Shelly Hudson v. Charleston County School District

── Shelly Hudson v. Charleston County School District ── Court: Court of Appeals for the Fourth Circuit Date: June 09, 2026 Category: General USCA4 Appeal: 25-2088 Doc: 40 Filed: 06/09/2026 Pg: 1 of 7 UNPUBLISHED UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT No. 25-2088 SHELLY G. HUDSON, Plaintiff – Appellant, v. CHARLESTON COUNTY SCHOOL DISTRICT; DANA RODGERS, in her individual capacity; JENNIFER COKER, in her individual capacity, Defendants – Appellees. Appeal from the United States District Court for the District of South Carolina, at Charleston. David C. Norton, District Judge. (2:22-cv-03423) Submitted: April 14, 2026 Decided: June 9, 2026 Before DIAZ, Chief Judge, and HARRIS and BENJAMIN, Circuit Judges. Affirmed by unpublished opinion. Judge Harris wrote the opinion, in which Chief Judge Diaz and Judge Benjamin joined. ON BRIEF: Lawrence C. Kobrovsky, KOBROVSKY LAW OFFICE, LLC, Charleston, South Carolina, for Appellant. Eugene H. Matthews, RICHARDSON PLOWDEN & ROBINSON, P.A., Columbia, South Carolina, for Appellees. Unpublished opinions are not binding precedent in this circuit. USCA4 Appeal: 25-2088 Doc: 40 Filed: 06/09/2026 Pg: 2 of 7 PAMELA HARRIS, Circuit Judge: Shelly Hudson taught for one year at a school for students with severe behavioral problems. After leaving that position, she sued the school district, the school’s principal, and another district employee, claiming students at the school had racially and sexually harassed her and that the defendants were liable for the resulting hostile work environment. The district court found that Hudson had not provided the defendants with sufficient notice of the alleged harassment and granted summary judgment to the defendants. Finding no errors, we affirm. In 2018, Hudson accepted a teaching position at the Daniel Jenkins Academy (“DJA”), an alternative school in the Charleston County School District. 1 DJA was designed to serve students with severe behavioral and mental health challenges, many of whom were assigned to attend the school in lieu of expulsion. At the time she accepted the position, Hudson had taught in similar alternative schools for more than a decade. During the sole year she taught at DJA, Hudson faced consistent harassment from students, who sometimes mocked and threatened her and frequently used vulgar language towards her. As is relevant here, some of this harassment involved the use of racial and sex-based slurs, including the terms “cracker” and “bitch.” In response, Hudson made at least 67 written disciplinary referrals to the school’s administration. According to Hudson, the school responded with inadequate punishments that only encouraged the harassment to 1 Except as otherwise noted, the facts presented here are not meaningfully disputed by the parties. 2 USCA4 Appeal: 25-2088 Doc: 40 Filed: 06/09/2026 Pg: 3 of 7 intensify. On a particularly tough day late in the school year, Hudson suffered a panic attack while teaching. She took leave, later resigned from her position, and has not worked since. Hudson sued the school district, the DJA principal, and the principal’s supervisor (whom Hudson described as the person in charge of student discipline for the school district). As is relevant on appeal, she claimed the defendants subjected her to a racially and sexually hostile work environment, in viola