24-13609
11th Cir.Sep 2, 2025Background
- Roger Williams, a Black ACC police officer, was investigated following an October 17, 2021 domestic-disturbance arrest in which the arrestee struck her head and became unresponsive; Williams admitted he "slammed her" twice but later minimized the force used.
- OPS Sgt. Paul Davidson reviewed bodycam footage, witness statements, and the incident report, concluding Williams used more force than objectively reasonable in two instances and violated ACC de-escalation and custody policies.
- Lt. Jody Thompson added critical comments to the incident report; the report then progressed through multiple supervisors and Deputy Chief Keith Kelley before reaching Interim Chief Jerry Saulters.
- Chief Saulters conducted an independent review (including repeated viewings of the bodycam, consultations with captains and outside chiefs, and a meeting with Williams) and concluded Williams violated policy; human resources terminated Williams.
- Williams sued under Title VII's mixed-motive provision alleging race discrimination, arguing (1) Thompson's alleged racial bias tainted the process (cat’s paw theory) and (2) statistical/other evidence showed a pattern of leniency toward white officers; the district court granted summary judgment for ACC and Williams appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Lt. Thompson's alleged biased remarks created a triable mixed-motive claim via the cat's paw theory | Thompson's comments drove the investigation and influenced the decisionmaker, so his alleged bias was a motivating factor | Chief Saulters independently investigated and made the termination decision based on OPS findings and his review, not solely Thompson's input | No — Chief Saulters conducted an independent, multi-tiered review; no evidence Thompson manipulated the decisionmaker, so cat's paw fails |
| Whether evidence of ACCPD "leniency" toward white officers created a triable issue that race motivated termination | Departmental practice tolerated force by white officers while penalizing Black officers, supporting an inference race was a motivating factor | No evidence links leniency to race; cited incidents were either lawful or insufficient; Williams was the first OPS use-of-force investigation in five years | No — statistical/ comparative evidence was conclusory and lacked a demonstrated connection between any alleged leniency and race; insufficient to survive summary judgment |
Key Cases Cited
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (framework for single-motive disparate-treatment claims)
- Quigg v. Thomas Cnty. Sch. Dist., 814 F.3d 1227 (11th Cir.) (mixed-motive standard and proof that a protected trait was a motivating factor)
- McCreight v. Auburn-Bank, 117 F.4th 1322 (11th Cir.) (summary-judgment standard for circumstantial Title VII mixed-motive claims)
- Stimpson v. City of Tuscaloosa, 186 F.3d 1328 (11th Cir.) (cat's paw theory and need to show manipulation of decisionmaker)
- Llampallas v. Mini-Circuits Lab, Inc., 163 F.3d 1236 (11th Cir.) (employer not liable when decisionmaker independently investigates)
- Wright v. Southland Corp., 187 F.3d 1287 (11th Cir.) (distinguishing reliance on accurate information from a biased source versus being manipulated)
- Jenkins v. Nell, 26 F.4th 1243 (11th Cir.) (example where corroborated racist remarks tied directly to the sole decisionmaker supported denial of summary judgment)
- Berry v. Crestwood Healthcare LP, 84 F.4th 1300 (11th Cir.) (discussing "convincing mosaic" of circumstantial evidence)