Linda Jean Quigg, Ed.D. v. Thomas County School District
2016 U.S. App. LEXIS 3007
11th Cir.2016Background
- Quigg served as Assistant Superintendent (1998–2007) and then Superintendent; School Board renewal governed by term contracts with a vote to renew.
- Board granted a three-year contract to Quigg, later extending it to mid-2011.
- From 2008–2010 Quigg received satisfactory evaluations, but she had a strained relationship with several Board members and faced unrelated concerns about program administration.
- Prior to the February 2011 renewal vote, Morgan and Nesmith pressed for an assistant superintendent with a male candidate; Quigg proposed a different organizational plan.
- The Board voted 5–2 against renewal in February 2011; Streets, Evans, Nesmith, Morgan, and Hiers opposed; Hiers later said the vote reflected a need for a strong male to work under Quigg; Quigg then filed EEOC/PSC complaints alleging sex discrimination and retaliation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Appropriate framework for mixed-motive circumstantial claims | Quigg argues McDonnell Douglas is inappropriate for mixed-motive circumstantial claims. | District follows McDonnell Douglas as the standard framework for discrimination claims. | White framework adopted; McDonnell Douglas inappropriate for mixed-motive circumstantial claims. |
| School District liability for sex discrimination based on mixed motive | Quigg established a triable issue that sex/gender was a motivating factor. | District argues same-decision defense and non-discriminatory reasons control. | Triable issue as to discrimination against Quigg; mixed-motive claim survives against the District. |
| Validity of the 'same decision' defense for § 1983 and Title VII claims | Defense fails for Nesmith and Morgan; bias could influence votes. | District argues the Board would have voted against renewal regardless of bias. | Same-decision defense fails for Nesmith and Morgan; Streets, Evans, Hiers would have voted against regardless; defenses as to those members succeed. |
Key Cases Cited
- Price Waterhouse v. Hopkins, 490 U.S. 228 (1989) (mixed-motive framework; direct evidence discussion; statute context)
- Desert Palace, Inc. v. Costa, 539 U.S. 90 (2003) (allows direct or circumstantial evidence in mixed-motive cases; sets framework context)
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (establishes burden-shifting for single-motive discrimination)