Quigg v. Thomas County School District

814 F.3d 1227 (2016)

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Quigg v. Thomas County School District

United States Court of Appeals for the Eleventh Circuit
814 F.3d 1227 (2016)

Facts

Linda Quigg (plaintiff) worked in the Thomas County School District (the district) (defendant) starting in 1998. In 2007, Quigg was appointed superintendent by the school board. In February 2011, the school board met for a renewal vote on Quigg’s contract, which was set to expire later that year. The school board consisted of seven members and voted five-to-two against renewing Quigg’s contract. Certain school board members had encouraged Quigg to bring on a male assistant superintendent to handle tough issues, which she resisted, and made comments suggesting they preferred a male in the assistant superintendent and/or superintendent positions. Quigg filed suit against the district alleging that it had discriminated and retaliated against her in violation of Title VII of the Civil Rights Act of 1964 (Title VII). The district court applied the McDonnell Douglas framework to Quigg’s claims and granted summary judgment for the district. Quigg appealed, arguing that the McDonnell Douglas framework should not be applied to mixed-motive claims involving circumstantial evidence.

Rule of Law

Issue

Holding and Reasoning (Wilson, J.)

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