A newly filed pretrial memorandum in former Wayland Superintendent Omar Easy’s lawsuit against the town lays out detailed and sharply conflicting accounts of what happened during his tenure, identifying specific meetings, conversations, employees and School Committee members that could become central to a trial.
The 16-page joint pretrial memorandum, filed Aug. 17 in Middlesex Superior Court, is significant because it puts both sides’ versions of the case in the same document and identifies dozens of potential witnesses. Easy is suing the Town of Wayland and former School Committee leaders Christopher Ryan and Ellen Grieco, alleging race discrimination. The defendants deny the allegations and say Easy was placed on paid administrative leave because of his performance and his creation of what they describe as a hostile and toxic work environment.
Only two substantive facts are identified as agreed upon at the beginning of the filing: Easy is Black, and he began working as superintendent of Wayland Public Schools in July 2021. Nearly everything that follows is presented separately as either Easy’s expected evidence or the defendants’ expected evidence, an important distinction because the allegations have not been established as facts at trial.
Easy’s section of the memorandum begins before he became superintendent. It alleges that racial bias surfaced during Wayland’s 2020 superintendent search, when two of the three finalists were Black.
The filing also revisits questions raised during Easy’s candidacy about his prior employment in Everett. It says Easy was asked whether he had filed an Massachusetts Commission Against Discrimination charge and then accused of having been untruthful about it. Easy’s position is that he understood the original question to be asking whether he had filed a lawsuit, which he had not. He had filed an MCAD charge concerning Everett’s superintendent hiring process, according to his statement.
Another dispute erupted over administrator evaluations in summer 2022. Easy gave a number of administrators “needs improvement” ratings, according to the filing. Some administrators objected that he had failed to follow an unwritten protocol and had not provided sufficient written feedback.
The filing then describes a series of strained relationships with town and school employees.
It alleges former Town Administrator Louise Miller declined to engage in one-on-one professional meetings with Easy and, during a disagreement, characterized his communication as “yelling.” Easy contends that description contributed to a broader stereotype of him as an aggressive Black man and was accepted by the School Committee without sufficient inquiry.
Easy’s filing also names former Wayland Middle School Principal Betsy Gavron and elementary school Principal Tricia O’Reilly as administrators who objected to his leadership style and accused him of intimidation and hostility.
Easy disputes that characterization. His filing says, for example, that he did not discipline O’Reilly after confronting her about COVID policy violations but instead wrote a letter documenting what he viewed as hostile and uncooperative behavior while expressing a desire to continue working with her.
The filing describes another dispute involving employee Ellen Whittemore. Easy’s statement says allegations were made involving physical contact and comments concerning pronouns or sexual orientation. Easy denies putting his hands on Whittemore or making such remarks and alleges the complaint followed her not being selected for an assistant superintendent position.
One of the most consequential interactions described in the filing occurred at an Oct. 13, 2022, Administrative Council meeting.
Easy says he gave a presentation addressing teacher-on-teacher harassment at multiple schools, including an alleged race-discrimination case at the high school and an exclusion incident at the middle school. He says he was pressing administrators to uphold the district’s anti-racism and anti-bullying principles.
According to Easy’s account, one or more white administrators subsequently complained to Ryan that Easy himself had bullied and intimidated participants at the meeting.
Easy says no administrator challenged his conduct during the meeting, other than engaging him in discussion over a math program, and that Ryan did not subsequently interview him about the complaints or give him an opportunity to explain what had occurred.
Easy’s attorneys contend his energetic and emotional discussion of racial discrimination against a Black teacher, identified in the filing as Mr. Douglas, was interpreted through a racial stereotype rather than viewed in context.
The filing also describes an earlier leadership retreat where an unnamed white employee publicly refused to participate in an introductory exercise. Easy’s filing portrays the refusal as deliberate disrespect for his authority. A footnote says the individual is not named in the memorandum because he later sued Easy in a separate action that was dismissed on anti-SLAPP (Strategic Lawsuit Against Public Participation) grounds.
Race-related incidents involving students and school buildings form another major part of Easy’s expected case.
