Introduction

In this unpublished but instructive decision, the Eleventh Circuit affirmed summary judgment against a Black police officer, Roger Williams, who alleged mixed‑motive race discrimination under Title VII following his termination for policy violations arising out of a domestic disturbance response. The case sits at the intersection of Title VII evidentiary standards, the “cat’s paw” theory of subordinate bias, and internal police use‑of‑force discipline. The appellate panel held that no reasonable jury could find that Officer Williams’s race was a motivating factor in his termination, given the independent and multilayered investigation culminating in a decision by the interim chief of police, who conducted his own review and relied on objective evidence rather than any allegedly biased subordinate input.

The opinion reinforces several doctrinal points: mixed‑motive claims still must meet Rule 56’s summary judgment standard; “convincing mosaic” is a descriptive metaphor rather than a test; and, crucially, an employer’s independent investigation can sever proximate causation under the cat’s paw theory, foreclosing liability where the decisionmaker did not rubber‑stamp a biased subordinate’s view.

Summary of the Judgment

The Eleventh Circuit (Judges Luck, Kidd, and Marcus; per curiam) affirmed the district court’s summary judgment in favor of the Unified Government of Athens‑Clarke County, Georgia (ACC). The court held that Officer Williams failed to produce sufficient evidence for a reasonable jury to conclude his race was a motivating factor in his termination, as required under Title VII’s mixed‑motive framework (42 U.S.C. § 2000e‑2(m)).

Two central evidentiary theories failed:

• Cat’s paw/subordinate bias: The record showed that the ultimate decisionmaker—Interim Chief Jerry Saulters—conducted an independent, multi‑source review (including repeated body‑cam review, consultations with multiple captains and outside police chiefs, and a meeting with Williams) and relied primarily on the Office of Professional Standards (OPS) investigation. Therefore, any alleged bias by Lieutenant Jody Thompson did not proximately cause the termination.
• Pattern/leniency claim: Williams’s assertion that ACCPD was “disproportionately lenient” toward white officers in use‑of‑force incidents lacked evidentiary support. The cited comparator incident (a taser deployment) was found compliant with policy; and there was no evidence of similarly situated officers of another race violating the same policies and being spared termination.

Distinguishing Jenkins v. Nell—where the biased supervisor was the decisionmaker and a robust record showed a pattern of race‑based treatment—the court found no comparable tie between alleged bias and the adverse decision here. The judgment for ACC was affirmed.

Case Background

On October 17, 2021, Officer Williams responded to a domestic disturbance. After deciding to take the female resident, Liana Beam, into custody, Williams’s interactions culminated in two instances where Beam hit her head—once against the ground and once on asphalt. Williams acknowledged he “slammed her” twice at the scene, later characterizing his actions as “guiding” her down while she resisted, attributing the impacts to her momentum. EMS cleared Beam for custody on scene.

Pursuant to policy, Williams filed a use‑of‑force report, which moved up the chain of command. Lieutenant Thompson appended comments identifying several policy concerns (limited de‑escalation, escalation of force, threat of force, and handling near the patrol car). Captain Derek Scott recommended an OPS investigation.

OPS Sergeant Paul Davidson conducted a comprehensive inquiry (body‑cam review, scene visit, witness interviews). He found two uses of force reasonable but concluded Williams used excessive force during the two takedowns to asphalt, failed to adequately deploy de‑escalation after the first fall, and failed to monitor/care for Beam’s safety in custody—each violating ACC policies.

Interim Chief Saulters independently reviewed the materials and the body‑cam footage multiple times, met with Williams (who said he would not have acted differently), consulted six captains and outside police chiefs, and concluded termination was appropriate. Human Resources issued the termination letter on May 6, 2022.

Williams filed a single‑count Title VII mixed‑motive claim alleging race discrimination. The district court entered summary judgment for ACC. Williams appealed.

