Quigg v. Thomas Cnty. Sch. Dist., No. 14-14530 (11th Cir. 2016)Annotate this Case
Plaintiff filed suit under Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., and 42 U.S.C. 1983, against the School District and the School Board, alleging that they discriminated and retaliated against her by refusing to renew her employment contract and filing an ethics complaint against her. The district court granted summary judgment for defendants. The court concluded that the proper framework for examining mixed-motive claims based on circumstantial evidence is the approach adopted by the Sixth Circuit in White v. Baxter Healthcare Corp., - not the McDonnell Douglas framework. Applying the proper mixed-motive framework to plaintiff's discrimination claims, the court held that the district court erred in granting summary judgment on her claims against the School District and School Board members Scott Morgan and Mark Nesmith. However, the court found that the district court properly dismissed plaintiff's remaining discrimination claims, as well as all of her retaliation claims. Therefore, the court affirmed in part and reversed in part.