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Media Alerts - Quigg v. Thomas County School District-11th Circuit
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April 7, 2016
  Quigg v. Thomas County School District-11th Circuit
Headline: The Eleventh Circuit holds the McDonnell Douglas framework is inapplicable to mixed-motive discrimination claims that are based on circumstantial evidence.

Area of Law: Employment Law

Issue: Whether the McDonnell Douglas framework is proper for evaluating mixed-motive employment discrimination claims that are based on circumstantial evidence.

Brief Summary: In a mixed-motive claim, the district court applied the framework set out in McDonnell Douglas v. Green, 411 U.S. 792 (1973). The Eleventh Circuit reversed the district court's use of the McDonnell Douglas framework and adopted a less burdensome standard used in other circuits.

Extended Summary: Linda Quigg, ("Quigg") claimed discriminatory and retaliatory practices when the Thomas County School District, and five members of the school board refused to renew her employment contract. The district court applied the McDonnell Douglas framework to Quigg's claim and found that no triable issue of discrimination existed based on the circumstantial evidence presented
On appeal, the Eleventh Circuit held the McDonnell Douglas summary judgment framework is "fatally inconsistent" with mixed-motive theory because the framework predicates on a single "true reason" for an adverse action. The Eleventh Circuit evaluated the framework applied in other circuits and held the proper analysis should only require a plaintiff to provide evidence sufficient to convince a jury that a defendant took adverse action and that a protected characteristic was a motivating factor in the action. Applying this framework, the Eleventh Circuit found Quigg's circumstantial evidence was sufficient to establish a jury issue. Additionally, the Eleventh Circuit affirmed the dismissal of some of Quigg's ยง 1983 claims and all her retaliation claims.

To view full opinion: Click Here

Panel: Wilson, William Pryor, and Gilman (United States Circuit Judge for the Sixth Circuit Court of Appeals, sitting by designation)

Argument: October 06, 2015

Date of Issued Opinion: February 22, 2016

Docket Number: 14-14530

Decided: Affirmed in part, reversed in part

Case Alert Authors: Matthew Carcano, Kevin Coppin, Oscar Quintero, Kielan Saborit.

Counsel: Harlan S. Miller, III for Appellant
Randall C. Farmer; Edward F. Preston for Appellee

Author of Opinion: Circuit Judge Wilson

    Posted By: Gary Kravitz @ 04/07/2016 02:28 PM     11th Circuit  

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