This Bad Boss Priest Cast the First Stone — at an Eighth Grade Teacher
Single mom Kourtney Liggins had worked for almost four years as an eighth-grade teacher at Transfiguration Elementary School, a Catholic school in Los Angeles, when Father Michael Tang, the school’s pastor, called her to his office.
Fr. Tang said he had heard Ms. Liggins was pregnant, she later told a court; accordingly, he asked her to stop acting as a youth minister because she was, as she said he put it, “morally corrupt.”
“Does it even have a father?” the priest inquired about the unborn child, a girl, according to testimony from Ms. Liggins, who also was Fr. Tang’s parishioner. “I don’t want to see it on this campus. I don’t want to see it at church.”
Hurt and upset, Ms. Liggins dropped much of her religious work but remained as a teacher at Transfiguration. She was approved for a year’s maternity leave upon her daughter’s birth that summer, but was called back early — and at lower pay — after Fr. Tang clashed with her substitute, she testified.
Just a few months after her return, she met again with Fr. Tang and was shocked to hear him claim that Transfiguration parents were now complaining about her. She told the court this was the first time she heard of any criticism — and further, that she came to believe that Fr. Tang had altered employment records and rewarded some of the parents for their complaints.
One week later, Ms. Liggins received a bad year-end review; Fr. Tang said she’d be suspended if she did not sign it, according to court documents. Backed up by a HR official, Ms. Liggins refused. A month later, however, she was told not to return for the next school year.
Michael Tang is our new Bad Boss of the Month.
Ms. Liggins filed a lawsuit against the Archdiocese of Los Angeles and Fr. Tang, among others. After a trial in October 2018, an L.A. County jury awarded her almost $3.6 million in compensation, plus a levy of $87,500 to punish Fr. Tang personally for his “outrageous” conduct. In January the judge invalidated part of that verdict, however, and ordered a new trial on damages alone. No one was happy, and the tangled outcome is now on appeal.
An experienced educator, Ms. Liggins had begun subbing at Transfiguration in 2007, not long after her sister, Mechele Yerima, became principal. It was her second stint at the school, which serves a diverse community of modest means; she had worked there from 1998 to 2003 and “really enjoyed” it. In 2008, Ms. Liggins was promoted to teach eighth graders a range of subjects from science to music to spelling. Often called Mrs. Johnson at school because she had children at Transfiguration with that surname from a previous marriage, she said she had no performance issues until her run-in with Fr. Tang.
Fr. Tang, meanwhile, had arrived at Transfiguration in 2010. A diocesan priest who teaches art and art history at nearby Loyola Marymount University, a Catholic institution with a close relationship to Transfiguration, he moved in a very different world than Ms. Liggins. He is a talented watercolorist and equestrian enthusiast who promotes himself as “America’s premier sporting artist”; his flattering horse-and-rider paintings are owned by society figures such as the Bertam Firestones and Jane Forbes Clark, and by tony institutions including The International Museum of the Horse.
Originally a Jesuit, Fr. Tang told a writer that he left that order partly because its vow of poverty conflicted with his wish to ride and show horses. On his Web site he solicits equestrian painting commissions, promising to capture “you and your favorite mount in pigment for posterity.” His About the Artist page features a glamorous studio photo and no hint of his vocation — although he was profiled as “The Holy Horseman” by UnTacked, a glossy supplement to The Chronicle of the Horse, appearing in his priestly collar as the cover model.
As pastor for Transfiguration, Fr. Tang technically did not supervise the teachers except in their religious role. But as a practical matter, according to testimony including his own, he drove many of the school’s staffing decisions.
Ms. Liggins told jurors that her relationship with Fr. Tang was good at first. He seemed to take an interest in her family, sometimes calling one of her daughters out of class to watch over his “babies” — his Jack Russell terriers, a breed that’s highly valued by fox hunters.
But things changed when the priest learned that she was expecting a child with her boyfriend, an L.A. school district administrator named Adrian Magee, according to Ms. Liggins. At trial, Fr. Tang denied that he judged Ms. Liggins for having an out-of-wedlock birth: “If I had that problem … we wouldn’t have a school,” he said, noting about that half the families at Transfiguration, and at least one other teacher, were in a similar situation.
At the same time, he acknowledged in testimony, he did tell Ms. Liggins not to bring her newborn to school — and he said he was bound, as her pastor, to find that her pregnancy violated “the philosophies and teachings of the Catholic church.”
With two other children enrolled at Transfiguration, Ms. Liggins didn’t want to lose her job. She reported Fr. Tang’s seeming bias to an HR official and to the bishop himself, Fr. Tang’s boss. The bishop’s response, according to filings: He asked her to “pray on it.”
