A groundbreaking 11th Circuit Court of Appeals ruling, which revived a Georgia school superintendent’s sex discrimination case, has paved the way to a $400,000 settlement award for the former superintendent, the Thomasville Times-Enterprise reported. The settlement marks the end to litigation that allowed the 11th Circuit to weigh in on how courts should handle cases like this one, in which there was a mixture of valid bases for the adverse employment action along with clear proof of gender-based bias.
The employee, Linda Quigg, was the superintendent of schools for the Thomas County School District from 2007-2011 after having spent nine years before that as assistant superintendent. After the school board voted 5-2 not to renew her contract in 2011, she sued for sex discrimination under Title VII. There were strong pieces of evidence on each side. The board had on its side several years of declining enrollment, ethical concerns about Quigg, and a history of middling performance reviews. The superintendent had several instances in which board members indicated a “need” to put a man in the superintendent position and instances in which board members had tried to insist that she hire a male assistant superintendent to be “tough” and “offset” Quigg.
In other words, Quigg’s case was a textbook example of what the law calls a “mixed-motive” case of discrimination. Nevertheless, the trial court awarded summary judgment to the school district, determining that the superintendent failed to prove, as required under the McDonnell Douglas v. Green standard for establishing employment discrimination, that the district’s stated non-discriminatory reasons for not renewing her contract were merely pretexts for sex discrimination.
The 11th Circuit reversed, deciding that the McDonnell Douglas framework was not the correct method for analyzing cases like Quigg’s. The correct analysis, according to the court, was to determine whether the employee’s membership in a protected group was a motivating factor in the adverse employment decision. In other words, was Quigg’s gender one of the factors that motivated the district to decide not to renew her contract? With that instruction, the 11th Circuit sent the case back to the District Court.
And, last month, the two sides consummated a settlement agreement. The school district’s insurer agreed to pay Quigg $400,000, while both sides acknowledged, as is typical in most settlement agreements, that the resolution was not an admission of liability by any party. The district, for its part, concluded that the settlement was the best way to focus on its actual mission. Quigg’s case “consumed hundreds of hours of school system personnel time and other resources. If the case had proceeded to trial, it would have continued to consume personnel time and system resources through trial and subsequent appeals.”
The resolution of this case illustrates one of the most important hurdles for any employee in a discrimination case, which is avoiding having your case thrown out on a motion to dismiss or motion for summary judgment. If you can successfully avoid these outcomes and move your case toward trial, you may be able to achieve a successful outcome through settlement, since your employer may decide that settling makes more business sense that expending time, money and employee hours needed to address all that is involved in the pre-trial and trial processes.
If you are an employee in Georgia, and you’ve been a victim of workplace sex discrimination, talk to the hardworking Georgia sex discrimination attorneys at Parks, Chesin & Walbert. Our attorneys have the knowledge, skills, and determination to help you seek an outcome that works for you. To speak with one of our lawyers about your case, call 404-873-8048.
More blog posts:
Sixth Circuit Ruling Highlights When Title VII Does (and Doesn’t) Protect Partners in a Partnership, Atlanta Employment Attorneys Blog, Dec. 7, 2016
New 11th Circuit Decision Changes the Way Some Discrimination Cases Will Be Decided in Georgia, Atlanta Employment Attorneys Blog, March 10, 2016