Linda Jean Quigg, Ed.D.v.Thomas County School District, et al.
Linda Quigg alleged that the Thomas County School District and individual school-board members discriminated and retaliated against her under Title VII and Section 1983. The district court granted summary judgment to all defendants, applying the McDonnell Douglas framework to Quigg’s circumstantial-evidence mixed-motive discrimination claims. The Eleventh Circuit held that McDonnell Douglas does not govern those claims; the mixed-motive framework from White applies. Because two board members had voted to renew Quigg’s contract, a triable issue remained whether two others would have voted differently absent bias, defeating the School District’s same-decision defense at summary judgment. The court revived Quigg’s mixed-motive theories against the School District under both statutes, and her corresponding bias-based Section 1983 claims against board members Morgan and Nesmith, remanding those claims. It affirmed summary judgment on her Section 1983 discrimination claims against Streets, Evans, and Hiers and dismissal of all retaliation claims. The judgment was affirmed in part, reversed in part, and remanded.
Loading published copy…