When Ms. Liggins returned to school early from maternity leave, she placed her baby in daycare across the street so that she could leave during lunch to nurse her. But around the same time, she testified, Transfiguration vice principal Evelyn Rickenbacker started scheduling teacher meetings at lunchtime, causing Ms. Liggins to miss out on important updates. Ms. Rickenbacker told her, she said, to “decide which is more important” — the meetings or the nursing.
The vice principal “would always say … ‘I’m sorry things aren’t to your liking, Mrs. Obama,” Ms. Liggins recalled in a deposition.
Both women are African American.
Ms. Liggins began to feel frozen out. At mass on Sundays, she testified, Fr. Tang declined to shake her hand as he did with other parishioners after the service. To make matters worse, her sister Ms. Yerima decided to resign as principal. Ms. Rickenbacker, herself a Transfiguration alumna, was named to fill the slot, and she and Fr. Tang started talking about refreshing the staff, according to Ms. Liggins’ testimony.
Tensions rose quickly. At a meeting that Ms. Liggins believed would be about financial aid for her children, Fr. Tang and Ms. Rickenbacker informed her of parent complaints about “frequent lateness, absences and cell phone use in the class,” according to testimony — but offered no documentation. Blindsided, Ms. Liggins sensed a set-up and flagged the issue to HR immediately.
Five days later, Mr. Magee — Ms. Liggins’ partner and father of their infant daughter — showed up without notice at Ms. Rickenbacker’s classroom to observe Ms. Liggins’ son Jonathan. Ms. Rickenbacker felt intimidated by Mr. Magee’s “glaring,” she told jurors, although she conceded that class observation by family members was an acceptable practice.
Then Mr. Magee accompanied Ms. Liggins to a meeting that Fr. Tang and Ms. Rickenbacker had scheduled to discuss Ms. Liggins’ work performance — and matters really escalated. According to a court filing by Ms. Liggins, the priest told Mr. Magee he couldn’t join the meeting, called him “an uppity-a** Creole n***er,” and banned him from the Transfiguration campus, an incident that jurors didn’t hear about.
Fr. Tang, who is of Chinese descent, then convened some of the school’s administrators and, according to meeting minutes later filed in the case, told them that he was aware of “all the comments and negativity” and “false rumors and petitions” circulating about him, and of “attempts to sabotage his work here.” Any staff member who was insubordinate, he warned — even to the extent of “eye-rolling” — could face termination: As pastor, he said, he had “ultimate authority and power” over the school, including firing power, according to the document.
Indeed, Fr. Tang had been exercising that power lately, jurors heard. Besides directing Ms. Yerima to fire Ms. Liggins’ long-term substitute for “badmouthing” him, he also let go a vice principal in part for “insubordinate behavior,” he said at trial. Another ex-Transfiguration official testified that he was fired after complaining that Fr. Tang had shown up to school meetings — including a PTA meeting — smelling of alcohol and acting “discombobulated.”
Ms. Liggins’ exit from the school took several weeks to play out. She withdrew her kids before the end of the school year, she testified, because they were being “targeted.” Fr. Tang finally provided letters to bolster his claims of parent complaints — but, he admitted in court, they were written after his initial meeting with Ms. Liggins, whose attorney intimated in court that the letters had been obtained in exchange for the priest’s help with debt and scholarships.
In the end, Ms. Liggins learned that her contract would not be renewed via a letter that she received at her parents’ home — and opened in front of her father, she testified, feeling “embarrassed” and “afraid.”
“It was devastating,” she told jurors.
Unable to find a full-time teaching job again, she had to switch all but one of her kids to public school. For a while she continued to attend Fr. Tang’s mass at Transfiguration Church, but it soon became “unbearable” and she found another parish.
“There were times” when she considered suicide, she testified.
The jurors ultimately found for Ms. Liggins on two claims — wrongful termination by the archdiocese and intentional infliction of emotional distress (IIED) by the archdiocese and by Fr. Tang. They awarded her more than $275,000 in economic damages, a further $3.3 million for pain and suffering, and $87,500 as punishment for Fr. Tang specifically.
According to the trial judge, however, Ms. Liggins technically wasn’t terminated: Her contract simply wasn’t renewed for another term, which can’t support a wrongful termination judgment in California, according to his order. Since the jury’s awards were lump sums, not allocated between claims, the judge ordered a new trial on the amount Ms. Liggins should receive for the IIED claim alone. Both sides appealed and the matter likely won’t be resolved until next year.
» Read about Fr. Tang’s horsy lifestyle via the profile in UnTacked, “The Intertwined Passions of Father Michael Tang”
The Employment Law Group® law firm was not involved in Liggins v. Archdiocese of Los Angeles. We select “Bad Boss” cases to illustrate the continuing relevance of employee protection laws for our newsletter’s audience, which includes attorneys and former TELG clients.
Ms. Liggins is represented in this case by Shegerian & Associates