Matthew Bottoms

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In Quigg v. Thomas County School District, the United States Court of Appeals for the Eleventh Circuit changed the summary judgment framework for mixed-motive employment discrimination cases. The ruling in Quigg will affect both employers and employees and will lead to more mixed-motive discrimination claims reaching the jury, rather than being dismissed through summary judgment. The newly-adopted framework takes the burden-shifting standard out of summary judgment, and many commentators consider it a much more plaintiff-friendly framework. Under the new framework, in order to survive a motion for summary judgment on a mixed-motive discrimination claim, all the plaintiff must do is show that a protected characteristic was a "motivating factor" for an adverse employment action. This standard is significantly lower than the standard that was previously used in the Eleventh Circuit, and it does not force the plaintiff to point to one "true" reason that led to the employment discrimination.