The U.S. Court of Appeals for the Fourth Circuit has affirmed a lower court's ruling in favor of Montgomery County Public Schools in an employment-related lawsuit brought by former employee Kimberly Ann Polk. The appellate court's published decision, issued January 28, 2026, upheld the district court's dismissal of claims against the school system and multiple board members sued in both their individual and official capacities.
The case, *Polk v. Montgomery County Public Schools* (4th Cir. 2026), involved a complex employment dispute between Polk and the Maryland school district. The lawsuit named as defendants Montgomery County Public Schools, the Montgomery County Board of Education, and eight individual board members: Shebra L. Evans, Monique Felder, Lynne Harris, Grace Rivera-Oven, Karla Silvestre, Rebecca Smondrowski, Brenda Wolff, and Julie Yang. All board members were sued in both their individual and official capacities.
The three-judge panel heard oral arguments on October 23, 2025, before reaching its decision three months later. Judge King wrote the majority opinion, which Judge Thacker joined. Judge Wilkinson filed a dissenting opinion, indicating the court was not unanimous in its ruling.
The case originated in the U.S. District Court for the District of Maryland at Greenbelt, where District Judge Deborah L. Boardman presided over the initial proceedings. The district court ruled in favor of the school system, prompting Polk's appeal to the Fourth Circuit.
Representing Polk on appeal was Frederick W. Claybrook Jr. of Claybrook LLC in Washington, D.C. Additional counsel included Robert Flores of Gammon & Grange, P.C. in Vienna, Virginia, and attorneys Steven W. Fitschen and James A. Davids from the National Legal Foundation in Chesapeake, Virginia.
The defendants were represented by Cassandra Ann Mitchell of Wilmer Cutler Pickering Hale and Dorr LLP's New York office. Additional counsel for the appellees included Bruce M. Berman, Julia M. May, Megan O. Gardner from the firm's Washington, D.C. office, and Alan Schoenfeld and Emily Barnet from the New York office.
Montgomery County Public Schools is one of the largest school districts in Maryland, serving approximately 165,000 students across the county. The school system has faced various employment-related lawsuits over the years, as is common with large public employers.
The Fourth Circuit's decision to publish the opinion suggests the court viewed the case as establishing important legal precedent or clarifying existing law in the employment context. Published opinions carry greater precedential weight than unpublished decisions and are binding on lower courts within the circuit.
Employment disputes involving public school systems often raise complex issues regarding governmental immunity, constitutional rights, and federal employment laws. These cases frequently involve claims under Title VII of the Civil Rights Act, the Americans with Disabilities Act, Section 1983 civil rights violations, or other federal statutes protecting employee rights.
The presence of individual capacity claims against board members suggests the lawsuit may have alleged constitutional violations or other conduct that could pierce governmental immunity protections. When public officials are sued in their individual capacities, they may be personally liable for damages if found to have violated clearly established rights.
Judge Wilkinson's dissenting opinion indicates there were substantive disagreements among the panel regarding the proper resolution of the case. Dissenting opinions often highlight areas where the law may be unsettled or where reasonable minds can differ on legal interpretation.
The affirmance means Polk's claims against Montgomery County Public Schools and the board members will not proceed. For the school system, the ruling provides closure to what was likely a lengthy and expensive litigation process. Public school districts often face significant legal costs defending employment-related lawsuits, which can impact resources available for educational programs.
The case demonstrates the challenges employees face when pursuing claims against large public employers with substantial legal resources. The involvement of multiple law firms on both sides underscores the complexity and stakes involved in the litigation.
For Montgomery County Public Schools, the favorable ruling may provide some protection against similar future claims, though the specific legal issues resolved in the case would need to be analyzed to determine the broader implications for the district's employment practices.
The Fourth Circuit's jurisdiction includes Maryland, Virginia, West Virginia, North Carolina, and South Carolina, meaning the precedent established in this case will be binding on district courts throughout the region. This could affect how similar employment disputes involving public school systems are resolved in these states.
While the specific nature of Polk's claims against the school system remains unclear from the available court documents, the appellate court's decision to affirm suggests the district court properly applied relevant law to dismiss her case. The published opinion will likely provide detailed analysis of the legal issues involved once the full text becomes available.