His statement cites racist graffiti found in the middle school around December 2021, including the N-word, “BLACK PEOPLE DIE” and a message demanding that Black people leave the district. It also cites racist taunts at district events in February 2022 and May 2023, including a basketball game involving Westford, and says METCO students were subjected to racist slurs.
Easy’s filing says he proposed placing cameras in middle school hallways in response to the graffiti, noting that cameras were already in use at the high school.
The memorandum alleges Gavron and middle school teachers responded that Easy was “destroying Wayland’s culture” and “bringing Everett culture to Wayland.” Easy’s attorneys characterize the references to Everett, a more racially diverse community where Easy previously worked, as racially coded. The filing says the School Committee did not back the camera proposal and the cameras were not installed.
Everett surfaces repeatedly in Easy’s account of disputes over hiring.
During consideration of a special education administrator identified as Baldassarre, who had previously worked in Everett, the filing attributes a statement to School Committee member Christina Rodrigo: “How many more of you are coming here from Everett? How many more are you going to bring here?”
The filing says that during subsequent deliberations, Rodrigo and an unnamed Happy Hollow teacher objected to hiring Mike Baldassarre because he came from Everett and said he did not fit Wayland’s “profile.”
In another case, Easy says he told Ryan he wanted to hire a special education consultant who was also from Everett. The memorandum alleges Ryan advised him not to do so because the candidate’s Everett background “could be a problem.”
The filing describes a separate personnel dispute involving Tulani Husband, identified as the district’s only Black building administrator at the time.
Easy says he was given evidence that a white senior administrator demeaned Husband in front of students and staff and questioned whether she was CPR-certified and trained in special education administration, questions the filing says were not asked of white administrators.
Easy sought disciplinary action, according to the memorandum, but contends the School Committee created delays and obstacles rather than supporting him.
At one point, the filing says the committee told Easy, “That is your responsibility. That is your problem to deal with.”
Easy’s memorandum says that after providing a 12-page document concerning the employee and receiving no response from committee counsel, he retained separate counsel for the district. According to Easy’s filing, that attorney concluded his actions were warranted and supported issuing an intent to dismiss the administrator. The senior administrator involved is not identified by name in this portion of the filing.
The racial incident most publicly associated with Easy’s tenure is also part of his expected case.
On Dec. 21, 2022, racist graffiti specifically naming Easy was painted on a wall near Wayland High School, facing the main campus entrance. The message paired his first name with the N-word.
Easy’s memorandum says he went to work that day despite the incident but that his attorney canceled a scheduled interview with the School Committee’s investigator in its immediate aftermath.
Easy publicly raised concerns about the district’s racial climate at a Jan. 4, 2023, School Committee meeting.
His attorneys allege that by approximately Jan. 18, the School Committee had learned that outside attorney-investigator Suzanne Hafer found no evidence that Easy had engaged in misconduct during the Oct. 13 Administrative Council meeting. According to Easy’s statement, the investigation found that his tone did not amount to workplace bullying, intimidation or harassment.
Easy’s filing also says the investigation found he had followed applicable requirements regarding the administrator evaluations, including meeting a 2022 Department of Elementary and Secondary Education deadline and entering ratings into TeachPoint.
Defendants’ case
The defendants present a substantially different case.
The Town of Wayland, Ryan and Grieco say they expect the evidence to show Easy was placed on paid administrative leave because he created a “hostile and toxic work environment” that lacked appropriate management, support, confidentiality, and leadership.
They say the decision was wholly unrelated to Easy’s race or color and contend they did not interfere with or breach his employment contract. They maintain that they acted reasonably and appropriately and deny causing the damages Easy claims.
In the portion of the filing jointly describing the lawsuit, the parties agree only on the nature of the dispute: Easy alleges race discrimination; the defendants say his administrative leave resulted from poor work performance and other issues, deny liability and contest his claimed damages.
The defendants also say they anticipate filing a significant number of motions seeking to limit evidence at trial based on differences between what Easy alleges and what they contend the evidence will actually establish.
The filing also states that attorneys for both sides have discussed settlement, mediation or other forms of alternative dispute resolution.
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