Title VI Discrimination, Retaliation, and “Cat’s Paw” Liability in the School–Contractor Context: Commentary on Quinn v. Columbia County School District

I. Introduction

The Eleventh Circuit’s unpublished, per curiam decision in Janelle Quinn v. Columbia County School District, No. 24‑11570 (11th Cir. Nov. 19, 2025), addresses a highly charged factual scenario: a Black elementary school student subjected to an unusual, invasive interaction by a White school counselor, and a mother who is both the child’s parent and a contractor providing counseling services in the same school system.

Although designated “NOT FOR PUBLICATION” and therefore not binding precedent, the opinion is important because it:

• applies and reinforces the demanding evidentiary standards for proving intentional race discrimination under Title VI in the school context,
• clarifies how “deliberate indifference,” McDonnell Douglas burden-shifting, and “convincing mosaic” approaches interact in circumstantial evidence cases,
• illustrates the limits of Title VI retaliation claims when the allegedly retaliatory employment action is taken by a third-party employer (a federal contractor) rather than by the school district itself, and
• highlights, yet deliberately leaves unresolved, an emerging question: whether a parent who is also a non-employee contractor has a personal Title VI retaliation cause of action against a school district.

At bottom, the Eleventh Circuit affirms summary judgment for the Columbia County School District (“the District”) on:

• a Title VI race discrimination claim brought on behalf of the child, D.J.Q., and
• Title VI retaliation claims brought on behalf of both the child and the mother, Quinn.

The decision underscores that troubling or inappropriate conduct by school personnel will not, standing alone, support Title VI liability without evidence linking the conduct, or the school’s response, to race-based animus and meeting stringent legal standards.

II. Summary of the Opinion

The Eleventh Circuit holds:

1. Discrimination claim (on behalf of the child):
   The District is entitled to summary judgment under any circumstantial-evidence framework (including the McDonnell Douglas burden-shifting test, the deliberate-indifference standard, and the “convincing mosaic” approach). Quinn failed to:
   • identify a similarly situated comparator student treated better than her son,
   • show that the District’s remedial response to the counselor’s conduct rose to the level of “deliberate indifference,” or
   • present sufficient circumstantial evidence from which a reasonable jury could infer that the conduct or the response was racially motivated.
2. Retaliation claims (on behalf of Quinn and her son):
   The court bypasses the unresolved question whether Quinn, as a parent and contractor rather than an employee, has a personal Title VI retaliation cause of action. Assuming she does, summary judgment is still proper because:
   • The “adverse employment action” (removing Quinn from Parkway Elementary) was taken by her employer, Magellan Federal, and ultimately approved by the Department of Defense—not by the District.
   • There is no evidence that the District was the “driving force” behind Magellan’s decision under a “cat’s paw” theory; instead, Magellan and the federal government independently applied a pre-existing conflict-of-interest policy.
   • Quinn offers no evidence that Magellan’s stated reason (its no-child-at-parent’s-school policy) is pretext for retaliation.
   As to the retaliation claim brought on behalf of the student, the court finds no materially adverse retaliatory action directed at the child at all.
3. Procedural/analytical points:
   
   • The district court’s reference to a “standing” defect in the retaliation claim is treated as a mislabeling of a cause-of-action issue under Lexmark, not as a jurisdictional problem.
   • Any potential errors in framing were harmless; the Eleventh Circuit reviews the summary judgment record de novo and affirms on alternative grounds.

III. Factual and Procedural Background

A. The Lunchroom Incident

During the 2020–21 school year, Quinn’s son, D.J.Q., a Black student, attended Parkway Elementary School in Columbia County, Georgia. Quinn herself, also Black, was a Military and Family Life Counselor (“MFLC”) employed by Magellan Federal (“Magellan”), a private contractor under the Department of Defense’s MFLC program. Magellan assigned Quinn to work at two Columbia County schools: Parkway (where her son attended) and Greenbrier Elementary.

In January 2021, at lunch, D.J.Q. asked Julie Owens, a White counselor employed by the District at Parkway, for a different eating utensil. Instead of giving him a new utensil, Owens:

• took the utensil from D.J.Q.,
• placed it in his mouth,
• removed it, and
• put it back in his hand, telling him to “clean” the utensil he had.

This occurred during the COVID‑19 pandemic, adding an obvious health and dignity dimension to the incident. That day, D.J.Q. told his mother he had “the worst day ever,” described what happened, and expressed discomfort and anxiety about being around Owens.

B. The District’s Initial Response

The next day, Quinn and her husband met with the school principal, Dr. Michael Doolittle. Key aspects of this meeting:

• Neither Quinn nor her husband initially characterized the incident as racially motivated.
• Owens apologized to both Quinn and D.J.Q.; Doolittle believed that the child accepted the apology.
• Doolittle reported the incident up the chain (to his supervisor, Dr. Deborah Williams, and the Superintendent, Sandra Carraway).
• The District reviewed video footage of the lunchroom incident.
• The District took steps to minimize or eliminate contact between Owens and D.J.Q. (the details are somewhat disputed but include changes to Owens’s lunch duty, permitting the child to leave class when Owens entered, and instructing Owens to avoid the child).

