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Linda Jean Quigg, Ed.D.v.Thomas County School District, et al.

CourtUnited States Court of Appeals for the Eleventh Circuit
Docket No.14-14530
DecidedFebruary 22, 2016
Reporter814 F.3d 1227
JudgesBefore Circuit Judges Wilson and William Pryor and Sixth Circuit Judge Gilman, sitting by designation; Wilson authored
Tags
CivilCivil RightsEmployment LawTitle VIISection 1983Summary JudgmentReversalRemand
Case Summary

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.

Opinion

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