to sign the Oath because I was absent during the day the
training/confidentiality film was shown to the staff. Without notice, I was notified that my portable
classroom was being used for testing, therefore, and without notice, I was directed by the
academic coordinator to remain in the modular building outside the school and assist with the
second grade teachers and their students.
For the first three days when I was immediately removed from my kindergarten classroom, my
students were served by a substitute teacher (March 16-18, 2015). On March 19, 2015, I was
replaced by a Guest Teacher by the name of Ms. Ibarra (or may be spelled Ybarra), whom is of a
different gender and race than myself and whom had less classroom experience than me. In a
memo dated August 7, 2014 to selected DISD principals, one of the FAQs on page 4 of the
memo read: Q: Can I use my Guest Teacher to cover a vacancy? A: No, Guest Teachers can
only be used to cover teacher absences. My school, Foster Elementary, was a selected school
that received this memo, so therefore, my principal Mr. Hall received this memo. The memo was
sent from Executive Director Meredyth Hudson and signed by both Carmen Darville and Ann
Smisko.
On April 14, 2015, I was hand-delivered a letter from a member of Employee Relations regarding
an Intent to Recommend Termination at the end of my contract term. I was then issued a three
day notice to voluntarily submit a resignation in order to avoid a contract non-renewal on my
record, in which I declined.
My colleagues at Stephen C. Foster Elementary School feel that Mr. Hall is trying to rid of all the
African-American staff that are currently housed in the school. At least two African-American staff,
other than myself, feel as though they are being harassed by Mr. Hall and the assistant principal,
and were at the frustration level to where they wanted to terminate their own positions half-way
through the school year. My colleagues believe that Mr. Hall feels threatened or intimidated by
me or possibly jealous of me because of my academic and educational accomplishments. They
believe that Mr. Hall feels that I am competitive with him or towards him for various reasons. One
other staff member feels that because I will not respond to Mr. Halls unwelcomed gestures and
non-verbal sexual advances towards me since we share the same sexual orientation, therefore
this leads Mr. Hall to retaliate against me with threats, bullying, harassment, demotion, and
repeated unnecessary reprimands. I have witnessed, alongside with other staff members, Mr.
Hall placing unnecessary surveillance on me by sitting outside my classroom on numerous
occasions.

Page 6 of 8

Affiant Initials: ______

3700 Ross Ave.

Dallas, TX 75204
(972) 925-3700
www.dallasisd.org

Professional Standards Office

2419 Cockrell Ave.
Dallas, TX 75215
(972) 925-5340

Mike Miles
Superintendent of Schools
Educating All Students For Success

Administrative Statement
The Dallas Independent School District, as well as Title VII of the Civil Rights Act of 1964, as
amended, explicitly states that it prohibits discrimination against employees on the basis of sex,
race, color, national origin, and religion. The following Responsibilities of the Principal Job were
just some of the responsibilities pulled from the 2014-2015 DISD principal handbook, in which Mr.
Hall violated, in part or whole:
Visit classroom regularly; observe and gather data to make adjustments as necessary
and appropriate to meet district and school goals and objectives relating to
curriculum, best teaching practices, cultural competency and related factors.
Monitor classroom performance of all teachers on a regular basis and offering
pathways and professional development to improve student performance through
improved teaching practices.
Communicate and promote high expectation levels for staff and student performance
in enabling, supportive way; provides proper recognition of excellence and
achievement. Mediates and facilitates resolution of conflicts among faculty, staff,
students, and parents.
Given this statement with merit, I close the foregoing, in light, by recapitulating the genuine issues
of fact that I was discriminated against on three different occasions with regards to race and skin
color. I was threatened with termination previously. I was placed under unnecessary surveillance
on multiple occasions. I have been continuously humiliated, bullied, and harassed by my
principal, Mr. Zachary Hall. I was eventually retaliated against with an immediate demotion,
reassignment, and then removal from my place of employment after filing a written complaint with
an eight-day temporal proximity/time frame. I suffered adverse employment action by being
replaced with someone of a different race and gender, and has less experience than I. Mr. Hall
did not produce evidence of any wrongdoing on my part, therefore, using a mere pretext for the
involuntary removal of myself from the campus. Unless otherwise shifted with affirmative defense,
I hold the burden of proof and meet prima facie, and inter alia, hoping to prevail by being granted
the redress and remedies below.
The remedies I am seeking are first, to be immediately re-instated as a full-time educator at
Stephen C. Foster Elementary School. I am asking that either Mr. Hall or the assistant principal
recommend me for continued probationary certification to my AC Program, therefore, the program
will recommend me to the TEA for a valid teacher certificate. I am seeking conflict resolution
management in the future from Mr. Hall as well as equal employment opportunity and the
succumbing of discrimination and retaliation. I would like a formal or informal mediation between
myself, Mr. Hall, the assistant principal, guidance counselor, and/or academic coordinator to
prevent any further false or misleading propaganda that would compromise or jeopardize myself,
my students, or my teaching career. I am asking to be removed from the non-renewal contract
list. And I am asking for all reprimands and letters of concern to be removed from my personnel
file.

Page 7 of 8

Affiant Initials: ______

3700 Ross Ave.

Dallas, TX 75204
(972) 925-3700
www.dallasisd.org

Professional Standards Office

2419 Cockrell Ave.
Dallas, TX 75215
(972) 925-5340

Mike Miles
Superintendent of Schools
Educating All Students For Success

Administrative Statement

Affiant
Sworn to and subscribed before me on this

day of

, 20

Notary Public in and for the State of Texas

Page 8 of 8

Affiant Initials: ______

3700 Ross Ave.

Dallas, TX 75204
(972) 925-3700
www.dallasisd.org

Professional Standards Office

2419 Cockrell Ave.
Dallas, TX 75215
(972) 925-5340