On January 24, 2021, Quinn sent a letter to the Board of Education describing the incident as “humiliating” and particularly alarming given the pandemic. She asserted that an apology was “a far cry from enough” and urged the Board to condemn the behavior, but she did not yet explicitly frame it as racially discriminatory or specify any disciplinary action.

C. Later Allegations of Racial Animus and Additional Complaints

At a subsequent meeting in late February 2021, Quinn for the first time characterized Owens’s conduct as a “racist act.” Quinn:

• stated she had no knowledge of other race-based conduct by Owens,
• reported no prior complaints from her son about Owens, but
• asserted that Owens had previously made comments suggestive of racial bias, including saying there were “too many Mexicans in Walmart.”

Doolittle reported never having received discrimination complaints against Owens. Quinn acknowledged she had not witnessed how Owens treated other students, of any race.

Feeling the District’s response was inadequate, Quinn escalated:

• she complained to the Georgia Professional Standards Commission,
• she contacted the U.S. Department of Justice, and
• in April 2021, she filed a police report with the Columbia County Sheriff’s Office, seeking assault or battery charges against Owens.

The police report left Owens “distraught,” and she was sent home from the school that day. Around this time, Doolittle informed Associate Superintendent Michele Sherman of the continuing situation.

D. Perceived Disruption and the “Separation” of Quinn and Parkway

The District and Quinn disputed the degree of disruption Quinn’s actions caused at Parkway:

• Quinn admitted she was angry and believed Owens should be fired but denied disrupting school operations.
• Doolittle believed Quinn was “causing a disruption” by being “everywhere that [her son] would go,” rather than performing her assigned counseling duties.
• Doolittle reported to Sherman that Quinn was following her child’s class and observing matters outside her MFLC responsibilities.

The District’s efforts to separate Owens and the child appear largely successful; there was only a single additional, vaguely described contact, about which Quinn acknowledged she did not know “what the scenario was.”

The District concluded that no formal discipline of Owens was necessary, viewing its scheduling changes as sufficient. Quinn, however, wanted Owens terminated or otherwise formally disciplined. Near the end of the school year, the District acceded to Quinn’s request to transfer D.J.Q. to a different school for the next academic year.

E. Magellan’s Conflict-of-Interest Policy and Quinn’s Reassignment

Parallel to these events, Quinn’s employment relationship with Magellan came under scrutiny:

• Sherman contacted Beth Welch, a Magellan representative, to “calm the situation” and discuss events at Parkway. The District had “no complaints” about Quinn’s actual job performance.
• This call alerted Magellan for the first time that Quinn was working at the same school her child attended.
• While the District had no policy forbidding employees or contractors from working at their own children’s school, Magellan did: a strict policy prohibiting MFLC counselors from being assigned to a school where their child is enrolled.
• Welch testified that Magellan would never knowingly assign a counselor to their child’s school, and she was unaware of any exceptions.

Quinn contended:

• she had not been told of such a policy,
• Magellan’s written conflict-of-interest policy did not explicitly cover this exact scenario, and
• her objectivity had not been compromised.

She conceded she did not affirmatively tell Magellan that her son attended Parkway. No other example existed of a Magellan counselor working at their child’s school, which Welch attributed to Magellan’s consistent enforcement of its policy.

Under its federal contract, Magellan reported the situation to the Department of Defense, which manages the MFLC program and is itself covered by Title VI. Welch recommended that Quinn complete the school year at Greenbrier only. The federal government investigated and agreed. During the investigation (late April–early May 2021), Magellan:

• instructed Quinn not to return to Parkway,
• continued to pay her salary, and
• did not charge her leave time.

Crucially, the District:

• did not employ Quinn,
• had no contractual relationship with Magellan, and
• was unaware of Magellan’s internal policy.

For the following school year (2021–22), Quinn remained employed by Magellan but was assigned to a different school district.

F. District Court Proceedings

Quinn filed suit near the end of the 2021–22 school year, alleging:

• Count I: Title VI racial discrimination on behalf of her son, D.J.Q., and
• Count II: Title VI retaliation on behalf of both herself and D.J.Q.

The District moved for summary judgment. The district court:

• granted summary judgment on the discrimination claim, holding Quinn had no direct or circumstantial evidence of racial discrimination and that the District was not deliberately indifferent, and
• granted summary judgment on the retaliation claims based on Consolidated Rail Corp. v. Darrone, 465 U.S. 624, 632 n.13 (1984), reasoning that Quinn and her son had no Title VI retaliation cause of action because the federal funds at issue were not primarily intended to provide employment.

