## Facts

- Dr. Linda Jean Quigg worked for the Thomas County School District from 1998, serving as superintendent from 2007 until the board declined to renew her contract in 2011.
- The elected school board hired the superintendent on a term contract subject to renewal; Quigg’s contract was extended to mid-2011.
- In performance evaluations from 2008 through 2010, the board rated Quigg overall as satisfactory or above satisfactory.
- In February 2011, the seven-member board voted 5–2 not to renew Quigg’s contract, ending her tenure.
- Quigg presented circumstantial evidence that certain board members expressed a preference for male leadership, including suggestions that she hire a “strong male” assistant superintendent to handle “tough issues” and statements that the board “wanted a man” in top leadership.
- Quigg also alleged retaliation after she complained about discrimination, including an ethics complaint filed against her.

## Issues

1. What summary-judgment framework governs a Title VII mixed-motive discrimination claim supported by circumstantial evidence in the Eleventh Circuit?
2. Under the proper framework, did Quigg present sufficient evidence for a jury to find that sex was a motivating factor in the nonrenewal decision as to the School District and particular board members?
3. Was summary judgment proper on Quigg’s retaliation claims?

## Decision

- The Eleventh Circuit held that Title VII mixed-motive claims based on circumstantial evidence are not evaluated under the McDonnell Douglas pretext framework at summary judgment.
- The court adopted the Sixth Circuit’s White v. Baxter Healthcare approach: a plaintiff must show evidence from which a jury could find (1) an adverse employment action and (2) that a protected trait was a motivating factor for that action.
- Applying that approach, the court reversed summary judgment on Quigg’s sex-discrimination claims against the School District and board members Scott Morgan and Mark Nesmith.
- The court affirmed summary judgment on Quigg’s sex-discrimination claims against the remaining board members due to insufficient evidence tying each of them to discriminatory motive.
- The court affirmed summary judgment on all retaliation claims.
- The case was affirmed in part, reversed in part, and remanded.

## Legal Principles

- A Title VII plaintiff may proceed on a mixed-motive theory using circumstantial evidence to show that a protected characteristic was a motivating factor in an adverse employment action.
- At summary judgment in a mixed-motive case, the question is whether the evidence would permit a reasonable jury to find the protected trait was a motivating factor; the plaintiff need not disprove all asserted nondiscriminatory reasons as required in single-motive pretext analysis.
- For individual-liability theories pursued in parallel, a plaintiff must present evidence linking each specific decisionmaker to discriminatory intent; generalized evidence about the group is insufficient absent a basis to attribute motive to each defendant.
- Retaliation claims require evidence supporting a causal connection between protected activity and the challenged adverse action; speculative inferences or weak temporal links will not defeat summary judgment.

## Conclusion

The Eleventh Circuit clarified that mixed-motive Title VII discrimination claims supported by circumstantial evidence are evaluated under a motivating-factor summary-judgment test rather than McDonnell Douglas, reinstating Quigg’s sex-discrimination claims against the School District and two board members while leaving intact judgment for the remaining defendants and all retaliation claims.


Quigg v. Thomas Cnty. Sch. Dist., 814 F.3d 1227 (11th Cir. 2016)