Analysis

Precedents Cited and Their Role

• Mixed‑motive framework and proof burdens
  • Quigg v. Thomas County School District, 814 F.3d 1227 (11th Cir. 2016): Mixed‑motive claims are not evaluated under McDonnell Douglas; courts instead ask whether a protected characteristic was a motivating factor for the adverse action. Also recognizes that discriminatory statements by those involved in the decision process can be relevant.
  • McCreight v. AuburnBank, 117 F.4th 1322 (11th Cir. 2024): Mixed‑motive theories lessen the causation standard, not the standard of proof; sparse evidence of group animus is insufficient without a nexus to the adverse action.
  • Yelling v. St. Vincent’s Health System, 82 F.4th 1329 (11th Cir. 2023): For mixed‑motive, the protected trait need only have “contributed in some way” to the outcome.
• Evidence frameworks and summary judgment
  • Berry v. Crestwood Healthcare LP, 84 F.4th 1300 (11th Cir. 2023): “Convincing mosaic” is a metaphor—not an independent legal test—describing how circumstantial evidence can allow a reasonable inference of discrimination.
  • Lewis v. City of Union City, 934 F.3d 1169 (11th Cir. 2019): Examples of a “mosaic” include suspicious timing, better treatment of comparators, and evidence of pretext.
  • Smith v. Lockheed-Martin Corp., 644 F.3d 1321 (11th Cir. 2011): If circumstantial evidence reasonably supports an inference of discrimination, summary judgment is inappropriate.
  • Tynes v. Florida Department of Juvenile Justice, 88 F.4th 939 (11th Cir. 2023) and McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973): Single‑motive burden‑shifting framework; here, the court notes mixed‑motive claims do not use McDonnell Douglas.
  • Valley Drug Co. v. Geneva Pharmaceuticals, 344 F.3d 1294 (11th Cir. 2003); Signor v. Safeco Insurance Co. of Ill., 72 F.4th 1223 (11th Cir. 2023); Allen v. Tyson Foods, Inc., 121 F.3d 642 (11th Cir. 1997): Summary judgment standards and the insufficiency of a “mere scintilla” of evidence.
• Cat’s paw, proximate causation, and independent investigations
  • Sims v. MVM, Inc., 704 F.3d 1327 (11th Cir. 2013): Proximate cause governs whether a protected characteristic was a motivating factor.
  • Ziyadat v. Diamondrock Hospitality Co., 3 F.4th 1291 (11th Cir. 2021): Discriminatory conduct by lower‑level employees can be the proximate cause where it influences the decisionmaker.
  • Stimpson v. City of Tuscaloosa, 186 F.3d 1328 (11th Cir. 1999): Cat’s paw liability exists when the decisionmaker follows a biased recommendation rather than independently reaching the decision.
  • Llampallas v. Mini-Circuits Lab, Inc., 163 F.3d 1236 (11th Cir. 1998): An employer’s independent investigation can break the chain of causation from a biased subordinate.
  • Wright v. Southland Corp., 187 F.3d 1287 (11th Cir. 1999): Requires proof that the biased subordinate manipulated the decisionmaker; mere consideration of accurate information from the subordinate is not enough.
• Comparator‑based mosaics distinguished
  • Jenkins v. Nell, 26 F.4th 1243 (11th Cir. 2022): Plaintiff survived summary judgment via a convincing mosaic where the biased supervisor was the actual decisionmaker; evidence included corroborated racially charged remarks, disparate discipline, and the exodus of white employees. Distinguished here because the alleged bias was not linked to the decisionmaker, and the record lacked comparable pattern evidence.

Legal Reasoning

The court’s reasoning proceeds in two main steps aligned with the plaintiff’s theories of motive:

1) Cat’s Paw Theory Fails Due to Independent Decisionmaking

Williams argued that Lieutenant Thompson’s alleged racial bias infected the process through his critical comments on the use‑of‑force report. The panel assumed arguendo that Thompson had made racially offensive comments in the past, but held that Williams could not satisfy proximate causation because Interim Chief Saulters independently decided to terminate Williams.

The independence was evidenced by:

• OPS Sergeant Davidson’s separate investigation, with mixed findings: two uses of force reasonable; two to asphalt excessive; plus de‑escalation and custody‑care violations.
• Saulters’s personal review of the entire file and the body‑camera footage “probably 20 times.”
• Consultations with six captains and with chiefs at the University of Georgia Police Department.
• A direct meeting with Williams, during which Williams confirmed he would not do anything differently.

Under Stimpson and Llampallas, such independent review severs the causal chain. Wright further requires manipulation by the biased subordinate, not merely that their comments were in the file. The record supported that Saulters relied principally on OPS findings and his own assessment of objective evidence (body‑cam), not on Thompson’s narrative. Accordingly, Thompson’s alleged bias did not proximately cause the termination (Sims; Ziyadat).

2) Pattern/Leniency Theory Fails for Lack of Comparators and Nexus

Williams asserted that ACCPD had a “disproportionately lenient” approach to white officers in use‑of‑force cases, implying that his race was a motivating factor. But:

• Williams identified no similarly situated officer—of a different race—who violated the same policies under comparable circumstances but received milder discipline.
• His one example (a taser deployment) was deemed policy‑compliant; thus, it does not show disparate leniency for policy violations.
• Chief Saulters testified that in five years, Williams’s case was the only OPS investigation for use‑of‑force policy violations—limiting the comparator universe.