The district court characterized the retaliation defect as one of “standing.” Quinn appealed.

IV. Legal Framework

A. Summary Judgment

The court reiterates the familiar Rule 56 standard:

• De novo review of summary judgment, with all facts and reasonable inferences drawn in favor of the non-movant (here, Quinn). Guevara v. Lafise Corp., 127 F.4th 824, 828–29 (11th Cir. 2025).
• A “genuine” dispute exists only if a reasonable jury could return a verdict for the non-movant. Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 252 (1986).
• “The mere existence of a scintilla of evidence” is insufficient; evidence must permit a reasonable jury to find for the plaintiff. Id.
• An appellate court may affirm on any ground supported by the record, even if the district court relied on the wrong rationale. Alvarez v. Royal Atlantic Developers, Inc., 610 F.3d 1253, 1264 (11th Cir. 2010).

B. Title VI Discrimination

Title VI of the Civil Rights Act of 1964 prohibits discrimination on the ground of race, color, or national origin in programs or activities receiving federal financial assistance. In the school setting, courts frequently import Title VII and Title IX analytical frameworks:

• McDonnell Douglas burden-shifting: Used for circumstantial evidence claims of intentional discrimination (originally in Title VII employment cases, now adapted across contexts). The plaintiff must first establish a prima facie case, including a similarly situated comparator treated more favorably.
• Deliberate indifference: In cases alleging institutional liability (commonly under Title IX and sometimes Title VI), the plaintiff may show that the institution had actual knowledge of discrimination and responded with “deliberate indifference” to an objectively serious risk or violation. Gebser v. Lago Vista Indep. Sch. Dist., 524 U.S. 274, 290 (1998); L.S. ex rel. Hernandez v. Peterson, 982 F.3d 1323, 1330 (11th Cir. 2020).
• “Convincing mosaic” approach: Even without strict adherence to McDonnell Douglas, a plaintiff can survive summary judgment by assembling a mosaic of circumstantial evidence from which a reasonable jury could infer intentional discrimination. McCreight v. AuburnBank, 117 F.4th 1322, 1335 (11th Cir. 2024).

C. Title VI Retaliation

Title VI, by its text, does not contain an express retaliation provision comparable to Title VII or Title IX. However:

• The Supreme Court has recognized implied retaliation causes of action under analogous statutes, most notably Title IX. Jackson v. Birmingham Bd. of Educ., 544 U.S. 167 (2005).
• The question whether similar retaliation claims are cognizable under Title VI, and by whom, remains less clearly defined.
• Retaliation claims generally require:
  1. Protected activity (complaining about discrimination, filing charges, etc.),
  2. a materially adverse action, and
  3. a causal connection between the two. See Johnson v. Miami‑Dade County, 948 F.3d 1318, 1325 (11th Cir. 2020).
• When the alleged retaliation is an employment action, Title VII doctrinal tools (such as cat’s paw liability and pretext analysis) often guide the analysis by analogy.

D. Statutory “Standing” vs. Cause of Action under Title VI

The district court viewed Quinn’s retaliation claim as failing for lack of “standing,” relying on Consolidated Rail Corp. v. Darrone, 465 U.S. 624 (1984), which addressed the limited scope of employment-related suits under a different funding statute.

The Eleventh Circuit clarifies:

• The issue is not Article III standing (jurisdiction), but whether Title VI grants the cause of action asserted—a question often described as whether the plaintiff falls within the statute’s “zone of interests.”
• This analysis follows Lexmark Int’l, Inc. v. Static Control Components, Inc., 572 U.S. 118 (2014) and Bank of America Corp. v. City of Miami, 581 U.S. 189 (2017), as applied in Kroma Makeup EU, LLC v. Boldface Licensing + Branding, Inc., 920 F.3d 704, 708 (11th Cir. 2019) and Physicians Multispecialty Group v. Health Care Plan of Horton Homes, Inc., 371 F.3d 1291 (11th Cir. 2004).
• This “standing” label is shorthand for a merits question: does the statute authorize this particular type of plaintiff to bring this particular type of claim?

E. Cat’s Paw Theory and Pretext

Where the entity alleged to have retaliated (here, the District) is not the plaintiff’s employer, but allegedly manipulates the actual employer into taking adverse action, plaintiffs sometimes invoke a “cat’s paw” theory:

• Under Stimpson v. City of Tuscaloosa, 186 F.3d 1328, 1332 (11th Cir. 1999), and Harris v. Public Health Trust of Miami‑Dade County, 82 F.4th 1296, 1301 (11th Cir. 2023), a cat’s paw theory requires evidence that:
  • a biased actor (the “puppeteer”) influenced
  • an ostensibly neutral decisionmaker (the “puppet”),
  • who then took adverse action without an independent investigation.
• If the ultimate decisionmaker conducts an independent investigation and reaches its own conclusion, the chain of causation is broken.

