Clara's letter also cites data showing west-side schools have more teachers rated as ineffective. His objections include:
• "The highest concentration of the least experienced teachers are employed in schools with the highest number of students of color, which is on the city's west side."
• "West-side schools also face the highest rate of teacher turnover."
• The combination of inexperience and high turnover "has existed for many years" in west-side schools.
• "Since, on average, the teachers at schools with higher numbers of white students are more experienced, the amounts spent on teacher salaries in east-side schools are greater."
By keeping the teacher distribution system and refusing to discuss it now on the school board level, the school district is violating a section of the Civil Rights Act that prohibits discrimination in federally funded programs, Clara argues.
Superintendent McKell Withers could not be reached for comment, but district spokesman Jason Olsen released a statement.
"We are disappointed that [Clara] feels the need to seek solutions by contacting federal officials in Denver instead of working collaboratively with the Board of Education and the district," the statement reads. "We believe Mr. Clara's complaints can and should be addressed through established board protocol. We are committed to advocating for all students."
After the board's Feb. 19 discussion of student achievement, according to his letter, Clara asked why there appeared to be a disproportionate number of teachers labeled "ineffective" in west-side schools.
Christine Marriott, a data coordinator, gave this response, according to his letter:
"One of our big problems with our distribution system for teachers, is that we have a lot of new teachers in west-side schools every single year. … The rubber really hits the road when you are looking at whether our west-side disadvantage[d] students are with the most effective teachers we can put in front of them."
She added: "We need to do something to turn around that very pattern that you can see."
On Feb. 20, Clara asked for the issue of equitable distribution of experienced teachers to be placed on the board's Feb. 24 agenda, he said. The school board president, Kristi Swett, rejected the request, explaining it would require "a rapid realignment of agenda priorities," he wrote. He then filed the complaint.
Clara said in an interview the data he cites on "ineffective" teachers in west-side schools are preliminary and notes he was not allowed access to all the district's information. The ratings are based on a student growth model, which gauges teachers from "highly effective" to "ineffective" based on student test scores.
Two examples he noted:
• At the west side's Meadowlark Elementary, 497 N. Morton Drive, "as high as 67 percent of teachers... were classified as 'ineffective.'"
• At east-side school Dilworth Elementary, 1953 S. 2100 East, 0 percent of the teachers were classified as ineffective within the subject of science.
The schools' principals and Mike Kelley, Utah Education Association spokesman, could not be reached for comment Tuesday.
Clara said the school board was alerted to the disparities a year ago, citing a report presented at a January 2012 meeting that noted, "Students in Title I schools have a five times higher chance of being with a marginal or ineffective teacher."
"Equal educational opportunity requires that the quality of schooling provided to students be similar across schools," he wrote. "In particular, it would require that students in high-poverty schools have access to teachers and principals of similar quality to those in schools serving more-advantaged students."