Without concrete comparators or statistical showings linking race to discipline decisions, the record amounted to “bits and pieces” insufficient to let a jury infer discriminatory motive. The court emphasized that the mixed‑motive standard is a lower causation standard, not a lighter proof burden (McCreight), and “convincing mosaic” is merely descriptive (Berry). The necessary connective tissue between race and the adverse action was missing.

Impact and Implications

Although unpublished, the decision is a clear, contemporary synthesis of Eleventh Circuit doctrine relevant to employment discrimination suits, particularly in law enforcement disciplinary contexts.

• Cat’s paw boundaries strengthened: Employers who conduct genuine, independent reviews—especially those using objective evidence (e.g., body‑cam footage), multiple supervisory layers, outside consultation, and HR oversight—are well‑positioned to defeat allegations that a biased subordinate tainted the outcome. Independence breaks proximate cause.
• Mixed‑motive remains proof‑driven: Plaintiffs must marshal sufficient evidence that race contributed to the decision—not merely that biased comments exist somewhere in the organization. Demonstrating that the alleged bias reached and influenced the decisionmaker is essential.
• Comparator and pattern evidence must be concrete: Assertions of general leniency toward another racial group, without valid comparators or robust data, will not survive summary judgment. Plaintiffs need details: same policies, similar conduct, similar ranks, and comparable contexts.
• Internal police discipline context: In agencies with formal use‑of‑force review processes, detailed records, and OPS or IA investigations, the institutional architecture itself can provide the “independence” that defeats cat’s paw claims—if, in fact, supervisors exercise independent judgment.
• Strategic litigation lessons:
  • For plaintiffs: Focus on proving the decisionmaker’s reliance on biased input, or show the “independent investigation” was perfunctory, incomplete, or pretextual. Develop meaningful comparator evidence and tie alleged racial animus to the specific adverse action.
  • For employers: Document the independence of the review—what materials were examined, who was consulted, and how the decision was reached. Ensure OPS/IA processes are robust and insulated from potential bias.

Complex Concepts Simplified

• Mixed‑Motive (Title VII): You win if you show race was one of the reasons (a “motivating factor”) for the decision—even if other legitimate reasons also played a role. But you still need enough evidence for a jury to reasonably find that race contributed to the outcome.
• Single‑Motive vs. Mixed‑Motive: Single‑motive (pretext) claims try to prove the employer’s stated reason is false and the real reason is discrimination. Mixed‑motive accepts that multiple reasons may exist and aims to show the protected trait was among them.
• “Convincing Mosaic”: Not a separate legal test. It’s a way to describe how various pieces of circumstantial evidence—timing, comparator treatment, suspicious remarks—can form a coherent picture suggesting discrimination.
• Cat’s Paw Theory: An employer can be liable if a biased subordinate uses the formal decisionmaker as a “cat’s paw,” manipulating the process so that the subordinate’s bias causes the adverse action. A truly independent investigation by the decisionmaker can break this chain.
• Proximate Cause: A legal concept requiring a sufficiently direct connection between the discriminatory input and the adverse decision. If an independent investigation breaks that link, proximate cause fails.
• Comparators: Other employees who engaged in similar misconduct under similar circumstances but were treated better. Valid comparators must be closely matched in role, policy, and context.
• Summary Judgment: A judge can decide a case without a trial if there are no genuine disputes of material fact and one side is entitled to win as a matter of law. “A mere scintilla” of evidence is not enough to get to a jury.

Conclusion

The Eleventh Circuit’s affirmance in Williams v. Unified Government of Athens‑Clarke County underscores three enduring principles in Title VII mixed‑motive litigation: evidence must link alleged bias to the decisionmaker; independent investigations substantially undermine cat’s paw causation; and generalized claims of disparate leniency are insufficient without concrete comparators or robust, contextualized data. The court’s careful application of Quigg, McCreight, and the cat’s paw line of cases (Stimpson, Llampallas, Wright) provides a practical roadmap for both sides of employment disputes—especially in law enforcement settings where body‑camera footage, formal OPS processes, and multi‑tiered reviews can provide, or challenge, the requisite causal link.

Key takeaways:

• Independent, well‑documented decisionmaking is the most effective shield against cat’s paw liability.
• Mixed‑motive is not a shortcut; plaintiffs still need substantial, connected evidence that race contributed to the specific adverse decision.
• Comparator and pattern evidence must be precise and grounded in policy‑equivalent, fact‑similar scenarios.

While unpublished, the decision offers persuasive guidance: in Title VII mixed‑motive claims, courts will look past allegations of bias in the chain of command and focus on whether the ultimate decisionmaker’s process and sources of information demonstrate genuine independence and objectivity.