If the employer offers a legitimate, non-retaliatory reason for the adverse action, the plaintiff must then show pretext:

• That the stated reason is not the real reason, but a cover for retaliation or discrimination.
• Courts look for inconsistencies, implausibilities, or contradictions in the employer’s explanation. Combs v. Plantation Patterns, 106 F.3d 1519, 1538 (11th Cir. 1997).
• Courts do not second-guess the wisdom of business decisions—only whether unlawful motives drove them. Alvarez, 610 F.3d at 1266; Jimenez v. U.S. Attorney General, 146 F.4th 972, 997 (11th Cir. 2025).

V. Analysis of the Court’s Reasoning

A. The Discrimination Claim on Behalf of the Student

1. Choice of Analytical Framework: McDonnell Douglas vs. Deliberate Indifference vs. Convincing Mosaic

Quinn argued on appeal that the district court used the wrong framework to analyze her Title VI discrimination claim. The Eleventh Circuit notes:

• The district court actually evaluated the claim under both McDonnell Douglas and deliberate-indifference standards, citing tension in the caselaw but concluding that Quinn failed under either.
• The appellate panel agrees that, regardless of framework, the claim cannot survive summary judgment, and expressly declines to choose which test “best fits” Title VI student discrimination claims.
• Relying on Tynes v. Florida Dep’t of Juvenile Justice, 88 F.4th 939 (11th Cir. 2023), the court emphasizes that these frameworks are evidentiary tools, not separate causes of action. The central question remains whether the evidence would allow a reasonable jury to find race discrimination.

This is consistent with broader Eleventh Circuit and Supreme Court trends cautioning against elevating proof frameworks into substantive law. The court thereby signals that plaintiffs cannot win merely by insisting on one preferred doctrinal label; they must marshal sufficient facts under any reasonable approach.

2. Failure of the McDonnell Douglas Prima Facie Case: No Comparator

Under McDonnell Douglas, Quinn needed to identify a “similarly situated in all material respects” comparator who was treated differently. Lewis v. City of Union City, 918 F.3d 1213, 1226 (11th Cir. 2019) (en banc).

The court points out:

• Quinn’s discrimination claim was brought on behalf of her son, a student.
• The only comparator she offered was Owens, compared to Quinn herself—a counselor and parent—rather than to her son.
• There was no evidence that Owens or any District employee treated a similarly situated student of another race (or even of the same race) differently under similar circumstances.

Without such a comparator, Quinn could not establish the prima facie case under McDonnell Douglas, and the District was entitled to summary judgment on that theory.

This aspect of the opinion reinforces a strict comparator requirement in circumstantial Title VI school discrimination claims that follow the employment-law template. It also highlights a practical difficulty for student plaintiffs: frequently, a child’s experience may be singular or may not have readily observable comparators, particularly where the incident is idiosyncratic (such as the unusual utensil episode here).

3. No Deliberate Indifference: Adequacy of the District’s Response

The deliberate-indifference standard, derived from Title IX and constitutional jurisprudence, requires showing that the District knew of and disregarded an “excessive”—that is, “extremely great”—risk to the student’s health and safety. L.S., 982 F.3d at 1330 (quoting Waddell v. Hemerson, 329 F.3d 1300, 1306 (11th Cir. 2003)).

Crucially, a school district is not:

“deliberately indifferent simply because the measures it takes are ultimately ineffective in stopping [the conduct].”
—Sauls v. Pierce County Sch. Dist., 399 F.3d 1279, 1285 (11th Cir. 2005).

And under Gebser, deliberate indifference in the Title IX context means conduct that amounts to “an official decision by the [defendant] not to remedy the violation.” 524 U.S. at 290.

Applying these principles, the Eleventh Circuit emphasizes that:

• The District took the complaint seriously: Owens apologized; the principal reported up the chain; video was reviewed; and steps were taken to separate Owens and D.J.Q.
• The record indicates that the separation was largely successful; there was only one additional, non-detailed interaction with no new incident of harm.
• While Quinn argued that the District’s measures were belated and driven by her rather than by the District’s initiative, deliberate indifference focuses on the adequacy of the response, not its source.

The panel concludes that, even construing disputed facts in Quinn’s favor, no reasonable jury could find that the District’s response reflected an “official decision” to ignore the problem or constituted conscious disregard of a great risk to the child. Thus, the deliberate-indifference route is foreclosed.

4. No “Convincing Mosaic” of Racial Discrimination

The district court did not separately analyze the “convincing mosaic” theory, but the Eleventh Circuit does so briefly. A convincing mosaic approach allows a plaintiff to survive summary judgment without fitting precisely within McDonnell Douglas, provided the totality of circumstantial evidence reasonably supports an inference of discrimination. McCreight, 117 F.4th at 1335; see also Berry v. Crestwood Healthcare LP, 84 F.4th 1300, 1314–17 (11th Cir. 2023) (Abudu, J., concurring).

The court identifies two potentially relevant pieces of circumstantial evidence:

1. Owens’s January 2021 conduct toward the child, and
2. Owens’s alleged remarks on another occasion that there were “too many Mexicans in Walmart,” suggesting some racial or ethnic bias.

However, the court notes:

• There is no pattern of Owens targeting Black students generally, or D.J.Q. specifically, in a racially selective way.
• The asserted remark targets “Mexicans,” not Black persons like Quinn and her son; while it demonstrates some prejudiced thinking, there is no evidence linking it to the incident in question.
• Quinn’s belief—articulated more than a month after the fact—that the incident was racially motivated is subjective and unsupported by additional facts.

Under Anderson and Guevara, a plaintiff’s subjective belief or conjecture, unaccompanied by objective evidence, cannot by itself create a “genuine” dispute of material fact. Thus, the mosaic is incomplete; a reasonable jury could not infer intentional race discrimination from the scant circumstantial evidence.

B. The Retaliation Claims

1. Quinn’s Individual Retaliation Claim: Scope of Title VI and Causation

a. A “Seemingly Novel” Cause-of-Action Question

The panel recognizes, but sidesteps, a “seemingly novel” issue: whether Quinn, as a parent who is also a contractor working in a school (but not an employee of the federally funded entity), has a Title VI retaliation cause of action in her own right. The parties had cited:

• Title IX employee retaliation cases (like Jackson v. Birmingham Bd. of Educ., 544 U.S. 167 (2005) and Lowrey v. Texas A&M Univ. Sys., 117 F.3d 242 (5th Cir. 1997)), where employees of educational institutions can sue for retaliation; and
• Cases denying parents personal Title VI claims (e.g., Jackson v. Katy Indep. Sch. Dist., 951 F. Supp. 1293 (S.D. Tex. 1996); I.G. v. Jefferson County Sch. Dist., 452 F. Supp. 3d 989 (D. Colo. 2020); Murray v. Lakeland Cent. Sch. Dist., 2017 WL 4286658 (S.D.N.Y. Sept. 26, 2017)).

Quinn’s position is “in between”:

• She is not a direct employee of the District or of a Title VI funding recipient (in the manner of classic Title IX employee cases),
• but she is not merely a parent either; she is integrated into the school environment as a contracted counselor.

The Eleventh Circuit declines to resolve this doctrinal question because, even assuming Quinn has such a cause of action, she loses on the merits. This is a classic example of judicial minimalism: when the disposition is clear on narrower grounds, broader statutory-interpretation questions are left for another day.

b. Causation Breakdown and the Limits of Cat’s Paw Liability

Even assuming Quinn enjoys Title VI retaliation protection, the court identifies a fundamental “causation problem”:

• Quinn’s alleged adverse action is her removal from Parkway—a workplace change.
• But that action was taken by Magellan (her employer), not by the District, and was endorsed by the Department of Defense after its own investigation.
• The District merely informed Magellan about the situation; it had:
  • no contract with Magellan,
  • no authority to direct Magellan’s personnel decisions, and
  • no knowledge of Magellan’s internal conflict-of-interest policy that drove the reassignment.

Quinn attempted to overcome this gap via a “cat’s paw” theory—arguing the District, motivated by retaliatory animus, set in motion the chain of events leading Magellan to reassign her.

The Eleventh Circuit, citing Harris and Stimpson, notes that cat’s paw liability requires that the puppet decisionmaker:

• follow the biased recommendation without an independent investigation, and
• serve as mere conduit for the biased actor’s animus.

Here, the opposite occurred:

• Magellan discovered its pre-existing conflict-of-interest policy applied to Quinn’s situation.
• Magellan, per its federal contract, reported the matter to the Department of Defense.
• The federal government conducted its own independent investigation and agreed with Magellan’s recommendation that Quinn should be reassigned.

The court finds no evidence that:

• the District manipulated Magellan or the federal government,
• Magellan or the federal government simply rubber-stamped a District recommendation, or
• the District even knew about or intended to trigger Magellan’s policy.

Accordingly, any causal chain between Quinn’s protected activity (her complaints about Owens and the District) and her reassignment is broken by intervening, independent decisions of entities outside the District’s control.

c. Legitimate Non-Retaliatory Reason and Lack of Pretext

Even if Quinn could establish a prima facie case of retaliation, the District (and Magellan) articulated a legitimate, non-retaliatory reason:

• Magellan had a pre-existing policy prohibiting MFLC counselors from working at schools where their own children are enrolled.
• Upon learning of the conflict, Magellan and the federal government enforced that policy by reassigning Quinn.

To prove pretext, Quinn needed to show that this reason was not really why Magellan (and by extension, the District, if one could connect them) acted.

Quinn argued:

• She was never informed of the policy.
• The written policy did not explicitly cover her precise situation.
• In her view, there was no actual conflict of interest because she could remain objective.

The court finds this insufficient:

• Whether the policy is wise or fair is irrelevant. Courts do not function as “super-personnel departments” to second-guess business judgments. Jimenez, 146 F.4th at 997; Alvarez, 610 F.3d at 1266.
• Welch’s uncontradicted testimony was that the policy existed before the incident and had always been applied to avoid assigning counselors to their children’s schools.
• There is no evidence of any other counselor being treated differently under similar circumstances—that is, no comparator within Magellan’s policy enforcement.
• Quinn’s speculation that the policy might have been created or tailored in response to her incident is just that—speculation—and contradicts the employer’s sworn testimony without factual support. Under Harris, speculation cannot create a genuine factual dispute.

The court concludes that Quinn offered no evidence from which a reasonable jury could infer that Magellan’s policy was a pretext for retaliation. That is independently fatal to her retaliation claim.

2. The Retaliation Claim on Behalf of the Student

The retaliation claim brought on behalf of the child, D.J.Q., fails even earlier in the analysis. Under Johnson, a prima facie case of retaliation requires an adverse action directed at the plaintiff.

The court finds:

• Although the child was the victim of the original lunchroom incident, that incident preceded any protected activity and is the alleged discrimination, not retaliation.
• After Quinn began complaining, there is no evidence that the child:
  • was punished,
  • received worse treatment from the District because of the complaints, or
  • was denied benefits or subjected to new harassment in response to the protected activity.
• To the contrary, the District attempted to separate him from Owens and later granted the requested transfer to another school.

Because the child suffered no retaliatory adverse action, his Title VI retaliation claim cannot proceed.

3. No Convincing Mosaic of Retaliation

Finally, the court considers whether any convincing mosaic of retaliation exists for either plaintiff. It concludes that the evidence, even viewed favorably to Quinn, does not support such an inference:

• Magellan and the federal government conducted independent investigations and applied a neutral policy.
• There is no evidence the District directed or puppet-controlled these decisionmakers.
• No clear inconsistencies or shifting explanations suggest that retaliation, rather than the policy, drove the reassignment.

Therefore, even under a flexible circumstantial-evidence approach, no reasonable jury could find that retaliation occurred.

VI. Precedents Cited and Their Influence

Several key precedents shape the Eleventh Circuit’s analysis:

1. Summary Judgment and Evidence Weighing

• Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986): Establishes that a mere “scintilla” of evidence is insufficient; courts must ask whether a reasonable jury could find for the non-movant based on the evidence.
• Guevara v. Lafise Corp., 127 F.4th 824 (11th Cir. 2025): Reiterates the standard of drawing all reasonable inferences in favor of the non-moving party and emphasizes that factual disputes must be both genuine and material.
• Alvarez v. Royal Atlantic Developers, Inc., 610 F.3d 1253 (11th Cir. 2010): Allows appellate courts to affirm on any ground supported by the record, reinforcing that mislabeling or partial misanalysis below is not fatal if the result is correct.

2. Title VI/IX, Deliberate Indifference, and Institutional Liability

• Gebser v. Lago Vista Indep. Sch. Dist., 524 U.S. 274 (1998): Defines deliberate indifference in the Title IX context; requires an official decision not to remedy known discrimination.
• Sauls v. Pierce County Sch. Dist., 399 F.3d 1279 (11th Cir. 2005): Holds that a school’s measures need not be perfect; they need only not be clearly unreasonable to avoid deliberate indifference liability.
• L.S. ex rel. Hernandez v. Peterson, 982 F.3d 1323 (11th Cir. 2020) and Waddell v. Hemerson, 329 F.3d 1300 (11th Cir. 2003): Provide the “extremely great risk” formulation for deliberate indifference and government liability.

3. Discrimination Frameworks in Employment and Analogous Contexts

• McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973): The classic burden-shifting framework for circumstantial evidence discrimination claims.
• Lewis v. City of Union City, 918 F.3d 1213 (11th Cir. 2019) (en banc): Tightens the “similarly situated in all material respects” comparator standard.
• Tynes v. Florida Dep’t of Juvenile Justice, 88 F.4th 939 (11th Cir. 2023): Emphasizes that McDonnell Douglas is a procedural device, not a separate doctrinal universe, and that courts must ultimately focus on whether the evidence proves discrimination.
• McCreight v. AuburnBank, 117 F.4th 1322 (11th Cir. 2024) and Berry v. Crestwood Healthcare LP, 84 F.4th 1300 (11th Cir. 2023): Discuss the relationship and overlap between McDonnell Douglas and the “convincing mosaic” approach.

4. Retaliation, Cat’s Paw, and Pretext

• Stimpson v. City of Tuscaloosa, 186 F.3d 1328 (11th Cir. 1999): Introduces the cat’s paw theory in the circuit.
• Harris v. Public Health Trust of Miami‑Dade County, 82 F.4th 1296 (11th Cir. 2023): Clarifies cat’s paw elements and reaffirms the need for evidence that the ultimate decisionmaker failed to conduct an independent investigation.
• Combs v. Plantation Patterns, 106 F.3d 1519 (11th Cir. 1997): Explains the standard for proving pretext through showing that the employer’s explanation is “unworthy of credence.”
• Johnson v. Miami‑Dade County, 948 F.3d 1318 (11th Cir. 2020): Sets out the basic elements of a prima facie retaliation case (protected conduct, adverse action, causation).
• Alvarez and Jimenez v. U.S. Attorney General, 146 F.4th 972 (11th Cir. 2025): Caution courts not to act as super-personnel departments and not to second-guess business decisions absent evidence of discriminatory or retaliatory motives.

5. Statutory Cause of Action / “Standing” Under Title VI

• Consolidated Rail Corp. v. Darrone, 465 U.S. 624 (1984): Suggests in a footnote that employment discrimination suits under certain federal funding statutes are limited to situations where the primary purpose of the federal assistance is to provide employment, influencing lower courts’ view of Title VI employment-related claims.
• Lexmark Int’l, Inc. v. Static Control Components, Inc., 572 U.S. 118 (2014) and Bank of America Corp. v. City of Miami, 581 U.S. 189 (2017): Distinguish Article III standing from the question whether a statute authorizes a particular plaintiff to sue.
• Physicians Multispecialty Group v. Health Care Plan of Horton Homes, Inc., 371 F.3d 1291 (11th Cir. 2004) and Kroma Makeup EU, LLC v. Boldface Licensing + Branding, Inc., 920 F.3d 704 (11th Cir. 2019): Apply Lexmark to treat such “standing” disputes as non-jurisdictional merits questions.

VII. Complex Concepts Simplified

1. Title VI vs. Title IX

• Title VI prohibits race, color, and national-origin discrimination in any program or activity receiving federal financial assistance.
• Title IX prohibits sex discrimination in educational programs receiving federal funds.
• Courts often borrow Title IX standards (e.g., deliberate indifference) when analyzing Title VI claims in educational settings because both statutes share similar structures and enforcement mechanisms.

2. Summary Judgment

Summary judgment allows a court to resolve a case without trial if:

• there is no genuine dispute about any material fact, and
• the moving party is entitled to judgment as a matter of law.

A “material” fact is one that could affect the outcome of the case. A dispute is “genuine” only if a reasonable jury could find for the non-moving party based on the evidence, not on speculation or mere assertions.

3. Prima Facie Case and Burden-Shifting (McDonnell Douglas)

In discrimination cases based on circumstantial evidence:

1. The plaintiff must first establish a prima facie case (meeting set elements, including showing a similarly situated person of a different protected characteristic treated more favorably).
2. The burden shifts to the defendant to articulate a legitimate, non-discriminatory (or non-retaliatory) reason for its conduct.
3. The burden then returns to the plaintiff to show that the proffered reason is a pretext—a false explanation intended to cover up unlawful discrimination or retaliation.

4. “Similarly Situated in All Material Respects”

To be a valid comparator, another person must:

• have engaged in the same or similar conduct,
• be subject to the same decisionmaker and policies, and
• share key relevant circumstances with the plaintiff (e.g., position, performance, disciplinary history).

This ensures that any differential treatment is attributable to discriminatory motive rather than to non-comparable factual differences.

5. Deliberate Indifference in School Discrimination Cases

Deliberate indifference is more than mere negligence. A school district is deliberately indifferent if:

• it has actual knowledge of discrimination or harassment that poses a serious risk, and
• its response is clearly unreasonable in light of the known circumstances—effectively, a decision not to remedy the situation.

Showing that the response was imperfect or that some harm continued is usually not enough; the response must be so inadequate that it amounts to willful blindness or conscious disregard of a great risk.

6. Convincing Mosaic

A “convincing mosaic” is a way of describing a collection of circumstantial facts that, taken together, support a reasonable inference of discrimination or retaliation even if none is individually conclusive. Examples can include:

• inconsistent explanations by the employer,
• statements suggesting bias,
• statistical patterns,
• suspicious timing, and
• comparative evidence of other people treated differently.

7. Cat’s Paw Theory

Named after a fable, the cat’s paw theory applies where:

• a biased subordinate or third party (the “monkey”) manipulates
• a decisionmaker (the “cat”) into acting against the plaintiff,
• such that the decisionmaker becomes an unwitting instrument of the biased actor’s animus.

Courts look for:

• evidence of the biased actor’s influence, and
• a lack of independent investigation by the decisionmaker.

If the decisionmaker independently considers the facts and reaches its own conclusion, cat’s paw liability is generally unavailable.

8. Statutory “Standing” / Zone of Interests

Beyond constitutional (Article III) standing, courts ask whether the statute in question allows this plaintiff to sue for this type of injury. This is sometimes called the “zone of interests” test. After Lexmark:

• it is not a jurisdictional issue; rather, it goes to whether the plaintiff has a valid cause of action under the statute, and
• its violation leads to dismissal on the merits, not for lack of subject-matter jurisdiction.

VIII. Impact and Significance

A. For Students and Parents Bringing Title VI Claims

The case underscores several practical realities for would-be Title VI plaintiffs:

• A single disturbing incident, without clear racial overtones or pattern, is unlikely to support a Title VI discrimination claim. Plaintiffs should expect to need either:
  • comparators (other students treated differently),
  • a history or pattern of similar incidents, or
  • specific evidence (e.g., statements, prior conduct) tying the conduct to race.
• Deliberate indifference is a high bar. Even where a student suffers emotional trauma, a school that apologizes, adjusts schedules, and limits contact between the student and the offending employee will usually be found to have responded adequately, absent much more egregious facts.
• Retaliation on behalf of a child requires retaliatory conduct toward the child. Even if a parent believes the school district is hostile toward them personally for complaining, the child’s retaliation claim fails without adverse action directed at the child.

While the panel acknowledges that “the facts of this case are concerning” and that parents should not have to worry about physical mistreatment of their children by school staff, it emphasizes the controlled scope of Title VI liability as currently interpreted.

B. For School Districts and Education Administrators

The decision, though unpublished, offers guidance:

• Prompt, documented remedial actions matter. Reporting up the chain, reviewing available evidence (e.g., video), arranging apologies, and restructuring schedules to avoid further contact can be sufficient to defeat deliberate-indifference claims.
• Neutral handling of parental complaints is critical. Although the District contacted Magellan about the “situation,” the court saw no evidence of retaliatory motive, particularly given the absence of any disciplinary recommendation about Quinn herself and the District’s lack of knowledge of Magellan’s policy.
• Cooperation with external entities can break causation chains. When independent contractors and federal agencies conduct their own investigations and apply their own policies, that tends to shield the school district from cat’s paw liability.

C. For Contractors and Third-Party Employers in School Settings

The case has implications for entities like Magellan and similar contractors:

• Internal conflict-of-interest policies can provide legitimate grounds for personnel actions. Courts are reluctant to treat the enforcement of facially neutral, pre-existing policies as pretext absent evidence of inconsistent application or suspicious timing.
• Documentation and consistency in policy enforcement are crucial. Welch’s testimony about the longstanding policy and its consistent application was pivotal in defeating pretext arguments.
• Communication gaps (failure to advise employees of policies) may be unfortunate but are not, by themselves, evidence of retaliation.

D. For Future Litigation: Unresolved Questions About Title VI Retaliation

Notably, the decision:

• does not resolve whether a parent who is also a contractor embedded in the school environment has a personal Title VI retaliation cause of action;
• leaves intact district court decisions from other circuits denying parents personal Title VI claims while suggesting that employment-oriented retaliation claims may be viable in some contexts; and
• signals that, in a future case with a clearer employment relationship and clearer causation, the Eleventh Circuit may need to address directly the scope of Title VI retaliation protections and their overlap with Title IX doctrine.

Thus, while Quinn does not create new binding law on who may sue under Title VI, it highlights a doctrinal gap ripe for further development.

E. Nonprecedential but Persuasive Value

Because the opinion is expressly “NOT FOR PUBLICATION,” it is not binding precedent within the Eleventh Circuit. Still, it carries persuasive authority and:

• illustrates how panels are likely to treat similar Title VI discrimination and retaliation claims,
• applies and harmonizes recent Eleventh Circuit decisions on summary judgment, discrimination frameworks, and cat’s paw liability, and
• may guide district courts within the circuit when faced with analogous fact patterns.

IX. Conclusion

Quinn v. Columbia County School District is an important application of Title VI jurisprudence, particularly in the increasingly common context where:

• the alleged discrimination occurs in a public school setting,
• a parent is also a contracted mental-health or family-life counselor in the same schools, and
• adverse employment actions are taken not by the school district but by a private contractor and a federal agency.

The Eleventh Circuit:

• reaffirms the stringent proof requirements for intentional race discrimination and deliberate-indifference liability under Title VI,
• clarifies that neutral, pre-existing conflict-of-interest policies can lawfully justify employment reassignments even when triggered by contentious complaints,
• limits the reach of cat’s paw theories where independent investigations by non-biased actors intervene, and
• underscores that Title VI retaliation requires demonstrable adverse action linked to the protected activity and directed at the plaintiff.

While the court recognizes the troubling character of the underlying incident, it ultimately holds that Title VI does not provide a remedy on this record. The decision thus serves as a cautionary illustration: without concrete evidence connecting adverse treatment to race or to retaliatory motives—and without adverse action directed at the party asserting retaliation—Title VI claims, however emotionally compelling, will not survive summary judgment.